UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
GUIDANCE FROM HOTLINE COMPENDIUM
WSGH12
Date Issued: September 1988
SUBJECT: Lead Ban Enforcement
SOURCE: Chet Pauls
A State official submits the lead prohibition certification to the Regional administrator. The
certification says that the prohibition must be enforceable throughout the State. In addition, the
State "must demonstrate effective enforcement activity in subsequent years", as stated in the
State Implementation and Enforcement of the Lead Prohibition and Lead Public Notice
Requirements of the Safe Drinking Water Act - policy guidance from Michael Cook, Director,
Office of Drinking Water, to Rebecca W. Hanmer, Acting Assistant Administrator for Water.
The official is unclear on the meaning of "subsequent year." It does not clearly define when the
demonstration is required. Exactly when must the State demonstrate satisfactory enforcement
activity?
Response:
Section U B (2) of this guidance (page 7) is quite clear in its explanation that subsequent
years refers to all years following an initial certification in FY 1989. It says: "In FY
1990 and beyond, States must have initial certification approval and must also
demonstrate effective lead ban enforcement to receive their full Public Water System
Supervision (PWSS) grant. The certification should account for any unique State
authorities or situations."
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