makingSenseNSF

The last round of Federal legislation on the Safe Drinking Water Act was effective January 2014. So why is this still news to our engineering and municipal customers? Here are just a few very important reasons:

  • Any sale or new installation of non-compliant products can result in punitive action such as fines or the forced replacement of parts. So these regulations need to be top-of-mind when specifying and procuring equipment and components.
  • Given the cost/burden of equipment modification and inventory, not all manufacturers or their upstream component/materials suppliers are compliant yet. And many manufacturers reps are confused or misinformed about ​both Federal and State requirements
  • Since the revised Federal law made certification voluntary in 2011, assuring that equipment complies with all regulations can be even more confusing.
  • The responsibility for compliance ultimately rests with you.

A Quick History

The Safe Drinking Water Act (SWDA), and Lead and Copper Rule (LCR), were enacted 40 and 35 years ago respectively, although both have been through several changes since. The original legislation prohibited the use of pipes, solder or flux that weren’t “lead free” in public water systems or plumbing in facilities providing water for human consumption. At the time “lead free” was considered ≤ 0.2% in solder/flux and ≤ 8% in pipes. In 1996, the SWDA was amended, requiring endpoint devices (plumbing fittings and fixtures) to comply with lead leaching standards developed by EPA appointed 3rd party certifiers. It also prohibited the sale or use of any pipe, plumbing fitting or fixture that was not lead-free.

The most pertinent, yet the most confusing impact to today’s municipal applications came with the Reduction of Lead in Drinking Water Act of 2011 (RLDWA). This act modified SDWA Section 1417 by tightening the definition of “lead-free”, creating exemptions to the existing lead prohibitions and eliminating the federal requirement for plumbing fittings and fixtures to comply with 3rd party standards. The Act allowed manufacturers, distributors and end users 3 years to modify equipment so that by January 2014, all pipes, pipe fittings, plumbing fittings and fixtures used for potable water must meet a weighted average lead content of ≤ 0.25% (rather than 8%, with solder and flux held at 0.20%).

The RLDWA extends to all drinking water products sold or installed for public water systems or plumbing in facilities and prohibits installation of any back inventory. Since this Act removed certification requirements or enforcement language other than what is already in the SDWA, it’s incumbent on local inspectors to police installed products for compliance. A high probability was anticipated that some leaded product would be field marked as no-lead, requiring factory diligence to extract falsified no-lead returned goods3.

Despite Federal law removal of certification, it’s extremely important to check your State and local mandates (see chart below). Third-party certification by a standards entity such as NSF International is mandated for components of many water systems in many states. Moreover, going beyond a manufacturer’s mere statement of compliance, certification ensures independent, accredited validation from a trusted source. Standards that are pertinent to water works equipment are described below.

Key standards: NSF 61, 61-G and 372

NSF/ANSI Standard 61–Drinking Water System Components Health Effects was originally published in 1988 to create minimum requirements to control potentially adverse human health effects from products that contact drinking water. This standard restricted both 1) the level of lead that can be contained in materials that contact drinking water products, and 2) the level of lead that can extract (leach) out of materials and into drinking water (as of 2012, a 5 ppb maximum lead leach that applies to all wetted materials, including rubbers, plastics, adhesives, lubricants, etc.)

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NSF/ANSI 61 Annex G – in 2008, Annex G amended Standard 61 to establish requirements for use when a ≤0.25% lead mandate needs to be met in addition to maintaining other chemical extraction requirements of NSF/ANSI 61. In 2010, Annex G’s lead content evaluation procedures were essentially moved to a new NSF/ANSI Standard 372. Annex G was updated to reference NSF/ANSI 372, but remained relevant only to products that fall under the scope of NSF/ANSI 61.

NSF/ANSI 372 – was introduced in 2011 to establish procedures to meet the 0.25% lead content requirement of the RLDWA using a wetted surface area average calculation or just simply using all no-lead materials for areas in contact with drinking water. NSF/ANSI 372 includes a broader scope of drinking water products covered by the law which may not be covered under NSF/ANSI 61 (e.g. coffee machines; food service equipment) and enables large or complex products and assemblies to achieve certification for the 2014 lead-free law that previously were unable to be certified under Standard 61. Note however, that NSF 372 is a lead-only prescriptive-based standard as compared to NSF 61-G’s performance-based requirements.

While Standard 372 was originally intended to replace Annex G as the 0.25% lead-free standard, there will be concurrent certifications for both NSF 61-G and NSF 372 until the market and certifiers sort out the implementation problems and make course corrections. So for the time being, all products certified as compliant with Annex G are also compliant with NSF/ANSI 372.
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Since 2014, pertinent NSF certifications can be identified by way of an equipment plaque. Look for these markings on the equipment and associated literature:

  • NSF®-61-G = the product is certified to all requirement of NSF/ANSI 61 (health effects) and all requirements of Annex G and NSF/ANSI 372 (lead content)
  • NSF®-372 = the product is only certified to NSF/ANSI 372 for lead content

PP&S Environmental Product Compliance

The simplest and safest way to assure you are compliant with all regulations is by purchasing fully certified equipment. PP&S offers a wide range of pumps, seals, peripheral equipment and epoxies that are certified to meet or exceed Federal, NC and SC state requirements:

NSF/ANSI 61-G/NSF 372 ​Certified (health effects + lead):
Flowserve® – full range of ANSI, vertical and submersible pumps
Griffco Valves – back pressure and pressure relief valves, calibration cylinders
ITW Polymers Adhesives – epoxy grouts
Pulsed Hydraulics – mixing systems

NSF/ANSI 61​ ​Certified (health effects):
​Axiall
– ​chlorination systems

What’s Ahead

The EPA held a public meeting in April 2015 to obtain input on potential revisions to regulations for the Prohibition on Use of Lead Pipes, Solder and Flux under the SWDA4. The input received from various industry segments at this public meeting was made available through the AWWA. Of particular interest is the presentation on the challenges for public utilities starting on slide 40. Peter Grevatt, Director of the EPA’s Office of Ground Water and Drinking Water (OGWDW) cited scale and quality as the two major pain points, indicating that 77% of the nation’s public water systems are struggling to meet regulatory requirements due to the lack of resources. He concurred that the Reduction of Lead In Drinking Water Act (RLDWA) needs revisions to sort out issues of clarity and complexity.5 We'll keep you informed as more information is released.

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1 - NSF Overview of Lead-Free Compliance
2 - http://www.nsf.org/newsroom_pdf/ASDWA_Survey.pdf
3 - http://www.wasda.com/pdf/NL_Regulatory_Change_Overview_2012-2014.pdf
4 - http://www.gpo.gov/fdsys/pkg/FR-2015-03-31/html/2015-07375.htm
5 - http://www.wateronline.com/doc/what-s-going-on-at-the-epa-0001

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There’s a lot of confusing and even misleading information on the internet, so we’ve compiled the most authoritative web resources for you below. Be sure to speak with a PP&S application engineer or your KAM for support with applying these regulations when specifying equipment for municipal applications:

Standards + certification

​Legislation

Industry Organizations

Download a Quick ​Reference