The document provides an overview of the requirements for lead in plumbing products under the Safe Drinking Water Act and the Reduction of Lead in Drinking Water Act. Key points include that as of January 2014, the maximum allowable lead content was lowered to 0.25% for pipes, fittings, and other plumbing products that convey water for human consumption. States are responsible for enforcing these requirements, often through building and plumbing codes. The role of code officials is to ensure compliant products are installed and help identify approved products, which have varying certification standards between manufacturers.
1. Safe Drinking Water Act:
2014 Requirements for
Lead in Plumbing
Products
Shawn Martin
Director of PMG Activities
International Code
Council
10/31/2013 VersionSafe Drinking Water Act
2. Disclaimer
This presentation is for information purposes
only and is not intended to be legal advice.
Should any party need legal advice
regarding the information contained herein,
they should contact their own counsel who
specializes in this area of law.
Safe Drinking Water Act 2
3. Description
Overview of the critical concepts of the "Reduction of
Lead in Drinking Water Act”
Focuses on the role of the code official implementing the law.
Note: References to FAQ in the document are to the Summary
Of The Reduction Of Lead In Drinking Water Act And Frequently
Asked Questions, U.S. EPA, October, 2013 which was recently
released in October, 2013.
Brought to you by the by ICC PMG Membership Council
and ICC Evaluation Service
Safe Drinking Water Act 3
4. Why Lead in Plumbing?
Lead has a long association with plumbing.
Safe Drinking Water Act 4
Term plumbing is based on the Latin
word “plumbum”
Wide use for plumbing pipes and fittings
and solder even into modern times.
More recently it is used as an
alloying element in cast bronze and
brass
Improves machinability
Reduces porosity
Resistant to corrosion
5. Health Effects of Lead
Lead causes a range of issues in adults and
children – many are lifelong
Neurotoxin that affects central nervous and
reproductive systems
Especially harmful to children and pregnant
women
Builds up - accumulates in bone and fat tissue
Lowers IQ, create behavioral issues, slow growth
“No safe blood level of lead has been identified.”1
Safe Drinking Water Act 51: CDC: Blood Lead Levels in Children Aged 1-5 Years – U.S., 1999-2010
Sources: food, water, contaminated soil, dust, paint, ceramics
6. Lead Poisoning Prevention Policy and
Children’s Average Blood Lead Levels
‘92‘76 ‘80 ‘82 ‘84 ‘86 ‘88 ‘90 ‘94 ‘96 ‘98
Year
‘72
BloodLeadLevels(µ/dL)
18
2
4
6
8
10
12
14
16
0
‘00‘78
Residential
Lead Paint
Ban (1978)
Lead Contamination
Control Act (1988)
Virtual Elimination of
Lead in Gasoline
2.7 %
2.2 %
Lead in
Plumbing <8%
(SDWA 1986)
‘02 ‘04
1.2 %
‘06
0.6 %
Ban on lead solder
in food cans (1995)
Lead Title X
(1992)
Housing units with
lead based paint
hazards reduced by
40% since 1990
‘74
Lead
Gasoline
Phase-out
(1973)
Source: U.S. Centers for Disease Control
7. Why Change?
EPA: Drinking water remains a
significant source of lead exposure:
10-20% of ingested lead
CDC: No safe blood level of lead.
NSF: Lead leaching is not directly
proportional to the level of lead in
the product.*
Lower lead alternative materials.
Better lead detection methods.
Safe Drinking Water Act 7
* McLellan, C., Purkiss, D., & Greiner, P., Interim Report on Extraction Results on Leaded
Products Submitted for Evaluation Under NSF/ANSI 61, NSF International, June 2005.
8. Current Safe Drinking Water Act
No person may use any pipe, any pipe or plumbing fitting or fixture,
any solder, or any flux, after June 19, 1986, in the installation or
repair of—
(i) any public water system; or
(ii) any plumbing in a residential or nonresidential facility providing water for
human consumption, that is not LEAD FREE (within the meaning of subsection
(d) of this section). [42 USC § 300g-6]
Safe Drinking Water Act 9
< 8.0% for
Pipes, Pipe
Fittings
< 0.2 % for
Solders and
Flux
Drinking. Teeth
Brushing,
Food Prep,
Maintain Oral
Hygiene
(FAQ #7)
9. Reduction of Lead in Drinking
Water Act
Reduction of Lead in Drinking Water Act
Signed January 4, 2011
Effective January 4, 2014
Amends the Safe Drinking Water Act
The amended definition of “lead free” is provided
0.20% max lead for solder and flux
0.25% max lead for products by weighted average
Multiple component products are calculated to address total
wetted exposure based upon wetted surface area of each
component and that component’s lead content by percentage
Safe Drinking Water Act 10Source: Get The Lead Out Consortium Presentation
10. New Calculation Method
Applies only to wetted surface area
Averages lead content at the surface of each wetted part
Safe Drinking Water Act 11
Weighted Average Lead Content
11. 2012 International Plumbing
Code
605.2 Lead content of water supply pipe and
fittings. Pipe and pipe fittings, including valves
and faucets, utilized in the water supply system
shall have a maximum of 8-percent lead content.
