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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