EPA Deadline for Lead Service Line Inventories Approaching

Despite awareness of the harmful effects, lead in drinking water remains a continual threat to public health and safety, and much of the danger stems from the use of the metal in service lines in water distribution systems. To help alleviate this source of contamination, the EPA Lead and Copper Rule Revisions in January 2021 required water systems to create a record of service line materials to identify pipes that need to be replaced. The deadline for initial inventory submissions is October 16, 2024.

Ideally, water systems began conducting inventories when the rule came out and are prepared to submit on time. But for those not on track, here's a quick look at required elements, inventory planning and record review, and communication with the public alongside some helpful resources.

Prohibition on Lead Pipes

In 1986, Congress amended the Safe Drinking Water Act (SDWA) to prohibit the use of pipes, solder, or flux that are not "lead-free" in public water systems or plumbing in facilities providing water for human consumption. A decade later, Congress further amended the SDWA to require plumbing fittings and fixtures to comply with lead leaching standards.

But these regulations applied to new construction. Today, up to 10 million American households still connect to water through lead pipes and service lines, along with more than 400,000 schools and childcare facilities. With unequal development of infrastructure around the country, minority and poorer communities are disproportionately exposed to this toxic element. The situation is exacerbated by the lack of a national requirement to test school and daycare drinking water for lead, leaving millions of children at risk.

Required Service Line Inventory Elements

Replacing only some of the lead pipes in a water distribution system doesn't prevent harm from exposure, according to the Environmental Defense Fund and the EPA's Science Advisory Board (SAB). The SAB stated that partial replacements "have not been shown to be reliably effective in reducing drinking water [lead] levels."

Accelerating pipe replacement in the next decade is part of the Bipartisan Infrastructure Law. The EPA has allocated $3 billion in funding to states, Tribes, and Territories for service line replacement. This investment will help ensure the safety of drinking water in all communities regardless of income or race.

The first step is inventories that detail key characteristics of service lines. Water systems must classify service lines according to material—whether lead, galvanized requiring replacement (GRR pipes either were or are currently downstream of a lead or unknown material service line), non-lead, or status unknown. Where ownership is split, the classification must include both the system and customer lines. Where there is lead or GRR pipe, inventories must include location identifiers. The EPA also recommends tracking other drinking water infrastructure components in the inventory.

Inventory Planning and Record Review

Developing a service line inventory requires reviewing historical records to determine construction materials. Records should include construction and plumbing codes, construction dates, water system distribution maps, drawings, capital improvement plans, standard operating procedures, maintenance records or work orders for service connections and meter installations, and inspections and records of the distribution system. With information on the date your system implemented a ban on lead materials, you can designate service lines constructed afterward as non-lead. You may also need to conduct investigations or physical surveys, although this isn't required.

The EPA released Guidance for Developing and Maintaining a Service Line Inventory in August 2022 to help water systems conduct inventories and to provide states with information for oversight and reporting to the EPA. The guidance includes best practices, an inventory template, case studies, and a discussion of the importance of prioritizing inventory development in disadvantaged communities and where children live and play. The EPA's Fact Sheet for Developing and Maintaining a Service Line Inventory provides a quick summary of inventory requirements.

In addition, the EPA released the Small Entity Compliance Guide to help small water systems comply with the initial inventory requirements. To help educate water system teams, the EPA also developed a webinar with guidance for developing service line inventories.

Communicating with the Public

At a minimum, the EPA requires water systems to make a location identifier available for each lead and GRR service line and recommends that water systems make information on measures to reduce exposure available to consumers served by lead service lines. Water distribution systems with more than 50,000 customers must make their inventories available online.

If your water system includes lead, GRR, or unknown material service lines, you must notify people served by these lines within 30 days after completing the initial inventory. Community water systems must include instructions on how to access the inventory in their Consumer Confidence Reports.

Water Quality Testing to Detect Lead

Every home and facility has different plumbing, pipes, and materials, and not all can be easily categorized. Testing drinking water is the only way to assess if this harmful element is present, making water test labs essential to eliminate lead from drinking water.

The EPA recommends sending tap water samples to a certified water test lab for analysis. Costs typically run between $15 and $100, according to the EPA, but some states and utilities help pay for testing. It's a sound investment to be certain Americans won't risk the harmful effects of lead every time they take a drink of water.