Volume 2. No. 1, March 1998

When It Comes to Safe Drinking Water, There's More Than Meeting the Regulations

In 1974, Congress passed the Safe Drinking Water Act, requiring the EPA to set mandatory standards for the quality and safety of water at the tap. Compliance with these standards is a key aspect in assuring safe drinking water. But the very chemicals used to treat water and the distribution systems that convey water to the consumer can also contribute unhealthy levels of contaminants. Unless these products have been evaluated for contaminants and certified as meeting health standards, the water reaching the consumer may not be safe.

Standards are not mandatory

Standards for the chemicals used for treating drinking water and for the system components are not a mandatory part of the federal laws and regulations that guide our national drinking water program. Instead, standards were developed under a voluntary program with input from regulators, product manufacturers and water utilities.

Water safety now depends on the state regulators adopting these standards, manufacturers providing products that comply with the standards, and water utilities specifying and using products certified to these standards.

For many years, the FDA, and more recently, the EPA, provided technical assistance to states and to water utilities in the form of advisory opinions on the safety of drinking water additives. These were typically lists of treatment chemicals added directly to water -such as alum, polymers and corrosion inhibitors. The old EPA lists also included drinking water system components such as storage tank coatings, piping and appurtenances that can add contaminants to water. In 1988, when the EPA discontinued this advisory function, the role of setting standards for additives was taken over by a consortium of stakeholders headed by NSF International. Other consortium members include the American Water Works Association Research Foundation, the Association of State Drinking Water Administrators, the American Water Works Association, and Conference of State Environmental and Health Managers (COSHEM no longer exists). The consortium and industry representatives provided guidance on the development of third-party volunteer standards.

Completion of the standards in 1988 launched the product certification program, which involved the long-term process of developing listings of certified products. The original consortium members continue to oversee the implementation of this program, which the states and utilities rely upon to make product specifications and purchase decisions.

Two Standards Adopted by ANSI

Two standards for assuring the safety of drinking water additives have been adopted by the American National Standards Institute (ANSI). ANSI/NSF Standard 60: Drinking Water Treatment Chemicals-Health Effects covers drinking water treatment chemicals; ANSI/NSF Standard 61: Drinking Water System Components-Health Effects covers indirect additives. These standards continue to be updated by a voluntary consensus process that represents all stakeholders, including regulatory agencies, industry, water suppliers and consultants.

ANSI has accredited NSF International in Ann Arbor, Michigan, to certify products against both of these standards. The organization has certified many different types of water treatment chemicals and systems components to the NSF Standards.

For more information on the NSF Program, contact Dave Purkiss at NSF International, (800) NSF-MARK, ext. 5715, or email to purkiss@nsf.org. You can also visit the NSF website at www.nsf.org. The organization maintains Listings of certified products on its website.

If your water utility is not currently requiring suppliers to meet these standards, it should be. According to a 1997 survey conducted by the Association of State Drinking Water Administrators, 41 states require compliance with ANSI/NSF Standards 60 and 61 through legislation, regulation or policy. Twenty-nine states have enacted legislation or regulations, and 12 require compliance by policy. Three other states have proposed legislation to establish compliance requirements.

Specification of these standards meets state requirements and also makes good sense. Recent incidents of drinking water contamination could have been avoided had the products used been certified to comply with ANSI/NSF Standards. For example, recent cases include documented contamination of drinking water from newly installed tube settlers. In these cases, surface water treatment plants detected significant concentrations of dichloromethane in their treated water, but none in the raw water. Extensive sampling and investigation implicated the tube settlers. It took the better part of a year for contaminant concentrations to decrease to attain the levels below the detection limits. This problem could have been avoided by requiring certified products.

Over the years, there have also been similar incidents as a result of utilities using non-certified piping materials and storage tank coatings.

The certification of faucets to ANSI/NSF Standard 61 meets the requirements of the Safe Drinking Water Act Amendments of 1996. This is important for compliance with the requirements of the EPA's Lead and Copper Rule, because most of the lead in the required one liter first draw samples would typically come from the faucet. Certification to ANSI/NSF Standard 61 assures that even brand new faucets, which typically reach the highest lead concentrations, will meet the target values for lead concentrations at the tap. As a drinking water professional, you should make sure that local plumbing codes are modified to incorporate product compliance with ANSI/NSF 61 as quickly as possible.

