UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     GUIDANCE FROM HOTLINE COMPENDIUM
                                                                             WSGH40
                                                             Date Issued: December 1991
SUBJECT:   Faucets Interpreted as "Lead Pipe Fittings"

SOURCE:    Jeff Cohen
             Peter Lassovszky
On June 7, 1991, EPA finalized the Lead and Copper Rule that establishes revised National
Primary Drinking Water Regulations (NPDWRs) for lead and copper (56 FR 26460).  Section
141.85 (a)(3)(ii), the public education and supplemental monitoring requirements, states that
"Congress banned the use of lead solder containing greater than 0.2% lead, and restricted the lead
contents of faucets, pipes, and other plumbing materials to 8.0%."  In reviewing the provisions of
the Lead Ban, it is not apparent that the term "faucet" is specifically included. Section
1417(d)(2) of the Safe Drinking Water Act states that the term lead-free — "when used with
respect to pipes and pipe fittings refers to pipes and pipe fittings containing not more than 8.0
percent lead."

The Safe Drinking Water Hotline's Compendium of Responses to Policy Inquiries resolves
several issues dealing with the Lead Ban and faucets. One of the issues (Issue VUI-5) responds
to a lead sample size question by indicating site sources to include "faucets, fittings, pipes, and
solder" for lead sampling. Another issue (Issue VIU-4) addresses interpretation of pipe fittings
which states that "it is reasonable to suggest that various other elements common to water
distribution systems-such as joints,  valves, meters, and fire hydrants—must be lead-free as well."

Is it EPA's interpretation that the term "faucets" was intended to be covered by the term "pipe
fitting"?

       Response:

       Yes, in implementing the provisions of the Lead Ban, EPA has included the term
       "faucets" as a "pipe fitting", under the restrictions of the Lead Ban.  EPA believes that the
       term "pipe fitting" purposely was used to include a wide range of plumbing products to
       protect the public against the use of lead in drinking water.

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