december 31st, 2013 issue 12 volume 12 20 pages white...

PLUMBING • IRRIGATION • KITCHEN & BATH •UNDERGROUND • ASPE

December 31st, 2013Issue 12 Volume 12

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THE PIPELINE

Jack MorganEditor and Publisher

20 Pages

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ASPE Annual Product ShowComing in March 2014

The Atlanta Chapter ofthe American Society ofPlumbing Engineers (ASPE)is excited to announce theywill be holding their annualproduct show on March 27,2014 at the Holiday Inn Pe-

rimeter North.Every year ASPE holds

this product show to bring to-gether today’s plumbing pro-fessionals, including design-ers, engineers, code offi-

John Royds, Jim Allen and David Woods hold downthe fort at the 2013 ASPE Product Show booth

White Wolf Group, Inc. toRepresent Gregory Industries,

G-Strut Products

White Wolf Group, Inc.announces the recent addi-tion of Gregory Industries,G-Strut products, to thecompanies they represent.

White Wolf Group beganrepresenting Gregory Indus-tries and G-Strut products onJanuary 1, 2014 and will be

Anthony Bolden, General Manager andZach Hudhins, Managing Director

NGWA 2013 GroundwaterExpo a Sound Success

E.P.A. Lead-content LawTakes Effect in 2014

The National GroundWater Association’s 2013Expo that took place Decem-

ber 3-6 in Nashville, Ten-nessee, was a sound suc-

The U.S. EnvironmentalProtection Agency postedon its Web site a revised listof frequently asked ques-tions to assist manufactur-ers, retailers, regulators,and the general public incomplying with, and under-standing, the requirementsof the Reduction of Lead inDrinking Water Act.

The FAQs address thedefinition of lead free, the ef-fective date, calculating leadcontent, third-party certifica-tion, product labeling, repair

and replacement parts, andexemptions.

The Reduction of Lead inDrinking Water Act was en-acted on January 4, 2011 toamend Section 1417 of theSafe Drinking Water Act,which covers the use and in-troduction into commerce oflead pipes, plumbing fittingsor fixtures, and solder andflux. The Reduction of Leadin Drinking Water Actchanges the Safe DrinkingWater Act definition of lead

Greetings plumbingpros! Hope you all are welland you had a wonderfulChristmas with your familyand friends! It’s hard to be-lieve the New Year is alreadyupon us. I would like to wishyou all have very prosper-ous 2014!

I will be making roundsto visit you all and I look for-ward to seeing you! If youhave any upcoming eventsyou would like the PlumbingNews to cover and/or placeon our calendar or wouldlike to place ads for the up-coming year, please contactme at [email protected] by phone at 770-378-1194. Be sure to check outour monthly calendar, whichis located in every issue.

We will soon be closingout our 2014 IndustrySource Guide for Carolina,so please be sure we haveyour updated listing and

ASPE Celebrates 50 Yearsof Advancing Plumbing

EngineeringIn 1964, a small group of

plumbing engineers in South-ern California formed the firstnational organization dedi-cated exclu-sively to theneeds of theplumbing engi-neering profes-sion: the Ameri-can Society ofPlumbing Engi-neers (ASPE).This year, ASPEwill honor their accomplish-ment, the accomplishmentsof all those who have servedin leadership roles since thefounding of ASPE, and theachievements of the Societyin advancing plumbing engi-neering during the past 50years via a year-long anni-versary celebration.

“It is a special honor to bePresident of this great Soci-ety for this milestone event,”says ASPE President WilliamHughes Jr., CPD, LEED AP,FASPE. “During the past 50years, ASPE has grown tobecome the voice of plumb-ing engineers and designersat both the national and in-ternational levels, the lead-ing provider of education,training, and technical pub-

lications for plumbing profes-sionals, and a key partnerwith other organizations serv-ing the plumbing industry.”

In the UnitedStates in the mid-1900s, plumbingengineering wasan indistinctbranch of theoverall mechani-cal engineeringindustry. Thereason for this

was the lack of a national,unified voice for the plumb-ing engineering profession.To rectify this, a group of ap-proximately 35 plumbing en-gineers and designers fromthe Los Angeles area met onApril 8, 1964, and a commit-tee was formed to investigateoptions for establishing anational association dedi-cated exclusively to plumbingengineering. Several monthslater, on September 18,1964, the group reconvenedto approve the draft bylawsand elect a board of direc-tors, and the American Soci-ety of Plumbing Engineerswas incorporated. The firstofficial local chapter (LosAngeles) was formed two

Georgia Plumbing News - December 31st, 2013

THE GEORGIA PLUMBINGNEWS

5579-b Chamblee -Dunwoody RDSTE 157 Atlanata Ga. 30338

Phone: 770.378.1194Fax: 770.395.7069

[email protected]: www.theplumbingnews.com

Find us on Facebook @ The Plumbing NewsTwitter: http://twitter.com/plumbingnews

E-mail: [email protected]’s E-mail: [email protected]: [email protected] Department : 770.378.1194

Jack Morgan - Editor and PublisherShea Britt - Staff [email protected]

The Georgia Plumbing News is a monthly publication of MorganPublishing Company. The publisher does not assume responsibilityfor statements made by advertisers and reports opinions by dealers,suppliers and manufacturers as quoted. The advertising and copydeadline for the next issue is January21st, 2014. All contents are

copyright 2013 by Morgan Publishing Company.

Advertising Index


December 31st, 2013

ASPE Monthly Meeting------------------ page 14Calendar ----------------------------------- page 5Classifieds --------------------------------- page 6Dupree Christmas Party ----------------- page 14

White WolfCONTINUED from PAGE 1

Cash Acme -------------------------------- page 18Ferguson ----------------------------------- page 19Georgia Power ---------------------------- page 6Georgia Power ---------------------------- page 15Merbaum, David-------------------------- page 16Normac ------------------------------------ page 8PDI ----------------------------------------- page 20PMA of Georgia -------------------------- page 17RBM North -------------------------------- page 13Saniflo -------------------------------------- page 5Southeast Pumps ------------------------- page 12Taco ---------------------------------------- page 9Winnelson ---------------------------------- page 2Winnelson ---------------------------------- page 4Winnelson ---------------------------------- page 10

Bobby Bu

CONTINUED from PAGE 1

THE PIPELINE

representing them in thegreat state of Georgia. “Ican’t be more pleased by thedecision that G-Strut made toselect our firm,” said ZachHudgins of WWGI. They areone fine company with a fan-tastic business model andexpansion plans that make

sense. “As the strut prod-uct line expands we look fora complete line of pipe hang-ers by Gregory in 2015,”stated Anthony Bolden ofWWGI.

Gregory Industries has aproud legacy of metals ex-pertise. Beginning with theirearliest roots in Brooklyn,New York, the Thomas Gre-gory Galvanizing Works was

established in 1896. Built onthe core values of qualityproducts and business in-tegrity, the firm thrived withexpansion into new facilitiesin New Jersey, New York andPennsylvania.

The present day firm wasfounded in 1957 by T.Raymond Gregory. With pio-neering efforts in large-ca-pacity kettles and the latercombination of roll-formingand continuous galvanizing,Gregory Industries grew insuccess and reputation bysupplying exceptional-qual-ity galvanized steel to numer-ous industries.

