How Safe Drinking Water Standards Affect Pump Users

Manufacturers and end users must certify the entire pump system to ensure compliance with a 2011
amendment to The Safe Drinking Water Act.
by David Carrier, QuantumFlo, Inc.

Simply using National Sanitation Foundation (NSF)-certified valves, pumps, fittings, tubing
and other parts is not sufficient because the system has not passed the NSF 61 standard in
accordance with NSF 372 requirements.

The Reduction of Lead in Drinking Water Act, enacted and signed by President Barack Obama
on Jan. 4, 2011, amended Section 1417 of the Safe Drinking Water Act (SDWA), which was
passed in 1974. Since its inception, SDWA has been updatedonce in 1986 and again in
1996to prohibit the use of lead by volume and the introduction of contaminants harmful to
human health into commerce.

The primary purpose of the 2011 change was to reduce the maximum allowable lead content of
the wetted surfaces of plumbing productssuch as pipes, pipe fittings, plumbing fittings and
fixturesfrom 8.0 percent to a weighted average of 0.25 percent.

SDWA Section 1417 applies to the entire plumbing systemfrom the water meter to the last
fixture in the building. The plumbing devices affected by this law now include domestic water
booster pumps. The amendment established a prospective effective date of Jan. 4, 2014, which
provided three years for affected parties to transition to the new requirements.
Image 1. The assembly process, as well as the testing process, must be evaluated to comply
with the current requirements of NSF 61. (Images courtesy of QuantumFlo, Inc.)

The act also established a statutory method for the calculation of lead content (now known as
Annex G) and eliminated the requirement that lead-free products comply with voluntary
standards established in accordance with SDWA 1417(e) regarding the leaching of lead from
new plumbing fittings and fixtures. Once the voluntary standard was eliminated, lead content
limiting requirements became mandatory, requiring third-party certification by a nationally
recognized testing laboratory.

NSF & California Certifications

Because the act required a standard for compliance, NSF Standard 61 was developed to provide
a benchmark to facilitate compliance for facilities that manufacture, sell or distribute water
dispensing equipment in North America. Since its inception, NSF 61 has been modified to
create additional clarifications regarding compliant materials and methods. Before 2011, the
standard also added a low-lead component requested by the state of California, known as
Annex G.

While Annex G was evolving, California had already passed a separate state law known as AB
1953, which revised their methods, requiring minimum lead-free content at the tap. With the
new California law in place and the January 2014 mandate imminent, consultants, contractors
and manufacturers began the certification process.
The new method for determining lead-free content (which by definition, becomes a weighted
average of 0.25 percent) has become known as NSF 372.

Image 2. Many currently certified centrifugal pumps are constructed in 304 stainless steel to
comply with NSF 372 but must also be approved to NSF 61.

NSF 372 is not a standard, but it is a specification that sets the minimum lead content allowable
percentage. Any product that has obtained the rigorous NSF 61 certification must first comply
with the methods and values defined in NSF 372, among others. Because NSF 372 mirrors the
California AB 1953 law, facilities that have a certification by a third-party laboratory indicating
product compliance with California AB 1953 are also compliant with NSF 372.

Compliance with the SDWA became mandatory in January 2014. If the SDWA is the
mandate and NSF 61 provides the vehicle for compliance to the mandate, it becomes the
responsibility of plumbing codes, such as Uniform Plumbing Code (UPC) and the International
Plumbing Code (IPC), to establish enforcement. A manufacturer of these components cannot
comply with the SDWA except by certification to NSF 61, which is required by the plumbing
codes.

The SDWA Section 1417 recognizes all plumbing devices, including pipes, fittings and all
components within the plumbing system from source to tap. In the case of a commercial
building, the law is applied to the entire plumbing system.

Water Booster Pumps

Domestic water booster pumps are among these plumbing devices. Because they are
prefabricated, they require certification as an entire system rather than the individual parts.
Simply using NSF-certified valves, pumps, fittings, tubing and other parts is not sufficient
because the system has not passed the NSF 61 standard in accordance with NSF 372
requirements as required by current plumbing codes.

Despite these requirements, some manufacturers did not begin compliance testing early enough
and are scrambling to complete testing. Others put off certification. End users must ensure that
the manufacturer of their system is certified to the SDWA amendment, which has been in effect
since Jan. 4, 2014.

Users can easily recognize a complete system certification by looking at the certification
document provided by the test laboratory. If the certification does not show the complete series
of products, the manufacturer may have only certified a component of the system and not the
whole packaged system, which means that the system is not fully compliant. Any company that
has not completed system testing is in violation of federal law.

A device or system installed in the potable water system that does not pass compliance must be
replaced. Any item installed after Jan. 4, 2014, that is not certified must be removed from the
system or should not be installed.