Northeast-Midwest Institute safe drinking water expert Elin Betanzo submitted comments on the Environmental Protection Agency’s Federal Register notice on the proposed rule Use of Lead Free Pipes, Fittings, Fixtures, Solder and Flux for Drinking Water. This regulation is intended to codify and clarify requirements under the Reduction of Lead in Drinking Water Act of 2011 (RLDWA) and the Community Fire Safety Act of 2013 (CFSA) which revise the definition of “lead free” to lead content at .25 percent of the wetted perimeter of a pipe, fitting or fixture.
This rule is an essential companion to the Lead and Copper Rule (LCR), which establishes requirements for lead sampling at customers’ taps and treatment requirements for reducing lead levels when high lead is measured at customers’ taps. While corrosion control is effective for reducing lead exposure at the tap, it is not foolproof for preventing lead exposure. Any time lead is in contact with drinking water there is a risk of lead exposure. Lead free plumbing is the foundation of public health protection from lead in drinking water. This proposed rule is critical for creating a baseline of preventative public health protection as residents replace their household water infrastructure over time. Failure to create a sufficiently protective rule that prevents unnecessary exposure to lead in drinking water will continue to create long-term problems that fall under the LCR, add costs to public water systems that must maintain compliance with the LCR, and continue to expose innocent residents to unnecessary lead in their drinking water whether by public water systems or private wells.
In this era of Do-It-Yourself (DIY) home improvements, the average citizen is purchasing and installing their own plumbing materials more than ever anticipated during the original lead ban in 1986. A massive culture has built up around amateurs remodeling and improving their own homes, generating cable channels dedicated 24-7 to home improvement, blogs where the writers detail their daily renovations, and Home Depot and Lowes generating $88.5 billion and $59 billion, respectively, in revenue in 2016. In this culture it is absolutely critical that if lead free and leaded plumbing products are sold in the same stores and on the same shelves that they are clearly and explicitly marked so there is no question of which product is appropriate for which application.
The Northeast-Midwest Institute recommends EPA make the following changes in finalizing the proposed rule:
- Eliminate exemptions for pipes, fittings, and fixtures that are compatible with potable water system.
- Maintain requirements to meet third party standards.
- Require third party certification for all manufacturers of pipes, fittings, and fixtures.
NEMWI’s complete comments can be found here. The public comment period for this rule ends on May 17, and comments can be submitted here.
For more information, contact Elin Betanzo, Director of the Safe Drinking Water Research and Policy Program at the Northeast-Midwest Institute.