Today Gregory Industriesis regarded as a leader inproprietary manufacturedproducts, continuous galva-nized coatings and metal-working services. Traditionsof quality, service and excel-lence remain commitmentsto our customers along withfresh approaches to innova-tion and competitive value.

G-Strut® Accessorieswork in hundreds of applica-tions and interchangeablemetal framing systems includ-ing: Electrical, conduit, plumb-ing, mechanical, pipe, PVC,Schedule 40, copper, hydrau-lic tubing, stainless steel pipeand tube, chemical, food,waste. Other applications in-clude: Simple strut, Equipmentservice stands, Panel sup-ports, Overhead electricalsupport systems, HVAC, ma-chinery, and, electronics pan-els, Trapeze schemes, Shelv-ing and shelf sytems, Wallmounted conduit or electricalsystems, C-Perlin, I-Beam,and T-Bar clamp support sys-tems.

White Wolf Group, Inc. isvery excited about represent-ing G-Strut and they look for-ward to discussing with theircustomers the extensive lineof products G-Strut has tooffer that you will fall in lovewith. For further informationon G-Strut Products, pleasecontact White Wolf Group,Inc at 1-800-401-4870 or onthe web at www.whitewolfgroupinc.com or onFacebook at facebook.com/whitewolfgroupinc.

any ads you may want to run.Our friend in Augusta andSavannah are welcome toadd their listings.

Don’t forget to visit ourwebpage theplumbingnews.com, as well as our Twitterand Facebook pages whichare receiving 50,000 hits permonth. I hope you all havewonderful New Year’s and asalways, I’ll see you down thepipeline.


Product Showcials, wholesalers/distribu-tors, architects, masterplumbers, students and con-tractors, for pertinent tech-nical information, as well as,the latest technologies andproducts in the plumbingrealm. This product show isthe largest and longest run-ning plumbing product showin the Southeast. It will fea-ture the latest plumbing prod-ucts and manufacturer ’sbooths, and 2 technical semi-nars will be held during theevent for attendees to earncontinuing education or pro-fessional development cred-its. Joe Messina, ASPE Presi-dent, stated “The AtlantaChapter of the American So-ciety of Plumbing Engineers

is over 40 years strong inadvancing the profession ofplumbing engineering andthe plumbing industry. OurChapter is consistently aleader on the nationalscene, as well as, the stateof Georgia. Our productshow is the longest runningand largest show of its kindin the entire southeast. TheAtlanta Chapter is confidentthat anyone who attends theproduct show will comeaway with the tools andknowledge that will help fur-ther their careers and putthem on the cutting edge ofthe industry.”

For further informationon this upcoming show,please contact Joe Messina,ASPE Atlanta President, byemail at [email protected] or by phone at404-601-8678.


E.P.A.free and creates exemptionsfrom the lead-free require-ments for plumbing productsnot used for drinking water.The Reduction of Lead inDrinking Water Act estab-lished a prospective effectivedate of January 4, 2014.

Under the "protect yourbusiness" category in the“member exclusive content”area of www.NGWA.org,members can access mate-rials developed by NGWA onthe Reduction of Lead inDrinking Water Act over thepast three years and an EPApresentation on the newlead-free law.

The EPA also offers aninformational handout to helpcompanies whose productsare certified as lead free toexplain the new certificationmarks.

There is no mandatoryfederal requirement for prod-uct testing or third-party cer-tification under the SafeDrinking Water Act, but someentities may require certifica-tion.

Consumers may chooseto increase their level of con-fidence by purchasing prod-ucts with a mark indicatingproducts have been certifiedby an accredited third-partycertification body as meetingthe new lead-free require-ment.

Products that have notbeen certified may still meetthe new lead-free require-ment. If you are unable todetermine if a product is leadfree, contacting the manu-facturer is the best way toconfirm the lead content.

Although other stateshave laws pertaining to thelead content in products,

California is currently theonly state that has a bill (SB1334) requiring certification,according to the EPA. How-ever, there may be locallaws or entities in otherstates that require it.

Becoming fully effectivein the beginning of 2014,the Reduction of Lead inDrinking Water Act defineslead free as not containingmore than 0.2 percent leadwhen used with solder andflux. Products also must notexceed a weighted averageof 0.25 percent lead whenused with the wetted sur-faces of pipes, and pipe andplumbing fittings and fix-tures. The new EPA hand-out also contains a helpfuldiagram for determiningwhich products must meetthe new lead-freerequirement.

years later, and the Societyheld its first national conven-tion in Los Angeles in 1968.

Since then, ASPE hasgrown into an internationalassociation of more than6,000 members and 60chapters. The Society isengaged in codes, stan-dards, and public health ini-tiatives globally via partner-ships with other industry or-ganizations such as the In-ternational Association ofPlumbing & Mechanical Of-ficials, International CodeCouncil, Canadian Instituteof Plumbing & Heating,Plumbing Manufacturers In-ternational, Asian SavingWater Council, and theWorld Plumbing Council.ASPE helps meet the careerneeds of plumbing engi-

50 Years


CONTINUED on PAGE 4


neers and designers by of-fering numerous profes-sional development opportu-nities both online and in-per-son, technical publications,American National Stan-dards, and local and nationalnetworking.

“The first 50 years werenot without growing pains,but ASPE survived and isrunning full speed ahead,”Hughes says. “The Societyis continually growing glo-bally to strengthen our posi-tion within the industry.Opening doors, seekingnew opportunities, andpartnering with other orga-nizations only reinforces ourposition within the worldwideplumbing community. I amtruly excited about the futureof ASPE and am looking for-ward to working with ourmembers to help set thecourse for the next 50years.”

ASPE will celebrate theaccomplishments of theplumbing engineering indus-try all year long with localchapter events, a 50th An-niversary website (aspe.org/50), news releases, and spe-cial features at the Society’sbiennial Convention & Expo-sition this fall. We invite allindustry representatives tojoin us in celebrating 50years of advancing plumbingengineering during the 2014ASPE Convention & Exposi-tion, which will be held inChicago on September 20–24. Registration for theevent will open on May 1 ataspe.org.


50 Years

cess, posting strong num-bers in both attendance andexhibitors.

“The 2013 NGWAGroundwater Expo and An-nual Meeting ranks fifth all-time among our non-LasVegas venues in our 65-year history,” said NGWACEO Kevin McCray, CAE.“Fresh ideas promised amemorable experience andit looks like folks found thatto be true. We hope all of ourguests left happy and re-newed, and ready for a newand prosperous year.”

More than 3,680 at-tended the NGWA Expo lastweek and spanned all sec-tors of the groundwater in-dustry — water well drillersand contractors, manufac-turers and suppliers, scien-tists and engineers. All 50United States were repre-sented, along with D.C. and

Puerto Rico, and 32 othernations.

In addition to 60-plushours of educational offer-ings, guest lecturers, skillstesting activities, NGWAaward presentations, andnearly 300 exhibitors —more than 30 of which werefirst-time participants — at-tendees also had thechance for some fun, includ-ing concerts by the Sweet-hearts of the Rodeo and TheBellamy Brothers.

