Get the Lead Out FAQ

  1. Is there a list of specific appliances that are exempt or a place to get this information? The language of the law provides a list of exempt items: "(4) EXEMPTIONS.—The prohibitions in paragraphs (1) and (3) shall not apply to - (A) pipes, pipe fittings, plumbing fittings, or fixtures, including backflow preventers, that are used exclusively for nonpotable services such as manufacturing, industrial processing, irrigation, outdoor watering, or any other uses where the water is not anticipated to be used for human consumption; or (B) toilets, bidets, urinals, fill valves, flushometer valves, tub fillers, shower valves, service saddles, or water distribution main gate valves that are 2 inches in diameter or larger." Interpretation of this wording is open to the Authority Having Jurisdiction.

  2. What type of valve should be used when a 4" main supplies a high rise or multi-family? The language of the law provides that water distribution main gate valves 2” and larger are exempt.

  3. Are dishwashers considered devices that supply drinking water? Dishwashers are not specifically listed as an exempt product and as such should be discussed with the Authority Having Jurisdiction.

  4. Shower valves listed as an exemption, does this also include shower heads as exempt devices?
    Shower valves are specifically listed in the Senate Bill language, shower heads are not. While it seems intuitive that shower heads would be included, assuming this would not be wise. It would be best to verify any items that are believed to be in question with the local Authority Having Jurisdiction.

  5. Are hose thread valves exempt or would they be considered products that are anticipated to convey water for human consumption?
    Exemption A states:
    ‘‘(A) pipes, pipe fittings, plumbing fittings, or fixtures, including backflow preventers, that are used exclusively for non-potable services such as manufacturing, industrial processing, irrigation, outdoor watering, or any other uses where the water is not anticipated to be used for human consumption; Hose thread valves are not specifically exempt. If they are used exclusively for nonpotable services, then the exemption could apply. In any case, the application should be verified with the Authority Having Jurisdiction.

  6. Do fixtures that connect to potable water lines but do not convey water meant for drinking (chemical dilution systems, dishwashers) fall under the "not anticipated to convey water for human consumption" exemptions?
    Piping that is used exclusively for non-potable uses is exempt. Interpretation of the document will ultimately lie with the local Authority Having Jurisdiction and as such, communication with these representatives is critical in determining acceptability of installed products.

  7. It has been stated that a pipe size 2" and less must meet the law. What about larger pipe sizes?
    The actual language in the exemption states:
    "(B) toilets, bidets, urinals, fill valves, flushometer valves, tub fillers, shower valves, service saddles, or water distribution main gate valves that are 2 inches in diameter or larger."

    The exempt device is a water distribution main gate valve that is 2 inches in diameter or larger. Other fittings and devices would need to be verified with the Authority Having Jurisdiction.

  8. Will electronic (self-closing) sensor faucets used in public restrooms be affected?
    As these devices are not specifically exempted, it would be reasonable to assume they will be included if it is anticipated that they may provide drinking water. Check with the local jurisdiction for their compliance requirements.

  9. Are mop/service sink faucets or laundry valves exempt?
    Mop sink faucets and laundry valves are not specifically exempt and might not be anticipated to provide water for human consumption. If there is concern that these products might provide drinking water, they would be subject to interpretation by the local Authority Having Jurisdiction.

  10. If a brass well tank tee needs to be changed, but a brass insert fitting connecting the poly pipe to the tee must be disconnected, can the brass insert fitting be re-connected?
    This is an interpretation issue that would best be answered by the local Authority Having Jurisdiction.

  11. Are components in the hot water system also covered by the new law?
    The law covers water intended for human consumption, if it is anticipated to be drinking water, it will be included. Specific cases should be discussed with the local Authority Having Jurisdiction.

  12. Do water meter, sub-water meters, or meter setting devices have to meet this requirement also?
    The law covers water intended for human consumption, the application of the water passing through the meters or setting devices would be a consideration. Specific cases should be discussed with the local Authority Having Jurisdiction.

  13. Is there a timeframe in which existing installed products must be replaced with lead free?
    The law requires new products, new installations, and repair work to comply with the regulation, there is no requirement to remove or retrofit existing products.

  14. If you repair a system or have a renovation that adds to a system, do you have to bring the entire system up to the new law?
    Materials installed must comply with the law after the effective date. There is no requirement to remove existing, functioning devices and replace with compliant products.

  15. Are galvanized products affected by this regulation?
    The changes being discussed are targeting brass products and reducing lead contents, therefore, this presentation has only considered the changes in brass products.

  16. Are backflow preventers being considered to isolate potable from non-potable systems or branches?
    Backflow prevention devices are required by the model codes to protect the potable water supply from hazardous conditions. Consult with local jurisdictions to determine if they may be considering increased application of these products.

  17. When a water main has a branch feeding the potable supply and another branch feeding a hydronic boiler heating system, would the backflow preventer require compliance to no-lead?
    Backflow prevention to devices such as hydronic heating boilers are prescribed by the plumbing code adopted by the jurisdiction. Consult with the local Authority Having Jurisdiction to determine the local requirements for these products.

  18. Will all fittings and piping that is lead free be marked accordingly?
    There is no uniform standard marking at this time but manufacturers are marking products in their own fashion. When in doubt, consult the manufacturer for clarification. It would be unwise to assume products are in compliance if no marking or documentation can be found.

  19. Is there a federal resource that can give an 'official' interpretation?
    Official interpretations will be provided by the EPA and are expected after implementation of the law, January 4, 2014.

  20. Does the lead free act take effect universally in all states on Jan 4 2014, or does this require adoption by local/state codes similar to current adoption/modification of model national codes?
    The law is a modification of the Safe Drinking Water Act and as such will apply equally across the country. There is no local adoption or modification needed.