NSF 61-2008 compliance required for
Safe Drinking Water Act 12
Faucets & fixture fittings
(424.1)
Water service pipe (605.3)
Distribution pipe (605.4)
Fittings (605.5)
Ball, gate, globe valves
(605.7)
DWTU tubing (611.3)
Fountains and coolers
(410.1)
12. 2015 International Plumbing
Code
Previous section on 8% lead remains. (FAQ #11)
“605.2 Lead content of water supply pipe and fittings. Pipe and
pipe fittings, including valves and faucets, utilized in the water supply
system shall have a maximum of 8-percent lead content.”
New proposal approved to add the following provision
(FAQ #19,21) :
“605.2.1 Lead content of drinking water pipe and fittings. Pipe,
pipe fittings, joints, valves, faucets, and fixture fittings utilized to supply
water for drinking or cooking purposes shall comply with NSF 372 and
shall have a weighted average lead content of 0.25 percent lead or
less.”
NSF 61 requirements remain. (FAQ#18)
Safe Drinking Water Act 13
13. What Products Are Covered?
Safe Drinking Water Act 14
Specifically Excluded Not Specifically Addressed
Toilets, Bidets, Urinals and Associated Flush
and Fill Valves
Water Heaters, Hot Water
Fixtures and Fittings
Tub fillers, Shower Valves Replacement Parts
Service Saddles Showerheads
Main Dist. Gate Valves >2” Diameter Hose Bibbs
Includes: “…any pipe or plumbing fitting or fixture… in a
residential or non-residential facility providing water for human
consumption.”
Excludes: “other uses where the water is not anticipated to be
used for human consumption.”
FAQ #6
FAQ #23-30
FAQ #9
15. Dual-Use Potable and Non-
Potable Products
Guidance Released by EPA in October, 2013
(FAQ #10, 12, 13) allows for higher lead content
product to be sold if labeled for exclusive non-
potable use.
Clear and prominent marking
Separate packaging and product labeling
Code enforcement officials should watch for and
flag installation of non-potable components in
potable applications.
Safe Drinking Water Act 16Summary of the Reduction Of Lead In Drinking Water Act &
Frequently Asked Questions, U.S. EPA, October, 2013
17. Enforcement – Role of the Code
Official
Enforcement of lead requirements for
installation/use is assigned to the states.
EPA can sanction states for failing to enforce
Primary enforcement mechanism through
building/plumbing codes.
States may assign other responsible parties
(e.g. DTSC in California)
Safe Drinking Water Act 18
18. Other Important Questions
What about replacement parts?
What about repair and return to service?
Are hot water systems considered sources
of potable water?
What about fire sprinklers, hydrants?
Do coated products comply?
Is retrofit required?
What about projects in progress?
Safe Drinking Water Act 19
?
FAQ #6
FAQ #23,29
FAQ #23
FAQ #17
FAQ #15
FAQ #23-30
FAQ #5
19. What about the states?
States may impose additional restrictions,
requirements – cannot be less stringent.
CA, LA, MD, VT currently have similar low-lead
requirements in place.
Certification, compliance requirements vary
Differing guidance on affected products
BE AWARE OF YOUR LOCAL STATE
REQUIREMENTS
8% lead limit
NSF 61
Safe Drinking Water Act 20
20. Key Difference Between
State and Federal Laws
California/Vermont/Maryland/Louisiana – applies
to any product intended to convey or dispense
water for human consumption through drinking
or cooking
Federal – Applies to any product used in
systems where water is anticipated to be used
for human consumption
Could be interpreted to cover a much broader group
of products than state laws
Safe Drinking Water Act 21Source: Get The Lead Out Consortium Presentation
21. Identifying Compliant Product
NO SINGLE WAY TO SHOW COMPLIANCE – VARIES
BETWEEN MANUFACTURERS
Options
Third-party certification to NSF 372, NSF 61 Annex G
Third-party certification to SDWA, State Lead Laws
Self-certification
Vehicles
Third-party certification listing
Product or packaging marking
Specification sheet
Manufacturer declaration (document, website)
Safe Drinking Water Act 22
Third Party
Certification
NOT
required by
SDWA
(FAQ #19)
22. Certification Marks
Safe Drinking Water Act 23How to Identify Lead-Free Certification Marks for Drinking
Water Plumbing Materials, USEPA
26. Summary and Conclusion
New federal lead requirements effective January 4, 2014
Reduce allowable lead content in potable plumbing
components to 0.25% (installed or sold)
No requirement for retrofit.
Enforcement at state level usually through codes
No single compliance mark – varies widely
States may have additional, more stringent requirements
More clarification and guidance from the EPA and states
is expected…
Safe Drinking Water Act 27
27. More Information from ICC
Resource Links: www.iccsafe.org/pmg
PMG Membership Council (free for members)
ICC-ES PMG: www.icc-es-pmg.org
Safe Drinking Water Act 28
Click
Resources
Tab
Shawn:
This webinar is geared specifically for code officials and arose out of questions coming from ICC Chapters and individuals.