As succinctly summed upby Alyson McDonald with aposting December 9 onNGWA’s Facebook page,“Outstanding meeting inNashville.”

The 2014 NGWA Expo —The Complete GroundwaterEvent — is scheduled totake place December 9-12 inLas Vegas.

NGWA, a nonprofit orga-nization composed of U.S.and international groundwa-ter professionals — contrac-

tors, equipment manufactur-ers, suppliers, scientists,and engineers — is dedi-cated to advancing ground-water knowledge. NGWA’s

vision is to be the leadinggroundwater associationthat advocates the respon-sible development, manage-ment, and use of water.


NGWA 2013

CONTINUED on PAGE 7

Summary of theReduction of Lead InDrinking Water Act

The Reduction of Leadin Drinking Water Act wasenacted on January 4, 2011to amend Section 1417 ofthe Safe Drinking Water Act(SDWA or Act) respecting theuse and introduction intocommerce of lead pipes,plumbing fittings or fixtures,solder and flux. The Act es-tablished a prospective ef-fective date of January 4,2014, which provided athree year timeframe for af-fected parties to transition tothe new requirements. Inanticipation of these

changes taking effect, EPAis providing the followingsummary of the require-ments of the lead ban provi-sions in Section 1417 andsome answers to frequentlyasked questions related tothe amendments to assistmanufacturers, retailers,plumbers and consumers inunderstanding the changesto the law.

On August 16, 2012, EPAheld a public webinar withstakeholders to discuss theReduction of Lead in Drink-ing Water Act and the poten-

tial ramifications that thischange in law may have. Par-ticipants included public utili-ties, government agencies,plumbing manufacturers,plumbing retailers and tradeassociations. At the end ofthis webinar, EPA solicitedcomments from the attend-ees on issues and concernsrelated to the new require-ments. The webinar pro-ceedings and the solicitedinput were used in formulat-ing an initial set of Fre-quently Asked Questions(FAQs) that were publishedfor public comment on May23, 2013.

This document, includingrevised answers to fre-quently asked questions, isintended to help the publicunderstand the statutory re-quirements, EPA intends tofurther clarify and refinethese and other issues re-lated to these provisions ina future rulemaking. These

Georgia Plumbing News - December 31st, 2013 CONTINUED from PAGE 1A

CONTINUED from PAGE 1AE V E N T S C A L E N D A R

2nd Tuesday of MonthSouth Metro PMALOCATION: McDounoughCONTACT: Tim Irwin 404-361-1928

3rd Tuesday of MonthNorth Georgia PHCCLOCATION: Logan’s Roadhouse, AthensCONTACT: Carol Lively 706-769-7063

3rd Thursday of MonthCentral Georgia PMALOCATION: Texas Cattle CompanyCONTACT: Doug Kersey, 478-788-1632

4th Tuesday of MonthNorthwest Metro PMA, MariettaLOCATION: Delkwood GrillCONTACT: Troy Callahan 678-410-1629

4th Tuesday of MonthASPE Atlanta Monthly MeetingLOCATION: Villa ChristinaCONTACT: [email protected]

January 13th, 2014Georgia General Assembly 2014 BeginsLOCATION: Atlanta, GeorgiaCONTACT: www.plumbingpros.org

Send all of your open house, continuing education, seminar, and trade show information to:THE GEORGIA PLUMBING NEWS CALENDAR: [email protected]

January 15th, 2014Joint Legislative ReceptionLOCATION: Atlanta, GeorgiaCONTACT: www.plumbingpros.org

January 21st-23rd, 2014AHR ExpoLOCATION: New York CityCONTACT: www.ahrexpo.com

January 26th, 2014 1-5PMPMA Snow Mountain DayLOCATION: Stone Mountain, GeorgiaCONTACT: www.plumbingpros.org

February 8th, 2014Legislative Luncheon with NFIBLOCATION: Atlanta, GeorgiaCONTACT: www.plumbingpros.org

February 4th-6th, 2014Kitchen & Bath Industry ShowCONTACT: www.kbis.com/

February 14-17th, 2014PHCC Zone 2 Leadership ConferenceLOCATION: Savannah, GeorgiaCONTACT: www.plumbingpros.org

March 13-14th, 2014CEFGA Career Expo Skills USALOCATION: GeorgiaInternational Convention CenterCONTACT: www.cefga.org

March 31st, 2014MLB Opening DayAtlanta Braves in Milwaukee

April 23-24th, 2014International Emerging Technologies SymposiumLOCATION: Arlington, VACONTACT: www.phccweb.org

April 24th, 2014PMA Plumbing, Heating, Cooling ExpoLOCATION: Marietta, GeorgiaCONTACT: www.plumbingpros.org

June 26-29th, 2014122nd Annual PMA ConferenceLOCATION: Jekyll Island, SCCONTACT: www.plumbingpros.org

September 9th, 2014PMA Fall Memorial Golf TournamentLOCATION: Suwanee, GeorgiaCONTACT: www.plumbingpros.org


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FAQs include some recom-mendations that are advisoryonly (indicated by the use ofthe words such as “should” or“encourages”).

EPA remains interested infeedback on these FAQs, forrefinement of these answers,to respond to new questions,or to determine which issuesshould be explored in itsrulemaking. As a result, EPAmay revise or supplementthese FAQs from time to time.

SDWA Section 1417Since 1986, the Safe

Drinking Water Act (“SDWA”or “the Act”) has prohibitedthe use of certain items thatare not lead free and since1996 the Act has made it un-lawful for anyone to introduceinto commerce items that arenot lead free.

Use ProhibitionSection 1417(a)(1) pro-

hibits the “use of any pipe, anypipe or plumbing fitting or fix-ture, any solder, or any flux,after June 1986, in the instal-lation or repair of (i) any pub-lic water system; or (ii) anyplumbing in a residential ornon-residential facility provid-ing water for human consump-tion, that is not lead free” asdefined in Section 1417(d).Prior to the 2011 Amend-ments, the only exception tothis prohibition was for“leaded joints necessary forthe repair of cast iron pipes.”

Unlawful CommerceProvision

There are three compo-nents to the “unlawful com-merce” provision. Section1417(a)(3) provides that “itshall be unlawful –

(A) for any person to in-troduce into commerce anypipe, or any pipe or plumbingfitting or fixture, that is notlead free, except for a pipethat is used in manufacturingor industrial processing;

(B) for any person en-gaged in the business of sell-ing plumbing supplies, exceptmanufacturers, to sell solderor flux that is not lead free; or

(C) for any person to in-troduce into commerce anysolder or flux that is not leadfree unless the solder or fluxbears a prominent label stat-ing that it is illegal to use thesolder or flux in the installa-tion or repair of any plumbingproviding water for humanconsumption.”

Summary of the Amend-ments to SDWA Section1417

The 2011 Reduction ofLead in Drinking Water Actrevised Section 1417 to:

(1) Redefine lead free inSDWA Section 1417(d) to:


Water Act• lower the maximum lead

content of the wetted surfacesof plumbing products such aspipes, pipe fittings, plumbingfittings and fixtures from 8.0%to a weighted average of0.25%;

• establish a statutorymethod for the calculation oflead content; and

• eliminate the requirementthat lead free products be incompliance with voluntarystandards established in ac-cordance with SDWA 1417(e)for leaching of lead from newplumbing fittings and fixtures.

