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									   Lead in Plumbing

Department of Toxic Substances Control
         Pollution Prevention
  Multimedia Consumer Products Unit


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                    History of Plumbing

                  Plumbing comes from the Latin word for
                lead, which is plumbum.
                  The word sewer comes from the French
                word essouier, meaning "to drain".
                  Ancient Rome plumbing system
                  Present California



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‐How we (CA) got involved and what we’ve done 
‐Note definition of plumbing fitting/system in 24CFR3280.602
                        History of Lead in Plumbing Law

                     Federal & State Historically
                     Assembly Bill 1953 (2006)
                     Senate Bill 1334 (2008)
                     Senate Bill 1395 (2008)
                     Health and Safety Code Section 116875
                    & 25214.4.3
                     Other States

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Section 1417 of the Safe Drinking Water Act (SDWA) [Section 300g-6 of 42 U.S. Code (USC)]
•requires that after June 19, 1986, only "lead-free" pipe, solder or flux may be used in the installation
or repair of (1) public water systems or (2) any plumbing in a residential or non-residential facility that
is connected to a public water system and provides water for human consumption.
Lead and Copper Rule (EPA 1991-2007)
•Lead in drinking water results from corrosion of plumbing materials containing lead in contact with
the water.
•Cannot be easily detected from household pipes and faucets
•Law prohibits use of any pipe, pipe or plumbing fitting or fixture, solder, or flux that is not “lead free”
•Law prohibits any person engaged in the business of selling plumbing supplies, except
manufacturers, from selling solder or flux that is not “lead free”

HSC section 116875 (AB 1953), amended to add independent lab certification (SB 1334) and section
25214.4.3 (SB 1395) annual sampling and reporting by DTSC
•As of January 1, 2010, some of the lead content limits described above are required to be further
reduced. Beginning January 1, 2010, HSC section 116875 redefines "lead free" to mean that the
maximum allowed lead content is:
   • 0.2 percent lead in solder and flux;
   • 0.25 percent lead in wetted surfaces of pipes, pipe fittings, plumbing fittings and fixtures, as
determined by a weighted average.

Other State Laws Vermont’s Lead in Consumer Products Law, Act 193 (2008),
effective Jan 1, 2010; DC and Maryland are proposing similar laws.




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                         DTSC's Role in Implementing
                          Low Lead in Plumbing Law

                  Role as Auditor
                     Testing Protocol
                     Coordination and Outreach
                     Annually Sampling and Testing
                     Web Posting and Reporting
                     Continued Follow-up
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Lead in Plumbing Outreach
1) Materials Development:
Web site, factsheets (including Feb 2009 general requirement; August 2009 DTSC testing protocol); updating
FAQs; List Server for update (more than 200 subscribers); Lead in Pluming Email Address to answer inquiries;
Phone Hot Line and support from Regulatory Assistance Office
2) Testing Protocol development - coordinate with ECL Lead in Jewelry testing program and ANSI certifiers to
participate Round Robin testing evaluation
3) Priority of 2010 product sampling collection and testing: sampling strategy (draft developed and will be
posted soon);
4) Outreach to industry to better understand concerns. Meeting, providing information and response to targeted
entities and associations (e.g. PMI, CMC, ANSI accredited certifiers, National Ground Water Association,
EBMUD, Water Quality Association…)
5) Coordinate with NSF Lead Task Group to develop a national voluntary standard “Drinking Water System
Components – Lead Content” (stand alone version of Annex G) for testing and evaluation of lead content in
plumbing products
6) Coordinate with DPH, Legislature office and different lobbyist group on implementation

DTSC website
•Evaluating and selecting reliable and adequate test methods, protocols and sample preparation procedures;

•Coordinating with the plumbing manufacturing industry and providing information on testing protocols;

•Annually testing, to the extent that resource are available, up to 75 faucet, fitting, and/or fixtures samples to
determine compliance with "lead-free" standards;

•Posting the testing results on DTSC's Web site and transmitting them to the California Department of Public
Health (DPH); and

•Coordinating with DPH on regulatory issues.
    Metals of Concern
    in Plumbing Products




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                       Lead (Pb)

                           Naturally occurring
                           Historical use
                           Exposure routes
                           Effects most organs and systems
                           Severe effects on nervous system
                           May cause anemia
                           May severely damage the brain and
                           kidneys
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Chemical properties
•Low melting point
•Action level =0.015mg/L; sources: corrosion of household plumbing systems
•Most Pb leach from pipes and solder-corrosion, dissolved O2, and low pH
•Even at low level range of health effects
        • child < 6 most at risk because due to significant period of brain development; paint is the
        primary source of lead. Effects are delay in physical and mental development
        •For adults, kidney damage, reproductive effects, high blood pressure, memory & problems
        in concentrating
•Can’t be detected by smell, taste, and/or see contamination
•Level limits=15 PPB (parts per billion)
•MCLG=0!
                       Copper (Cu)

