EPA held an August 16 public meeting to discuss the implementation of the Reduction of Lead in Drinking Water Act of 2011. As of January, 2014, the Act will amend Section 1417 of the Safe Drinking Water Act (SDWA) to establish more stringent criteria for defining products as “lead free” under the SDWA. The main component of the new, stricter definition of “lead free” requires that wetted surfaces of pipes, pipe fittings, plumbing fittings and fixtures contain less than 0.25 percent lead, down from the previous 8 percent limit required to be considered “lead free” under SDWA.
Most manufacturers are already in the process of adhering to the new definitions, but utilities need to be vigilant in their procurement processes going forward. One of the most prominent concerns for water utilities is making sure that parts in replacement inventories are meeting the new definition by 2014, a process that should be underway sooner rather than later.
Additional implementation challenges such as labeling criteria and replacement requirements during repairs are also expected to arise from the new definition, but will not be addressed by 2014 when the new definition goes into effect. EPA said during the August 16 meeting that it was contemplating guidance on these potential issues and would need to follow with final clarifications via a rulemaking process, specifically, as part of the long-term revisions to the Lead and Copper Rule (LCR) currently under development. Because it is already in the development process, the revised LCR provides the quickest path to finalize any additional issues related to the new lead free definition, though it will make an already complicated rulemaking even more cumbersome.
Additional information on the new “lead-free” definition and its potential implications is available in the EPA’s August 16 presentation for the meeting, available on AMWA’s website at http://www.amwa.net/cs/members_only/regulatory_committee.