(2) Create exemptions inSDWA Section 1417(a)(4)from the prohibitions on theuse or introduction into com-merce for:

• “pipes, pipe fittings,plumbing fittings or fixtures,including backflowpreventers, that are used ex-clusively for nonpotable ser-vices such as manufacturing,industrial processing, irriga-tion, outdoor watering, or anyother uses where the water is

not anticipated to be used forhuman consumption;” (SDWA1417(a)(4)(A))

• “toilets, bidets, urinals, fillvalves, flushometer valves,tub fillers, shower valves, ser-vice saddles, or water distri-bution main gate valves thatare 2 inches in diameter orlarger.” (SDWA 1417(a)(4)(B))

Effective Date of theAmendments

The amendments will be-come effective on January 4,2014.

Until January 4, 2014:• The definition of lead free

is a maximum lead content of8.0%

• None of the exemptionscreated by the 2011 amend-ments apply

• Plumbing fittings and fix-tures must be in compliancewith the voluntary standardSection 9 of NSF, Interna-tional (NSF)/American Na-tional Standards Institute(ANSI) Standard 61.

As of January 4, 2014, the2011 amendments to Section

1417 of SDWA take effectand therefore:

• A new definition of leadfree applies, including a maxi-mum lead content of 0.25%and a method for calculatingit, unless the product is cov-ered by one of the exemp-tions.

• While SDWA still refers tovoluntary standards, it nolonger requires plumbing fit-tings and fixtures to be in com-pliance with Section 9 of NSF/ANSI Standard 61 (e.g., newendpoint devices).

Other laws related to thesale or use of plumbing prod-ucts that contain lead

It is important to note thatState and local jurisdictionsmay have additional limita-tions or requirements regard-ing the use or sale and distri-bution of pipes, pipe or plumb-ing fittings, or fixtures that con-tain lead. Contact your localor State plumbing or drinkingwater authority to find outmore about any additionalrequirements that may apply.

Frequently AskedQuestionsDefinition of Lead Free1. Q. How exactly will the

definition of lead free change?A. Prior to January 4,

2014, lead free has the fol-lowing definition:–

(1) when used with respectto solders and flux, lead freerefers to solders and flux con-taining not more than 0.2 per-cent lead;

(2) when used with respectto pipes and pipe fittings, leadfree refers to pipes and pipefittings containing not morethan 8.0 percent lead; and

(3) when used with respectto plumbing fittings and fix-tures, lead free refers toplumbing fittings and fixturesin compliance with standardsestablished in accordancewith SDWA Section 1417(e)(e.g. Section 9 of NSF/ANSIStandard 61).

Effective January 4,2014, lead free means:

(A) not containing moreCONTINUED on PAGE 8

American Standard an-nounced an official Commit-ment to Action with theClinton Global Initiative(CGI) this week, pledging toimprove sanitation and qual-ity of life for three millionpeople around the worldfrom 2014 through 2017. In-cluding the 2.5 million resi-dents of Bangladesh receiv-ing safer sanitation assis-tance during 2013 and2014, American Standard willreach an estimated 5.5 mil-lion people by 2017.

Earlier this year, Ameri-can Standard launched theFlush for Good campaignaimed at increasing aware-ness of the global sanitation

American Standard Announces ClintonGlobal Initiative Commitment to Action

to Improve Global Sanitation

American Standard President and CEO Jay Gould (far right)announced his company's Commitment to Action during the 2013Clinton Global Initiatives (CGI) conference. American Standard

pledged to improve sanitation and quality of life for three millionpeople in developing countries from 2014 to 2017.

crisis and creating innova-tive solutions to help stopthe spread of diseasecaused by inadequate sani-tation facilities in developingcountries. The company haspartnered with organizationsincluding BRAC, Save theChildren and other NGOs toresearch, develop, and dis-tribute a pioneering sanitarytoilet pan that is easy to useand inexpensive to produce,incorporates local bathroompractices, and effectivelyreduces the transmission ofdisease.

Following eight months ofresearch and field testing inBangladesh, American Stan-dard unveiled the SaTo (pro-

nounced SAH-toh, derivedfrom “Safe Toilet”) sanitarytoilet pan in early 2013. Thecompany invented the SaTo,which works without a sewerinfrastructure, using inge-niously simple mechanicaland water seals to close offpit latrines from the open air,thereby reducing the trans-mission of disease. The com-pany anticipates donatingmore than 500,000 SaTos tocommunities in Bangladeshduring 2013, helping an es-timated 2.5 million residentsto improve their quality of lifethrough safe sanitation fa-cilities.

Expanding upon this ini-tial mission, American Stan-dard will use a recent grantfrom the Bill & Melinda GatesFoundation to develop a newtoilet system that works inareas where water is scarce.Field research is currentlyunderway focusing on thesanitation issues in Sub-Sa-haran Africa. The company'sgoal is to distribute 600,000of this newly designed toiletproduct for use by an esti-mated three million people inthe rural populations of bothBangladesh and Sub-Sa-haran Africa by the end of2017.

The Clinton Global Initia-tive brings together highlyinfluential individuals fromacross the globe, includingheads of state, CEOs, Nobel

Prize laureates and leadersof NGOs, all with a missionof turning ideas into action.More than 2,500 Commit-ments to Action have beenmade by CGI members sincethe Initiative was founded in2005, to the benefit of anestimated 430 million peoplearound the world.

Worldwide, 2.5 billionpeople lack access to ad-equate sanitation facilities.Every day, 2,000 childrendie from diseases caused bythis lack of proper sanita-tion. The United Nations hasset a 2015 Millennium Devel-opment Goal of reducing byhalf the proportion of peoplewho lack access to safedrinking water and basicsanitation.

The work being done byAmerican Standard inBangladesh and Sub-Sa-haran Africa is designed tohelp make this goal a real-ity. “American Standard hasembarked on a mission tosave lives through safe sani-tation,” said Jay Gould,president and CEO of Ameri-can Standard.

“We take our Commit-ment to Action very seri-ously. Our company is proudto be part of the solutionaddressing the critical needfor improved sanitation inthese developing areas ofthe world.”

For more information onthe Flush for Good cam-paign, visit www.americanstandard.com or www.flushforgood.com. Learn moreabout the Clinton Global Ini-tiative at www.clintonglobalinitiative.org.


CONTINUED on PAGE 9

than 0.2 percent lead whenused with respect to solderand flux; and

(B) not more than aweighted average of 0.25percent lead when usedwith respect to the wettedsurfaces of pipes, pipe fit-tings, plumbing fittings, andfixtures.

CalculationFor purposes of the Act,

the weighted average leadcontent of a pipe, pipe fitting,plumbing fitting, or fixture iscalculated by using the fol-lowing statutory formula:


Water Act• For each wetted compo-

nent, the percentage of leadin the component is multi-plied by the ratio of the wet-ted surface area of that com-ponent to the total wettedsurface area of the entireproduct to arrive at theweighted percentage of leadof the component.