                           Brass is any alloy of copper and zinc.
                           High brass is used for spring, screws
                           and rivets due to its high tensile
                           strength.
                           Bronze is principally an alloy of
                           copper and tin.
                           Often used in pipe fittings
                           Health effects
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•   Lead is added to brass to reduce machine tool wear.
•   Germicidal, e.g. brass doorknobs disinfecting themselves of many bacteria within 8 hours
•   Despite this distinction some types of brasses are called bronzes and vice-versa.
•   Leaded brass is an alpha-beta brass with an addition of lead. It has excellent machinability,
    easily worked due to its ductile and malleable properties.
•   History of use back 10,000 years
    -Over course of centuries experience with copper smelting assisted in development of other
    metals
    -Alloying Cu with Zn (Zinc) to make brass and bronze [Bronze Age]
    -Cu became important culturally as used in coinage and holistic medical science (i.e.: sterilizing
    wounds, headaches, burns, gargling for      sore throats
•   “Modern” use
    -copper plating (“sheeting” of ship halls)
    -wire as conductor; 1990 super conducting material; printed circuit boards
    -electrochemical reaction between iron and copper in plumbing, failure of union therefore non-
    conducting material between (plastic or rubber)
•   Toxicity- eating acidic food cooked in Cu cookware, cirrhosis of liver in Indian children from
    boiling milk in Cu pots
•   Action level: 1.3 mg/L; sources of contamination: Corrosion of household plumbing systems;
    erosion of natural deposits etc.
                                       Cadmium (Cd)

                                            Naturally occurring
                                            Current uses
                                            Exposure routes
                                            Lung damage
                                            Stomach irritation
                                            Build-up in kidneys
                                            Fragile bones

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•Sources of contaminant in drinking water:
             • corrosion of galvanized pipes
             • erosion of natural deposits
             • solder byproduct

•Main exposure routes:
            • inhalation in work environment leading to pneumonias, pulmonary edema, or death; exposure also through smoking tobacco

•MCL: 0.005 mg/L

•Concern of Cadmium based products to be hazardous waste when disposal:
             •TCLP and STLC: 1.0 mg/L
             •TTLC wet weight: 100 mg/kg

•Cd primarily for metal plating and coating
             • baked enamel
             • H2O-longterm kidney damage (MCL= 5 ppb)
             • “Hai-itai” disease in Japan (1912-1946) from mining discharge; massive Cd poisoning
             • softening of bone
             • kidney failure
             • not identified as cause until 1968

•Source of contaimination
             • galvanized pipes
             • solder byproduct
             • removal from H20 > coagulation/filtration
                           • ion exchange and lime softening
             • Use decreased significantly because of high toxicity & carcinogenicity

• Current use in Ni-Cd batteries & solar panels (Cd-telluride)

• Byproduct found in Zinc & lesser extent Pb & Cu
                       Other Metals of Concern

                           Arsenic (As)
                           Mercury (Hg)
                           Hexavalent Chromium (Cr+6)




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DTSC regulates other metals within pollution prevention
Arsenic (As)
• sore throat or irritated lungs, nausea and vomiting, decreased production of red and white blood
cells, abnormal heart rhythm, damage to blood vessels, and a sensation of “pins and needles” in
hands and feet
• Ingestion of methyl and dimethyl compounds can cause diarrhea and damage to the kidneys
• MCL: 0.05 mg/L
Mercury (Hg)
• Naturally occurring in several forms
        •Metallic mercury (silvery liquid)
        •Inorganic mercury (combined with inorganic elements)
        •Organic mercury (combined with carbon)
•The nervous system is very sensitive to all forms of mercury
•Can permanently damage the brain, kidneys, and developing fetus
•MCL: 0.05 mg/L
Hexavalent Chromium (Cr+6)
• MCL: 0.1 mg/L (total)




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Yeah, but what about that law?




     …Wetted surface area…???




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                                 10
                             Weighted Average Lead
                                    Content
                        n   ⎛   ⎢ WSA c ⎥ ⎞
                 WLC = ∑ ⎜LCc x ⎢
                            ⎜           ⎥⎟
                       c =1 ⎝   ⎣ WSA t ⎦ ⎟
                                          ⎠

                 WLC = weighted average lead content of product
                 LCc = percentage lead content of component
                 WSA c = wetted surface area of component
                 WSA t = total wetted surface area of all components
                  n         = number of wetted components in product
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CALIFORNIA CODES HEALTH AND SAFETY CODE SECTION 116875‐116880 excerpts:

• For the purposes of this section, "lead free" means not more than 0.2 percent lead when used with
respect to solder and flux and not more than a weighted average of 0.25 percent when used with
respect to the wetted surfaces of pipes and pipe fittings, plumbing fittings, and fixtures.


• "lead free," not more than 8 percent when used with respect to pipes and pipe fittings. With respect
to plumbing fittings and fixtures, "lead free" means not more than 4 percent by dry weight after
August 6, 2002, unless the department has adopted a standard, based on health effects, for the
leaching of lead.
              Questions?

              Health Effects




        Law                    DTSC Role

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Q & A
                   Important Links

                        Lead-in-Plumbing-Fact-Sheet Feb.
                        2009
                        Lead-in-Plumbing-Testing-Protocol
                        Fact Sheet Aug. 2009
                        CA Health & Safety Code 116875
                        CA Health & Safety Code 25214.4.3



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•http://www.dtsc.ca.gov/PollutionPrevention/upload/Lead‐in‐Plumbing‐Fact‐Sheet.pdf


•http://www.dtsc.ca.gov/PollutionPrevention/upload/lead‐in‐plumbing‐testing‐
protocol.pdf


•http://www.dtsc.ca.gov/PollutionPrevention/upload/Lead_in_Plumbing_HSC_116875.pdf


•http://www.dtsc.ca.gov/PollutionPrevention/upload/Lead_in_Plumbing_HSC_25214‐4‐
3.pdf
      Contact Information

Multimedia Consumer Products Unit
Office of Pollution Prevention and Green
Technology
Department of Toxic Substances Control
P.O. Box 806, Sacramento, CA 95812-0806
Phone: (916) -323-9757
Email: leadinplumbing@dtsc.ca.gov

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