New Disinfection By-Products and Surface Groundwater Rules

Implementation of the new Disinfection By-Products and Surface Water Treatment Rules may possibly result in increased use of organic polymers in filtration plants. Chemically speaking, organic polymers are complex products. Using polymer products that have not been evaluated for toxicological safety is a risky practice when it comes to protecting public health. In addition to good practice there are also regulatory requirements for epichlorohydrin and acrylamide monomers, two contaminants found in organic polymers.

Certification of these organic polymers to ANSI/NSF Standard 60 will assure that these products comply with the regulatory requirements.

The third-party standards and certification program works as a result of cooperation between manufacturers, utilities and state and federal regulatory agencies. Everyone's support is required to make the program function well and to assure that the public's interest and health are properly protected, so think about how you can support this important program at your company, agency or utility.

For more on the NSF Certification Program for Drinking Water Additives, contact Dave Purkiss at (800) NSF-MARK, ext. 5715, or send email to purkiss@nsf.org.

Dave Purkiss, General Manager,
Drinking Water Additive Program

Q&A:

1996 Amendments to the Safe Drinking Water Act and NSF Standard 61

The US EPA released the following commonly asked questions related to the 1996 Amendments to the Safe Drinking Water Act on February 10, 1998. Part of the article is reprinted here with permission.

Is there any law or regulation for lead in drinking water?

Yes. The National Primary Drinking Water Regulations (NPDWR) for Lead and Copper, 40 CFR Parts 401 and 142, promulgated in 1991, established an action level of 15 parts per billion (ppb) for lead in drinking water. Action level exceedence is measured by the concentration of lead in a number of samples collected from a specified number of consumers' taps. The lead action level is exceeded if the concentration of lead in more than 10 percent of tap water samples is greater than 15 ppb. Public water systems exceeding the lead action level are triggered into treatment technique requirements, including corrosion control treatment, public education, and, if appropriate source water treatment and/or lead service line replacement.

Is there a performance standard limiting the leaching of lead into drinking water from faucets, fittings, fixtures, pipes and plumbing devices?

A voluntary standard, the NSF International consensus Standard 61 (ANSI/NSF Standard 61: Drinking Water System Components-Health Effects), including inline and endpoint devices has been established. The criteria for lead in the NSF Standard limits the amount of lead that can leach into the water from a particular product. Devices made of brass alloys which contain lead may be certified if they pass the performance test prescribed by the Standard. Some manufacturers modified their manufacturing processes to meet the NSF Standard.

NSF Standard 61, section 9 covers endpoint devices. The NSF Standard defines endpoint devices as mechanical plumbing devices, components, and materials which are typically installed within the last liter of the distribution system and are intended by the manufacturer to dispense water for human ingestion. The devices include kitchen and bar faucets, lavatory faucets, water dispensers, drinking fountains, water coolers, glass fillers, residential refrigerator ice makers, supply stops and endpoint control valves.

NSF Standard 61, section 8, covers mechanical devices which include inline devices in building distribution systems including any device that is used to measure or control the flow of water that is used in treatment/transmission distribution systems, and is in contact with the water intended for human ingestion. Inline devices in a building used to measure or control the flow of water include water meters, building valves, check valves, meter stops, valves and fittings backflow preventers, etc. The NSF Standard defines inline devices as any device installed on a service line or building distribution system downstream of the water main and before endpoint devices.

NSF Standard 61, Section 4, covers pipes, fittings and small drinking water storage devices having domestic or residential applications including the products or water contact materials of pipes, fittings, tubing, hoses, well casing, drop pipes and screens, etc.

How does NSF Standard 61, Section 9 relate to the definition of lead free?

NSF Standard 61, Section 9 relates to the amount of lead leached from a product while the definition of "lead free" for pipe and pipe fittings corresponds to a maximum of 8 percent lead content. By amending section 1417 of the SDWA, Congress incorporated a performance standard into the law for endpoint devices intended to "dispense water for human consumption." Section 1417(e) of the SDWA states that "lead free" with regard to plumbing fittings and fixtures intended to dispense water for human consumption means those fittings and fixtures that are in compliance with a voluntary standard established pursuant to the Act.

The reason for this requirement by Congress, EPA believes, was that some brass fittings and plumbing fixtures containing 8 percent or less lead have been found to contribute high lead levels for a considerable amount of time after their installation, even in contact with relatively non-corrosive waters. Because of low flow and infrequent usage, lead concentration levels in water in contact with endpoint devices containing dispensing water for human consumption were found to exceed the 15 ppb action level for lead, established by EPA in the Lead and Copper Rule.