Frequent Questions

How does EPA interpret the new statutory provisions to apply to repairs, reinstallations, and replacement parts?

Repairs of previously installed pipes, fitting or fixtures

A pipe, fitting or fixture that was installed in a public water system or a facility providing water for human consumption prior to the effective date of the 2011 Act does not need to meet the new definition of lead free regardless of whether it is repaired. The repaired pipe, fitting or fixture is not being "used" in the repair or installation, or "introduced into commerce" and therefore, the requirements of Section 1417 are not triggered as a result of the repair. Parts used in repairs may need to meet the requirements of Section 1417 (see "Replacement Parts" below and FAQ #24, 26, 27 and 28).

The temporary removal of pipes, fittings, or fixtures for repairs and reinstallation to their original location would not trigger the requirements of Section 1417 because the pipes, fittings or fixtures are not being installed or "used in" repair. (See FAQ #29). Similarly, the temporary removal of pipes, fittings or fixtures for storage or calibration and reinstallation to their original location would not trigger the requirements of Section 1417. (See FAQ #30.)

Replacement Parts

After the effective date of the 2011 Act, any replacement parts that are pipes, fittings, or fixtures either installed or used in repairs of a public water system or a facility providing water for human consumption, or introduced into commerce, must meet the definition of lead free. (See FAQ #25)

However, where the replacement of pipes, fittings, or fixtures is part of a device (such as a water heater) made up of several component parts and the device meets the definition of lead free in the 2011 Act, the replacement parts themselves need not meet the new definition of lead free. As long as the overall device would meet it with the replacement part installed, then the requirements of Section 1417 would be met. Such replacement parts should be labeled as specifically for use in the device that meets the new definition of lead free. (See FAQ # 24.)

Also, the use or introduction into commerce of replacement parts that are not pipes, fittings, or fixtures does not trigger the requirements of Section 1417. EPA recommends that any replacement parts that are not pipes, fittings, or fixtures that come into contact with potable water meet the definition of lead free in the 2011 Act because of their potential to cause elevated levels of lead in drinking water, but they are not required to do so. (See FAQ #26.)

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