• The weighted percent-age of lead of each wettedcomponent is added to-gether, and the sum of theseweighted percentages con-stitute the weighted averagelead content of the product.The lead content of the ma-terial used to produce wet-ted components is used to

determine compliance.• For lead content of ma-

terials that are provided asa range, the maximum con-tent of the range must beused.1

1 Following is an exampleof the statutory calculation.Note: The formula will varyfor each product dependingupon the number of compo-nents and the wetted surfacearea of each component.Equation: Total % Lead =[Pb%C1 X RWSAC1] +[Pb%C2 X RSAC2] +[Pb%Cn X RSACn]

Example:Component (Pb%) Lead

Content (RWSA) Ratio of

Wetted Surface AreaWeighted % Lead

Washer 0.50% 1/10000.0005

Pipe 0.10% lead 999/1000 0.099

Weighted Average LeadContent: 0.0005 + 0.099 =0.0995

Questions aboutCoverage2. Q. What did Congress

mean by pipes, pipe fittings,plumbing fittings and fix-tures?

A. By removing Section1417(d)(3) from the defini-tion of lead free, the 2011amendments eliminated dis-tinctions between “pipes”

“pipe fittings”, “plumbing fit-tings” and “plumbing fix-tures.” As a general matter,Congress intended thatthese amendments broadlyapply to pipes and plumbingthat may provide water forhuman consumption so thatlead in the wetted surfacesof these conveyances canbe minimized or eliminated,thus reducing exposures tolead in tap water. For pur-poses of these FAQs, EPA isusing the term “pipes, fittingsor fixtures” as a shorthandto refer to pipes, pipe fittings,plumbing fittings and fix-tures, as those terms areused in the Act.

3. Q. I am a manufac-turer of faucet-mounted wa-ter treatment devices andplumbed-in treatment de-vices, which may includededicated faucets. Are thesetypes of devices a pipe, fit-ting or fixture that is subjectto the new lead free require-ments?

A. Yes, both point-of-useand point-of-entry devicesare covered by the lead freerequirements because theterms used by Congress arecommonly understood to in-clude kitchen and bathroomfaucets and the pipes lead-ing to such faucets. Thesedevices are typically inte-grated into a faucet orplumbing system that deliv-ers drinking water and assuch is considered to be cov-ered by the new lead freerequirements. Becausethese devices may be de-signed to remove lead, EPAexpects that some may al-ready meet the lead contentlimit of 0.25%.

4. Q. I am a manufac-turer of stand-alone appli-ances that are not con-nected to a potable waterdistribution system (i.e. non-plumbed), such as coffeemakers or pour through wa-ter filters. Are these types ofitems required to meet thenew definition of lead freebefore I introduce them intocommerce?

A. These stand-alone,non-plumbed, appliances ordevices do not logically fitwithin the statutory refer-ence to pipes, fittings or fix-tures because they are notplumbed in and they are notpart of the drinking waterdistribution system. The fo-cus of SDWA Section 1417is to prevent the contamina-tion of the drinking water inthe distribution system bylead that has leached frompipes, faucets and other fix-tures incidental to the deliv-ery of potable water. As


CONTINUED on PAGE 12


Water Actnoted in the legislative his-tory of the 1996 amend-ments to Section 1417, “[i]tis the intent of the Commit-tee that the terms pipe andplumbing fittings and fixturesin the legislation are in ref-erence to drinking water ap-plications….” EPA does en-courage manufacturers toavoid the use of lead in suchappliances and EPA alsoencourages consumers toconsult the manufacturers ofthese items to make surethat they do not containlead.

Where such devices are,however, integrated intopipes, fitting or fixtures forthe delivery of water, suchas a plumbed in coffeemaker, they would logicallycome within the scope of thenew lead free requirements.

5. Q. Are fire hydrantssubject to the lead free re-quirements in section1417(a)?

A. Information availableto EPA indicates that fire hy-drants can be, and are, usedin emergency situations toprovide drinking water whenthere are disruptions to thenormal operations of thedrinking water distributionsystem. Therefore, as aclass, hydrants would notqualify for the exclusion forpipes, fittings and fixturesused exclusively fornonpotable services.

6. Q. Are household ap-pliances or fixtures, such aswashing machines, dish-washers and water heaterssubject to the lead free re-quirements?

A. If the appliance or fix-ture is part of the plumbingsystem and is not used ex-clusively for nonpotable ser-vices, it is subject to the leadfree requirements. As a re-sult, washing machines areexempt as a device that isused exclusively fornonpotable services. Dish-washers and water heaters,on the other hand, are notexempt because they areused for potable services.

7. Q. How does EPA in-terpret the phrase “potableservices”?

A. EPA interprets “po-table services” to be servicesor applications that providewater suitable for human in-gestion (e.g. drinking, teethbrushing, food preparation,dishwashing, maintainingoral hygiene).

8. Q. Are temporarily in-stalled items, includingthose used for emergencyrepairs, subject to the new

lead free requirements?A. There is no exemption

in the statute for temporaryor emergency repairs;therefore under the lan-guage of the statute, anypipe, fitting or fixture used ininstallation or repair, begin-ning January 4, 2014, is sub-ject to the lead free require-ments and must meet thenew definition of lead free,even if their installation isonly temporary or for anemergency repair.

9. Q. I am a manufac-turer of hose bibs (threadedfaucets with nozzles bentdownward). I market themand sell them primarily foruse outdoors (e.g. to con-nect to a garden hose,

sprinkler, or irrigation sys-tem) but they could be usedfor services associated withhuman consumption as well.Are the hose bibs requiredto meet the new definition oflead free?

A. A hose bib is a pipe,fitting or fixture under thelanguage of the statute andtherefore it is subject to therequirements in Section1417 unless it is used exclu-sively for nonpotable ser-vices. If you market and sellhose bibs for nonpotableservices, and the bibs areprominently and clearly la-beled as illegal to use forpotable services and notanticipated to be used forhuman consumption, then

EPA would generally con-sider them to be used exclu-sively for nonpotable ser-vices and therefore, exemptfrom the lead free require-ments in SDWA 1417(a)(1)and (3).

10. Q. I am a manufac-turer of pipes, fittings or fix-tures (e.g. backflowpreventers). Some of theproducts I make are mar-keted and sold for use innonpotable services exclu-sively, and some products Imake are marketed and soldfor both potable andnonpotable services. Theproducts marketed and soldfor use in nonpotable ser-vices could theoretically beused for potable services. If

I affix a label to the productsthat are sold for nonpotableservices identifying it as ille-gal to use for potable ser-vices, could it be consideredexempt under 1417(a)(4)(A)?

A. Yes. While there is norequirement in the statute tolabel pipes, fittings or fixturesas either lead free or notlead free, a manufacturercould use labeling to estab-lish that the pipe, fitting or fix-ture is used exclusively fornonpotable services andtherefore, exempt from thelead free requirements inSDWA 1417(a)(1) and (3). Inimplementing the new re-quirements, EPA would gen-



erally consider pipes, fittingsor fixtures to be used exclu-sively for nonpotable servicesif they are marketed and soldfor use in nonpotable ser-vices, and prominently andclearly labeled as illegal to usein potable services and notanticipated for human con-sumption.

