More lead requirements
Plumbing manufacturers are the focus of these rules, not plumbing contractors.
This July, the requirements for lead concentration in the NSF 61 standard are changing. I have had many plumbing contractors asking, “How does this impact me?”
The simple answer? It doesn’t.
However, this simple answer requires a complex explanation. The change to the lead concentration requirements are in no way related to the no- or low-lead requirements in California, Vermont and Maryland that will become federal law in 2014. These two issues are unrelated.
Five years ago, the NSF Joint Committee on Drinking Water Additives decided to give plumbing manufacturers time to modify their products. Rather than implementing an immediate change, they added a date of July 1, 2012, for the new lead concentration level to become effective.
This doesn’t necessarily mean that the lead concentration in the product is lowered. What it means is that when the product is tested to the protocol in NSF 61, the concentration of lead must be lower. There is a difference in that NSF 61 is concerned with how much lead leaches into the drinking water. That is what is being measured during the testing of a plumbing product.
Currently, the allowable contribution to lead in the drinking water is 15 parts per billion. The new number drops to 5 parts per billion. That is a significant drop in lead concentration. To make it a little more confusing, faucets are only permitted to contribute 11 parts per billion of the overall 15 parts per billion. That number also will drop to 5.
To put these numbers into perspective, let’s assume China has a population of 1 billion people (it is actually more than 1.3 billion). A value of 15 parts per billion means that, in the entire country of China, 15 people are made out of lead. Yes, these are small numbers. But they are numbers to keep the drinking water as safe as possible.
Most manufacturers started changing their products five years ago to comply with the new numbers. Virtually every residential kitchen and lavatory faucet meets the new requirements and many have for years.
Some manufacturers have delayed the introduction of products that will comply, such as fittings and valves. The reason for the delay is because of the higher cost. These newer complying products will cost you more. Hence, on July 1, expect to see an increase in cost for certain products. That cost increase may be more than you anticipated.
The standard only applies to manufacturers and their listings. If a product is made on June 30, it can meet the old concentration levels. If it is produced on or after July 1, it must meet the new concentration levels.
This has no impact on your current inventory. You can continue to install any current brass product you have in your shop or on your truck. You can even purchase products that do not comply with the new concentration levels after July 1. The same thing applies to supply houses. They can still purchase products from manufacturers’ inventory that do not meet the new standard requirements.
Neither supply houses nor contractors are required to get rid of existing inventory because of the change in the standard. You can continue to install any listed product prior to 2014.
Some manufacturers are loading up their inventory prior to the change in the requirements. I don’t consider that to be following the spirit of the delay in implementation. However, they are hoping to capitalize on the ability to sell a lower-cost product for a longer period of time. While this may appear seedy or unethical, it is perfectly acceptable and legal. I will admit this was not the purpose of the change, but it is one of the allowances.
Other manufacturers will be promoting that all their products comply with the new requirements. Some are already doing that with a reference to NSF Annex F, which is the part of the standard identifying the new requirements and the implementation date. On July 1, Annex F disappears since the requirements are then added directly into the standard. But you still may hear of manufacturers promoting Annex F.
When this change comes about, you have a choice to make. You could promote it to your customers while proclaiming that you only install the new lower-lead-concentration products. Or you could find the older products at a lower price and sell to your customers for a lower installed price.
Protection of drinking water sells. So does safety. The first option can promote your name as a leader in protecting the drinking water of your customers. You also can find plenty of brochures to hand out that talk about the hazards of lead in drinking water.
Another thing that sells is lower prices. However, if you take this option, I wouldn’t advertise why you have a lower price. Although don’t be surprised if your competitors tell those same customers you aren’t offering the healthier option that they are.
While this new requirement doesn’t really impact you, the same cannot be said for the new federal law that becomes effective in 2014. After that date, you cannot install any plumbing product in a water line used for drinking or cooking that has a lead concentration greater than 0.25% lead.
So, if you buy the older products, be sure you get them out of your inventory by 2014.
