By Jacques St-Denis
Lead is a naturally-occurring metal and a commonly-used substance in household plumbing materials and water-service lines. Due to an increasing amount of research linking the presence of lead in drinking water to a variety of adverse health effects, plumbing standards regarding the lead content in drinking water have been established and strengthened over the past four decades.
The Reduction of Lead in Drinking Water Act (RLDWA) of 2011 was enacted by Congress to lower the acceptable levels of lead in the nation’s supply of drinking water from those originally established in the Safe Drinking Water Act (SDWA) of 1974. Led by the state of California, which independently enacted its own stricter lead content standards, and advocated by the plumbing industry, the RLDWA made the following changes to the previous version of the SDWA:
The act changed the definition of lead free by reducing lead content from 8 percent to a weighted average of not more than 0.25 percent in the wetted surface material
Lead pipes, solder, and flux can no longer be used
Third-party testing is encouraged for manufacturers to show compliance to the federal law that their products are lead free and is required in order to sell products in the U.S.
Effective in January 2014 , the RLDWA was designed to keep the general public safer by reducing exposure to lead that is typically leached from pipes, faucets, and other plumbing fittings and components. To ensure that plumbing products are in compliance with the new requirements, manufacturers must have their products tested to new standards. Among the numerous standards governing potable water, NSF/ANSI 61 and NSF/ANSI 372 are most often cited when discussing lead content in plumbing products testing.
NSF/ANSI 61: Drinking Water System Components – Health Effects was published in 1988 to establish minimum requirements for the control of potential adverse human health effects from products that contact drinking water. Revised in December 2008 and effective January 2010, it established requirements for use when a 0.25 lead content requirement needs to be met, in addition to current lead extraction requirements. The requirements are located in Annex G – Weighted Average Lead Content Evaluation Procedure of NSF/ANSI 61.
In 2010, the lead content evaluation procedures of Annex G were moved to NSF/ANSI 372: Drinking Water System Components –
Lead Content, and Annex G was updated to simply reference it. While no additional testing is required for products certified as compliant with Annex G, movement of the procedures from Annex G to NSF/ANSI 372 allowed for its application on products beyond the scope of NSF/ANSI 61.
NSF/ANSI 372 specifically addresses conduits or materials that distribute water with respect to their lead content and serves to establish the new testing requirements and standards a manufacturer must meet in order to comply with the Reduction of Lead in Drinking Water Act of 2011. While the original NSF/ANSI 61 Annex G has information for how the lead content should be calculated, it did not have the testing protocols that are now addressed in NSF/ANSI 372 for how to calculate lead content.
Additionally, NSF/ANSI 61 was specifically designed to address concerns for plumbing materials and did not cover end-use devices. However, NSF/ANSI 372 applies to any product that comes in contact with potable water. Now, items like ice machines, coffee makers, soda fountains, and hot water tanks need to be tested using only NSF/ANSI 372 because NSF/ANSI 61 does not apply to them.
As of January 2014, manufacturers must ensure that their products comply with the new low-lead regulation. Any products – such as, pipes or faucets – that were already in use when the regulation went into effect did not have to be updated; however, if any part of these products must be replaced they will need to be compliant. For example, if a valve in an existing plumbing line needs replacing, a newer low-lead valve will need to be installed. Another example might be if a manufacturer makes ice machines. The ice machines that were installed before the regulation took effect do not need to be updated, but any ice machines that are held in stock must be compliant with the new low-lead law before being installed.
In order to sell their products in the U.S., many manufacturers consult third-party testing organizations – such as, Intertek, UL, IAPMO, and NSF – to help ensure compliance with all standards and testing requirements. A certification mark showing compliance to NSF/ANSI 372 signifies that a product has been tested to and found to comply with national standards by a qualified, independent testing laboratory. The certification process requires product review and analytical testing before the final report and mark are issued to the manufacturer.
During product review, samples and documentation from the manufacturer are evaluated to determine the product’s testing needs and certifications. Documentation is required to identify the manufacturer and all materials in the water pathway; including, component name, part number, material type, color, quantity, wetted surface area spec sheets, and diagrams of the water pathway. Prior to testing, a report is shared with the manufacturer letting them know their product’s testing needs and how the product will be tested. There are many tests in NSF/ANSI 61 that are required, all of which depend on the type of material the product is made from.
Most of the testing to NSF/ANSI 61 involves exposing the product to water with different chemical properties and then testing the water after the exposure period to see what can be extracted. For NSF/ANSI 372, testing begins by scanning all materials that are not expected to contain lead with a portable X-ray fluorescent (XRF) spectrometer, which has the ability to qualify and quantify any element. Any samples expected to contain lead are tested separately using Inductively Coupled Plasma (ICP), a process that yields more accurate results. Samples that do not meet the size and shape requirements for XRF are broken down by an acid solution and then tested to the ICP process to determine lead content. Following the analytical testing, all lead results are collected and a final report is created. An authorization to mark is issued after the final report is accepted and the product is listed in the certification laboratory’s public directory.
Once certified, products are required to have a continual follow-up inspection program to ensure that current manufactured products remain in compliance. Follow-up inspections are conducted on a quarterly basis through unannounced visits to the manufacturer, allowing inspectors to verify that the construction, components, and quality control remain in accordance with the requirements for certification. If the product requires any updates or changes, a report is issued to the manufacturer and the project receives a new project number. A project change order request is used to tie the new work order to the original project making it easier to track changes to products under review.
Low-lead product testing and certification provides documentation focusing on safety, helping to protect consumers from the harmful effects of lead to the body and manufacturers and retailers from liability. Although market research suggests certification marks are rarely included in the buying criteria of consumers, the opposite can be said for architects, distributers, city code officials, and plumbing inspectors. A nationally recognized certification mark not only signifies low-lead compliance, but it also indicates that a product meets all of the necessary expectations and requirements for sale throughout North America. l
Jacques St-Denis is a Building Products/Plumbing Team Leader based in Montréal, Canada. With over 25 years of experience at Intertek, Jacques is an expert in plumbing product testing and certification. As a leader of Intertek’s plumbing product testing services, he is responsible for creating testing plans, compiling product reports and interfacing with clients. In addition to reviewing Intertek’s testing ability, Jacques is on ASME/CSA/IAPMO standards committee for plumbing fixtures and fittings, as he also is a BNQ committee member for pipes and fittings. Jacques has a degree in Civil Engineering from Le Collège Montmorency in Laval, Québec.