EPA also recommends thatthe label identify some ex-amples of potable services toconvey that it includes morethan drinking water. For ex-ample, the label could say “Itis illegal to use this product in


Water Actpotable services such asdrinking water, handwashing,food preparation, anddishwashing.”

11. Q. I am a manufacturerof toilets, bidets, urinals, fillvalves, flushometer valves,tub fillers, shower valves, ser-vice saddles, or water distri-bution main gate valves thatare 2 inches in diameter orlarger. Now that the new lawexempts these products fromthe use prohibition and theunlawful commerce provisionin SDWA 1417(a)(1) and (3),do they still need to meet theold definition of lead free orcould they contain more than8.0% lead?

A. Once the amendmentstake effect on January 4,2014, there will be nothing inthe SDWA that would requireany part of these products tomeet the old (or new) defini-tion of lead free. However,there may be State or locallaws prohibiting these prod-ucts from containing morethan a certain percentage oflead, or other legal implica-tions to increasing the leadcontent of these products, somanufacturers may want toseek legal advice before in-creasing the lead content ofthese products.

12. Q. I am a manufacturerof products that are not an-

ticipated to be used in potableservices but the products arenot used exclusively innonpotable services. Are theproducts exempt from the re-quirements of the Act underSection 1417 (a)(4)(A)?

A. No, only pipes, fittingsor fixtures that are used ex-clusively in nonpotable ser-vices are exempt under1417(a)(4)(A). If the item isused exclusively innonpotable services it is alsonot anticipated to be used forhuman consumption, but theinverse is not necessarilytrue. Pipes, fittings or fixturesthat are not anticipated to beused for human consumption

but are physically capable ofbeing used for potable ser-vices may not be used exclu-sively for nonpotable servicesin which case they would notbe exempt under Section1417(a)(4)(A).

13. Q. I am a manufacturerof products that are sold foruse in nonpotable servicesbut they could be connectedto potable services. If I wantto assure my products areused exclusively fornonpotable applications, whatkind of labeling should I use?

A. If you choose to labelyour pipes, fittings or fixturesin order to establish that theyare to be used exclusively fornonpotable services, the la-beling should be clear andprominent; otherwise, it maynot be reasonable to assumethat the product will be usedexclusively for nonpotableservices and not anticipatedto be used for human con-sumption. EPA recommendsthat the labeling consist ofboth a product label and apackaging label becauseproducts can get separatedfrom their packaging. Anotherreason for labeling both thepackage and the product isthat one package may containmany individual productswithin it and purchasers maynot be aware of the label onthe bulk package. EPA furtherrecommends that product la-bels consist of physicallymarking the product, a tagphysically attached to eachindividual product or an indi-vidual bag that contains eachindividual product. Labelsshould clearly indicate that itis illegal for use in potable ser-vices and not anticipated forhuman consumption.

Effective Date14. Q. I operate a hardware

store that sells pipes, fittingsor fixtures primarily tohomeowners, contractors,and some small businessesthat sell plumbing services. Irecently purchased a largeamount of pipes, fittings or fix-tures that meet the old defi-nition of lead free, but notthe new definition of leadfree. If my inventory of thesefixtures has not sold by Janu-ary 4, 2014, may I continueto sell them until I’ve sold myexisting supply?

A. No. The changes to thelaw become effective on Janu-ary 4, 2014. Congress pro-vided a transition period ofthree years after enactment(2011) of the new require-ments. The statute does notprovide any further exten-sions or exceptions for backinventory, small businesses,or sales to end-users. How-ever, back inventory that

Georgia Plumbing News - December 31st, 2013 Page 13


Scenes from theDupree PlumbingChristmas Party

The Dupree Brood is growing-Aidin, Saylor, Mike,Roman, Maddox, JoLynn and Josh Dupree

Alan Thurmond of PDI, Tony Pruett of APEX Supply,Adam Brown of PDI and Steve Pulley of Pulley &

Associates

Charlie Pulley of Pulley & Associates, Jessica Hicksand Billy Caviness of Marietta Winnelson

Mike, Faye, and Robert Dupree

Grace McBrayer, Jane and Skip Turner with DebbieDupree Bennett

Josh and Emily Dupree

The Varsity was on hand with their famous chili dogand burgers

David Payne of Dupree Plumbing and Larry Reno infront of the new Dupree truck rollout

Scenes from the Monthly ASPE Meeting

Joe Messina with John Bertrand

Nick Mosley with Susan Freed

Che Barbour and Dalton Rawson

James Sulko with Joe Welsh

Terri Zebrowsky, Steve Mastley and Bill Stewart

Jim Zebrowski, Joe Messina and Terri Zebrowski

Robert Hall, Mike Mahndy and Che Barbour

John Royds with Dave Perry

Richard Taylor chats with John Royds


could be used in both potableand nonpotable services maystill continue to qualify for theexemption, and, as a result,be sold, if the products areclearly labeled as illegal to usefor potable services.

15. Q. I am a builder and Ianticipate that I will have aproject that is partially com-pleted on January 4, 2014.Am I required to remove all theplumbing that is not compliantwith the new definition of leadfree?

A. Any plumbing installedprior to January 4, 2014 wouldnot need to be replaced un-der SDWA so long as it metthe lead free requirementsapplicable at the time of in-stallation. Any pipe, fitting orfixture installed after January4, 2014 must meet the newlead free definition.

EPA recommends youcheck with your local buildinginspector to get more infor-mation on implementation ofthis requirement, includingany documentation requiredto demonstrate the lead con-tent and installation date.

Calculating Lead Content,Third Party Certification andLabeling Products

16. Q. I am a manufacturerof plumbing fittings. How do Idetermine whether my prod-ucts meet the definition oflead free in SDWA?

A. Starting January 4,2014, the statute requiresthat you use the method forcalculating lead content inSection 1417(d)(2), which isdescribed in the answer toquestion 1.

17. Q. I am a manufacturerof plumbing supplies. If I ap-ply a coating to the wettedsurface or use a lead removaltechnology to treat the sur-face, how does it affect mycalculation of the lead contentof the material used to pro-duce the wetted component?

A. Section 1417 (d)(1)(B)defines lead free for pipes, fit-tings or fixtures to mean “notmore than a weighted aver-age of 0.25% lead” when usedwith respect to the wetted sur-faces. The statutory provisionfor calculating lead content(Section 1417(d)(2)) providesthat “[t]he lead content of thematerial used to produce wet-ted components is used todetermine compliance withthe lead free definition.” Thatprovision also provides that,for lead content of materialsthat are provided as a range,the maximum content of therange must be used. The “ma-terial used to produce wettedcomponents” includes all of

the materials used to produceany component that has awetted surface. If a coating isapplied to a pipe, fitting or fix-ture, you must calculate thelead content of both the alloyand the coating and use themaximum lead content. If apipe, fitting or fixture is treatedwith a lead removal technol-ogy, you would need to cal-culate the lead content of thealloy used to produce thepipe, not just the surface ofthe pipe, fitting or fixture —because the alloy is the ma-terial used to produce thepipe and the pipe is the wet-ted component. If the lead

content of the material is pro-vided as a range, you woulduse the maximum lead con-tent.

