The U.S. Environmental Protection Agency announced earlier this year that back inventory of products not meeting the definition of lead-free under the Reduction of Lead in Drinking Water Act [PDF] can no longer be used after January 3, 2014, unless the product is exempted under the law. NGWA members should plan their production, purchasing, and inventory management to meet this deadline in the United States.
The Reduction of Lead in Drinking Water Act changed the definition of lead-free to mean not containing more than a weighted average of 0.25% lead when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures.
As of January 4, 2014, no person may introduce into commerce or use any pipe, or plumbing fitting or fixture, in the installation or repair of any public water system or any plumbing in a residential or nonresidential facility providing water for human consumption, that is not lead-free under this new definition.
Back inventory that does not meet the 0.25% lead-free calculation cannot be installed after January 3, 2014, unless it is exempt from the prohibitions. The definition of lead-free solder and flux—0.2% lead—was not affected by the Act.
Exemptions are provided for 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. Also specifically exempted are toilets, bidets, urinals, fill valves, flushometer valves, tub fillers, shower valves, service saddles, or water distribution main gate valves that are 2 inches in diameter or larger.
Some states such as California, Maryland, and Vermont have already adopted and implemented their own 0.25% lead-content standards. The federal action is separate from these state laws. However, NGWA members may get some idea of what the transition under federal law may mean from state experience.
Jeffrey W. Williams, MGWC, CVCLD, vice president of Spafford & Sons Water Wells in Jericho, Vermont, said he spent 14 months reducing his on-hand materials to comply with Vermont’s lower lead limits. Even so, he reports he still had 15% of his product inventory that didn’t comply with that state’s law.
“From my experience, it certainly helps to start the transition process early to prevent any future issues,” said Williams, a member of the NGWA Board of Directors. “I believe we as an industry need to be as proactive as possible in preparing for this new law and the rules that follow.”
Throughout the United States manufacturers in the groundwater industry are taking the necessary steps to comply with the Reduction of Lead in Drinking Water Act.
Mo Rainey, vice president of Simmons Manufacturing Co. in McDonough, Georgia, reports that the company plans to transition over the next several months to the new lower lead standard for its affected products well ahead of the January 4, 2014 deadline.
Rainey also stresses the importance of clear business communication throughout the supply chain in advance of this deadline.
“We have to get beyond the principals and somehow reach down to the purchasing agents and sales people so they are aware,” he said. Rainey sees sales people as especially critical to getting the word out to the contractors.
Contractors and suppliers developing their purchasing and inventory control plans should also check on return policies. Simmons Manufacturing is notifying its customers that returns may only be credited at scrap value as time moves forward as they, like contractors and distributors, will not be able to sell the older leaded products under the new law.
As covered in past issues of the Water Well Journal, the EPA developed a draft FAQ document and sought comments on it. NGWA will continue to maintain implementation of the law and provide any additional updates to the FAQ or rules.