Manufacturers with questions regarding certification of specific products meet the requirements of state and federal lead laws should consider contacting ICC-ES PMG.
Shawn
Shawn
What are the Health Effects of Lead?
Lead can affect almost every organ and system in your body. Children six years old and younger are most susceptible to the effects of lead.
Children
In children, the main target for lead toxicity is the nervous system. Even very low levels of lead in the blood of children can result in:
Permanent damage to the brain and nervous system, leading to behavior and learning problems, lower IQ, and hearing problems
Slowed growth
Anemia
In rare cases, ingestion of lead can cause seizures, coma and even death.
Pregnant Women
Lead can accumulate in our bodies over time, where it is stored in bones along with calcium. During pregnancy, lead is released from bones as maternal calcium is used to help form the bones of the fetus. This is particularly true if a woman does not have enough dietary calcium. Lead can also be circulated from the mother’s blood stream through the placenta to the fetus. Lead in a pregnant woman’s body can result in serious effects on the pregnancy and her developing fetus, including:
Miscarriage
Reduced growth of the fetus and premature birth
Find out more about lead's effects on pregnancy:
March of Dimes Healthy Pregnancy Exit
Effects of Workplace Hazards on Female Reproductive Health, National Institute for Occupational Safety and Health
Lead can also be transmitted through breast milk. Read more on lead exposure in pregnancy and lactating women (PDF) (302 pp, 4.2 MB, About PDF).
Adults
Lead is also harmful to other adults. Adults exposed to lead can suffer from:
Nervous system effects
Cardiovascular effects, in increased blood pressure and incidence of hypertension
Decreased kidney function
Reproductive problems (in both men and women)
Read more on the health effects of lead at the Agency for Toxic Substances and Disease Registry (ATSDR).
Potable Services: Services or applications that provide water suitable forhuman ingestion
Lee Starts
Is the International Plumbing Code changing in response to the revisions to the Safe
Drinking Water Act?
Yes. A proposal was submitted during the code development process
to insert the following language into the 2015 IPC:
“605.2.1 Lead content of drinking water pipe and fittings.
Pipe, pipe fittings, joints,
valves, faucets, and fixture fittings utilized to supply water for drinking or cooking
purposes shall comply with NSF 372 and shall have a weighted average lead content of
0.25 percent lead or less
.“
4
While the 2015 IPC, which will be released in 2014
,
will require NSF 372 certification to
comply with the new Safe Drinking Water Act provisions
,
;
it will take varying amounts of
time until jurisdictions elect to adopt the new version of the code.
Is the International Plumbing Code changing in response to the revisions to the Safe
Drinking Water Act?
Yes. A proposal was submitted during the code development process
to insert the following language into the 2015 IPC:
“605.2.1 Lead content of drinking water pipe and fittings.
Pipe, pipe fittings, joints,
valves, faucets, and fixture fittings utilized to supply water for drinking or cooking
purposes shall comply with NSF 372 and shall have a weighted average lead content of
0.25 percent lead or less
.“
4
While the 2015 IPC, which will be released in 2014
,
will require NSF 372 certification to
comply with the new Safe Drinking Water Act provisions
,
;
it will take varying amounts of
time until jurisdictions elect to adopt the new version of the code.
Free Requirement Exemptions
(A) The new requirement does not apply to pipes, pipe fittings, plumbing fittings, or fixtures, including backflow preventers, that are used exclusively for nonpotable services, such as manufacturing, industrial processing, irrigation, outdoor watering, or any other uses where the water is not anticipated to be used for human consumption.
(B) The new requirement does not apply to toilets, bidets, urinals, fill valves, flushometer valves, tub fillers, shower valves, service saddles, or water distribution main gate valves 2 inches in diameter or larger.
Free Requirement Exemptions
(A) The new requirement does not apply to pipes, pipe fittings, plumbing fittings, or fixtures, including backflow preventers, that are used exclusively for nonpotable services, such as manufacturing, industrial processing, irrigation, outdoor watering, or any other uses where the water is not anticipated to be used for human consumption.
(B) The new requirement does not apply to toilets, bidets, urinals, fill valves, flushometer valves, tub fillers, shower valves, service saddles, or water distribution main gate valves 2 inches in diameter or larger.
DTSC = California Department of Toxic Substance Control
Lee ends
Lee ends, Shawn re-starts
Lee
Shawn
Since the information on this issue is still changing, it’s important for code officials and manufacturers to have reliable sources. To make it easier, ICC has collected a wide range of sources of information into a single list, which is available for download on the PMG Website as shown, under the Resources Tab. Another ongoing source of information for ICC members if the PMG Membership Council, which is free for ICC members. That council raised the need for information among ICC members, and continues to update its members on new information as it becomes available.
If you are a manufacturer who needs information on compliance and certification of a specific plumbing product, you should consider contacting ICC Evaluation Service’s PMG Group. Their website is provided above and a specific contact is provided at the end of this presentation.
Lastly, ICC is a member of the Get the Lead Out Consortium, and their resources are also a good source of information. Specific links are provided on the resource list above.