18. Q. Now that the newdefinition of lead free nolonger refers to pipes, fittingsor fixtures “in compliance withstandards established in ac-cordance with subsection (e)of this section”, could State orlocal law and regulations stillprohibit the use of productsthat are not in compliance withcertain voluntary standards?

A. As of January 4, 2014,pipes, fittings or fixtures areno longer required by theSDWA to be in compliance

with voluntary standards (e.g.,Section 9 of NSF/ANSI Stan-dard 61 or NSF/ANSI Stan-dard 372) because Congressremoved Section 1417(d)(3)(which referenced Section1417(e)) from the definition oflead free. State or local lawsand regulations (e.g., plumb-ing codes) however, may stillprohibit the use of productsthat are not in compliancewith certain voluntary stan-dards.

19. Q. I am a plumbingmanufacturer. Does theSDWA require that my prod-ucts be certified by a thirdparty to demonstrate compli-

ance with the new definitionof lead free?

A. The SDWA does notrequire manufacturers to ob-tain third party certification oftheir products. However, EPAencourages manufacturers touse third party certification orto create a system to docu-ment compliance (e.g., self-certification) with Section1417 of SDWA and to provideimportant information to sub-sequent purchasers or usersof the product, including re-tail stores, plumbers and con-sumers. Additionally, a recentsurvey of States found that 47



Water Act


have requirements for watertreatment and distribution sys-tem components to complywith NSF/ANSI Standard 61and most of them require anANSI-accredited third partycertification.

20. Q. I am a manufacturerof pipes, fittings or fixtures. AmI required to label my productsas being lead free?

A. There are no require-ments in SDWA for a manu-facturer to label these prod-ucts as lead free; however,EPA encourages manufactur-ers to provide subsequentpurchasers or users of theproduct, including retailstores, plumbers and con-sumers with information thatclearly indicates the lead con-tent in the products they areselling or distributing. Addi-tionally, some States or localgovernments may require



Water Actlead free labeling.

21. Q. Is there a role forthird party certifications?

A. While the SDWA doesnot require third party certifi-cation, third party certificationbodies or agencies may beused by manufacturers to in-form consumers which prod-ucts meet a voluntary stan-dard. One such standard,NSF/ANSI 372, is consistentwith the requirements of theReduction of Lead in Drink-ing Water Act. A third partycertification such as NSF/ANSI372 could be a useful way toidentify a product as meetingthe requirements of Section1417. Also, there may beState or local laws that requirethird party certification.

22. Q. I am installing abathroom sink faucet (e.g., aplumbing fixture serving wa-ter intended for human con-sumption) and I want to besure that the fixture meets therequirements of the Reduc-

tion of Lead in Drinking Wa-ter Act. How can I tell whichproduct to purchase?

A. Any bathroom sink fau-cet for sale after January 4,2014 must be lead free (con-taining not more than 0.25%weighted average lead con-tent). While the statute doesnot require labeling, EPA en-courages and expects manyplumbing product manufac-turers to label their productsas lead free so that they candemonstrate compliance withSDWA as well as provide in-formation to purchasers orusers of the product.

Many State plumbingcodes require the use of prod-ucts that are in compliancewith NSF/ANSI standards 61and 372. NSF/ANSI Standard372 is a certification processby which independent labora-tories verify that the plumbingproduct is in compliance withthe requirements of the 2011Reduction of Lead in Drink-

ing Water Act. Products willbear the mark of the labora-tory that has independentlycertified that the productmeets the standard. EPA pub-lished a brochure to assist thepublic with identifying the vari-ous marks that indicate aproduct has been certified aslead free to the new require-ment of the Act: “How to Iden-tify Lead-Free CertificationMarks for Drinking Water Sys-tem & Plumbing Materials.”You can access the documentat http://nepis .epa.gov/Exe/Z y P D F . c g i ?Dockey=P100GRDZ.txt

Alternatively, a consumercould directly contact themanufacturer of the productto confirm that the model youwish to purchase meets thelead free requirements.

Repairs and ReplacementParts

23. Q. How does EPA in-terpret the new statutory pro-visions to apply to repairs,

reinstallations, and replace-ment parts?

A. Repairs of previouslyinstalled pipes, fitting or fix-tures

A pipe, fitting or fixture thatwas installed in a public watersystem or a facility providingwater for human consumptionprior to the effective date ofthe 2011 Act does not needto meet the new definition oflead free regardless ofwhether it is repaired. Therepaired pipe, fitting or fixtureis not being “used” in the re-pair or installation, or “intro-duced into commerce” andtherefore, the requirementsof Section 1417 are not trig-gered as a result of the re-pair. Parts used in repairsmay need to meet the require-ments of Section 1417 (see“Replacement Parts” belowand FAQ #24, 26, 27 and 28).

The temporary removal ofpipes, fittings, or fixtures forrepairs and reinstallation totheir original location wouldnot trigger the requirementsof Section 1417 because thepipes, fittings or fixtures arenot being installed or “used in”repair. (See FAQ #29). Simi-larly, the temporary removalof pipes, fittings or fixtures forstorage or calibration and re-installation to their original lo-cation would not trigger therequirements of Section1417. (See FAQ #30.)

Replacement PartsAfter the effective date of

the 2011 Act, any replacementparts that are pipes, fittings,or fixtures either installed orused in repairs of a publicwater system or a facility pro-viding water for human con-sumption, or introduced intocommerce, must meet thedefinition of lead free. (SeeFAQ #25)

However, where the re-placement of pipes, fittings, orfixtures is part of a device(such as a water heater)made up of several compo-nent parts and the devicemeets the definition of leadfree in the 2011 Act, the re-placement parts themselvesneed not meet the new defi-nition of lead free. As long asthe overall device would meetit with the replacement partinstalled, then the require-ments of Section 1417 wouldbe met. Such replacementparts should be labeled asspecifically for use in the de-vice that meets the new defi-nition of lead free. (See FAQ# 24.)

Also, the use or introduc-tion into commerce of replace-ment parts that are not pipes,fittings, or fixtures does nottrigger the requirements ofSection 1417. EPA recom-



Water Actmends that any replacementparts that are not pipes, fit-tings, or fixtures that come intocontact with potable watermeet the definition of leadfree in the 2011 Act becauseof their potential to cause el-evated levels of lead in drink-ing water, but they are notrequired to do so. (See FAQ#26.)

24. Q. I am a manufacturerof pipes fittings or fixtures thatserve water intended for hu-man consumption. Thesepipes, fittings or fixtures aremade up of several compo-nent parts. If I sell or providefree replacement parts, ANDthe original pipe, fitting or fix-ture met the lead free require-ment in the 2011 Act, mustthose replacement parts meetthe new definition of leadfree?

A. If the original pipe, fit-ting or fixture met the lead freerequirement in the 2011 Act,and the replacement partsare sold for use in that spe-cific device, they would notmake the fixturenoncompliant, and thereforethose parts do not need tomeet the lead free require-ment.