This July, the requirements for lead concentration in the NSF 61 standard are changing. I have had many plumbing contractors asking, “How does this impact me?”
The simple answer? It doesn’t.
However, this simple answer requires a complex explanation. The change to the lead concentration requirements are in no way related to the no- or low-lead requirements in California, Vermont and Maryland that will become federal law in 2014. These two issues are unrelated.
Five years ago, the NSF Joint Committee on Drinking Water Additives decided to give plumbing manufacturers time to modify their products. Rather than implementing an immediate change, they added a date of July 1, 2012, for the new lead concentration level to become effective.
This doesn’t necessarily mean that the lead concentration in the product is lowered. What it means is that when the product is tested to the protocol in NSF 61, the concentration of lead must be lower. There is a difference in that NSF 61 is concerned with how much lead leaches into the drinking water. That is what is being measured during the testing of a plumbing product.
Currently, the allowable contribution to lead in the drinking water is 15 parts per billion. The new number drops to 5 parts per billion. That is a significant drop in lead concentration. To make it a little more confusing, faucets are only permitted to contribute 11 parts per billion of the overall 15 parts per billion. That number also will drop to 5.
To put these numbers into perspective, let’s assume China has a population of 1 billion people (it is actually more than 1.3 billion). A value of 15 parts per billion means that, in the entire country of China, 15 people are made out of lead. Yes, these are small numbers. But they are numbers to keep the drinking water as safe as possible.
Most manufacturers started changing their products five years ago to comply with the new numbers. Virtually every residential kitchen and lavatory faucet meets the new requirements and many have for years.
Some manufacturers have delayed the introduction of products that will comply, such as fittings and valves. The reason for the delay is because of the higher cost. These newer complying products will cost you more. Hence, on July 1, expect to see an increase in cost for certain products. That cost increase may be more than you anticipated.
Existing inventory
This raises the question as to whether you, as a contractor, must only install newer low-lead-concentration products after July 1. That is not the case as this change is not directed at plumbing contractors.The standard only applies to manufacturers and their listings. If a product is made on June 30, it can meet the old concentration levels. If it is produced on or after July 1, it must meet the new concentration levels.
This has no impact on your current inventory. You can continue to install any current brass product you have in your shop or on your truck. You can even purchase products that do not comply with the new concentration levels after July 1. The same thing applies to supply houses. They can still purchase products from manufacturers’ inventory that do not meet the new standard requirements.
Neither supply houses nor contractors are required to get rid of existing inventory because of the change in the standard. You can continue to install any listed product prior to 2014.
Some manufacturers are loading up their inventory prior to the change in the requirements. I don’t consider that to be following the spirit of the delay in implementation. However, they are hoping to capitalize on the ability to sell a lower-cost product for a longer period of time. While this may appear seedy or unethical, it is perfectly acceptable and legal. I will admit this was not the purpose of the change, but it is one of the allowances.
Other manufacturers will be promoting that all their products comply with the new requirements. Some are already doing that with a reference to NSF Annex F, which is the part of the standard identifying the new requirements and the implementation date. On July 1, Annex F disappears since the requirements are then added directly into the standard. But you still may hear of manufacturers promoting Annex F.
When this change comes about, you have a choice to make. You could promote it to your customers while proclaiming that you only install the new lower-lead-concentration products. Or you could find the older products at a lower price and sell to your customers for a lower installed price.
Protection of drinking water sells. So does safety. The first option can promote your name as a leader in protecting the drinking water of your customers. You also can find plenty of brochures to hand out that talk about the hazards of lead in drinking water.
Another thing that sells is lower prices. However, if you take this option, I wouldn’t advertise why you have a lower price. Although don’t be surprised if your competitors tell those same customers you aren’t offering the healthier option that they are.
While this new requirement doesn’t really impact you, the same cannot be said for the new federal law that becomes effective in 2014. After that date, you cannot install any plumbing product in a water line used for drinking or cooking that has a lead concentration greater than 0.25% lead.
So, if you buy the older products, be sure you get them out of your inventory by 2014.
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