25. Q. I am a plumber whoinstalls and repairs pipes, fit-tings or fixtures that provide

water for human consump-tion. If one of these devicesrequires replacement afterJanuary 4, 2014 does the newpipe, fitting or fixture need tomeet the new federal defini-tion of lead free?

A. Yes, the replacement ofa pipe, fitting or fixture wouldtrigger the requirements ofSection 1417 and the newpipe, fitting or fixture wouldneed to meet the new defini-tion of lead free. Section

1417(a)(1) prohibits the useof a pipe, fitting or fixture thatis not lead free in the installa-tion or repair of any plumbingin a residential or non-resi-dential facility providing waterfor human consumption.

26. Q. I am a plumber whoinstalls and repairs plumbingin facilities providing water forhuman consumption. A pipe,fitting or fixture requires repairof a part that is not a pipe, fit-ting, or fixture. Does the newpart need to meet the defini-tion of lead free? Summary OfThe Reduction Of Lead InDrinking Water Act And Fre-quently Asked Questions 13

A. No. The definition oflead free does not apply tocomponent parts that are not“pipes, pipe fittings, plumbingfittings, and fixtures” (referredto in these FAQs as “pipes,fittings, and fixtures”). EPArecommends that the wettedcomponents of any replace-ment parts that are not pipes,fittings, or fixtures also be leadfree. (See FAQ #2). EPA alsonotes that solder and fluxused to install or repair pipes,fittings and fixtures may notcontain more than 0.2 per-cent lead (See FAQ #1).

27. Q. I am repairing, inplace, a pipe, fitting or fixture,which provides water for hu-man consumption. The pipe,fitting of fixture was installedprior to January 4, 2014 andI do not know whether itmeets the new definition oflead free in the 2011 Act. Dothe replacement parts need tomeet the new definition of leadfree?

A. While the previously in-stalled pipe, fitting or fixturedoes not need to meet thenew definition of lead free asit was installed prior to the ef-fective date of the new leadfree requirements, the statu-tory language requires thatany replacement parts thatare pipes, fittings or fixturesmust meet the lead free re-quirements. In addition, EPArecommends that any re-placement parts that are notpipes, fittings, or fixtures thatcome into contact with po-table water should meet thedefinition of lead free in the2011 Act.

28. Q. I am repairing a pipe,fitting or fixture, which pro-vides water for human con-sumption. The pipe, fitting orfixture was installed afterJanuary 4, 2014 and meetsthe new definition of lead free.Do the replacement partsneed to meet the new defini-tion of lead free?

A. It is unlikely that some-body making a repair will beable to recalculate theweighted average of lead in



the pipe, fitting or fixture as awhole. Therefore, if the repaircalls for parts that are pipes,fitting, or fixtures, those partsmust meet the new definitionof lead free unless the repairis using parts specificallymade by the vendor for usein repairing the specific pipe,fitting or fixture in question,ensuring that the new parts

would have the same leadcontent as the existing partsthat are being replaced.

29. Q. If I am repairing apipe, fitting or fixture whichwas installed prior to January4, 2014 and I need to tempo-rarily remove it, does it needto meet the new definition oflead free after the repair hasbeen completed?

A. No. The repaired pipe,fitting, or fixture does not needto meet the definition of lead


Water Actfree because it is not being“used in” a repair or installedfor the first time or introducedinto commerce. Just as apipe, fitting, or fixture thatdoes not meet the new defi-nition of lead free may be re-paired in place, a pipe, fitting,or fixture can be temporarilytaken out of service for repairand returned to the same lo-cation without triggering therequirement to meet the defi-nition of lead free in the 2011

Act. Any component partsused in the repair that arethemselves pipes, fittings, orfixtures must meet the defini-tion of lead free in the 2011Act (see FAQ # 25).

30. Q. I operate a watersystem that temporarily re-moves pipes, fittings or fix-tures (e.g. seasonal storageor calibration) and the pipe,fittings or fixtures are returnedto their original location; mustthese pipes, fittings or fixturesmeet the new definition of leadfree after January 4, 2014?

A. No. Because the watersystem is simply returning anunaltered pipe, fitting or fixtureto the same location it wouldnot be required to meet thenew definition of lead free.

Introduction Into Com-merce

31. Q. Has EPA interpretedthe term “introduction intocommerce” in SDWA Section1417(a)(3)?

A. Yes. In 1998, after Sec-

tion 1417 was amended toprohibit the introduction intocommerce of any pipes, pipeor plumbing fittings or fixtures,EPA issued guidance on theenforcement and implemen-tation of Section 1417. In theguidance, EPA explained thatit “interprets ‘introduce intocommerce’ as used in Section1417 of SDWA to cover notonly the initial offering of prod-ucts for sale but also the saleor distribution from an inven-tory of products.” (WSG #129,Sept. 24, 1998, at 2).

32. Q. If I give away freereplacement parts, am I intro-ducing those parts into com-merce?

A. Yes. As noted, above,EPA has previously inter-preted the phrase “introduceinto commerce” as includingthe distribution of products,not just the sale of products,so giving away free productsor parts would be covered bythe Act.

Proposed Plumbing CodeChange to Require

Insulation of Hot WaterPiping in New BuildingsThe United Association of

Journeymen and Appren-tices of the Plumbing andPipefitting Industry (UA) andthe Natural Resources De-fense Council (NRDC) havereached an agreement on alandmark proposal to saveenergy and water in newbuildings. The two organiza-tions jointly submitted a pro-posal to the InternationalAssociation of Plumbing andMechanical Officials(IAPMO) to require the insu-lation of hot water piping innew buildings.

To curtail water waste innew buildings, NRDC and theUA proposed that the 2015edition of IAPMO’s UniformPlumbing Code require insu-lation of all hot water pipingsystems such as those serv-ing lavatories, showers, dish-washers and kitchen sinks.The Uniform Plumbing Codeis the model for local andstate plumbing codes now inforce in at least 19 states.

The following is a state-ment from William P. Hite,General President of theUnited Association:

“As IAPMO drafts its nextset of codes, we recommendinsulating hot water piping toreduce the waste of energyand water in hot water sys-tems. This proposal is in-dicative of the UA's commit-ment in construction, serviceand maintenance practices

required for energy efficientgreen buildings. Through-out the construction indus-try, there are untapped op-portunities to make our build-ings and our economy moreefficient, and we shouldseize these opportunities tocreate good jobs for Ameri-can workers.”

In a typical, 3-bedroom,2-bath home, an estimated12% of all hot-water use iswasted, according to a 2009analysis led by RobertHendron of the National Re-newable Energy Laboratory(NREL). Purging at showers,kitchen sinks and lavatoryfaucets was responsible for95% of the estimated total ofnearly 3,000 gallons of hotwater waste annually.

NRDC estimates pipe in-sulation can reduce thiswaste of water and energyby 15-30%. Of course, manynew homes are built withmore hot water outlets thanthe NREL model’s base case,and with hot water distribu-tion systems that are far lessefficient.

For example, some newhomes are built with theirhot-water heaters located inthe garage, far away fromshowers and faucets. Theproposed revision to UniformPlumbing Code will ensurethat hot water pipes supply-ing these fixtures are fullyinsulated.

december 31st, 2013 issue 12 volume 12 20 pages white...

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