3Ts: TRAINING, TESTING, TAKING ACTION -S- Module 4: Developing a Sampling Plan Lead Water Coolers Banned in 1988 Lead Water Coolers Banned in 1988 The Lead Contamination Control Act (LCCA), which amended the Safe Drinking Water Act (SDWA), was signed into law on October 31, 1988 (P.L. 100-572). The potential of water coolers to contribute lead to drinking water in schools and child care facilities was a principal focus of this legislation. Specifically, the LCCA mandated that the Consumer Product Safety Commission (CPSC) order the repair, replacement, or recall and refund of drinking water coolers with lead-lined water tanks. In addition, the LCCA called for a ban on the manufacture or sale in interstate commerce of drinking water coolers that are not "lead-free." Civil and criminal penalties were established under the law for violations of this ban. With respect to a water cooler that may come in contact with drinking water, the LCCA (Section 1461 of SDWA) defines the term "lead-free" to mean: not more than 8 percent lead, except that no drinking water cooler which contains any solder, flux, or storage tank interior surface which may come in contact with drinking water shall be considered "lead-free" if the solder, flux, or storage tank interior surface contains more than 0.2 percent lead. Another component of the LCCA was the requirement that EPA publish and make available to the states a list of drinking water coolers, by brand and model, that are not "lead-free." In addition, EPA was to publish and make available to the states a separate list of the brand and model of water coolers with a lead-lined tank. EPA is required to revise and republish these lists as new information or analyses become available. Based on responses to a Congressional survey in the winter of 1988, three major manufacturers (the Halsey Taylor Company, EBCO Manufacturing Corporation, and Sunroc Corporation) indicated that lead solder had been used in at least some models of their drinking water coolers. On April 10,1988, EPA proposed in the Federal Register (54 FR 14320) lists of drinking water coolers with lead-lined tanks and coolers that are not "lead-free." Public comments were received on the notice, and the list was revised and published on January 18,1990 (Part III, 55 FR 1772). See the following page for a list of water coolers and lead components included on that list. Important Note: The 1990 list is based on a definition of "lead free" in SDWA applicable to drinking water coolers only (SDWA Section 1461). At the time it was enacted, the 8% standard of the definition was the same as the definition of lead free in another section of SDWA applicable to pipes, pipe fittings, plumbing fittings, and fixtures, solder and flux (SDWA Section 1417). Since then, however, the definition of "lead free" for pipes, fittings, and fixtures in Section 1417 was changed as a result of the 2011, THE REDUCTION OF LEAD IN DRINKING WATER ACT to a weighted average of 0.25 percent of the wetted surface. It is still important to test fixtures that are not on this list; especially if they were installed prior to 2014, the year THE REDUCTION OF LEAD IN DRINKING WATER ACT became effective. f/EPA AND DRINKING WATER Office of Water (4606M) EPA 815-F-18-019 October 2018 ------- TESTING \ BTs: TRAINING, TESTING, TAKING ACTION r ^ s*f." ¦v*' '«• ^ List of Water Coolers and Lead Components EBCO Manufacturing All pressure bubbler water coolers with shipping dated from 1962 through 1977 have a bubbler valve containing lead. The units contain a single 50-50 tin-lead solder joint on the bubbler valve. Model numbers for coolers in this category are not available. The following models of pressure bubbler coolers produced from 1978 through 1981 contain one 50-50 tin lead solder joint each. CP3 DP15W DPM8 IP 13P DPM8H DP15M DP3R DP8A DP16M DP5S C10E PX-10 DP7S DP13SM DP7M DP7MH DP7WMD WTC10 DP13M-60 DP14M CP10-50 CP5 CP5M DP15MW DP3R DP14S DP20-50 DP7SM DP10X DP13A DP13A-50 EP10F DP5M DP10F CP3H CP3-50 DP13M DP3RH DP5F CP3M EP5F 13PL DP8AH DP13S CP10 DP20 DP12N DP7WM DP14A- 50/60 Halsey Taylor Lead solder was used in these models of water coolers manufactured between 1978 and the last week of 1987: WMA-1 SCWT/SCWT-a SWA-1 DC/DHC-1 S3/5/10D BFC-4F/7F/4FS/7FS S300/500/100D The following coolers manufactured for Haws Drinking Faucet Company (Haws) by Halsey Taylorfrom November 1984 through December 18, 1987, are not lead-free because they contain 2 tin-lead solder joints. The model designation for these unites are as follows: HC8WT HC14F HC6W HWC7D HC8WTH HC14FH HC8W HC2F HC14WT HC14FL HC14W HC2FH HC14WTH HC8FL HC4F HC5F HC14WL HCBF7F HC4FH HC10F HC16WT HCBF7HO HC8F HC8FH HC4W HWCZ ------- 3Ts: TRAINING, TESTING, TAKING ACTION TESTING Lead Lined Tanks Prior to publication of the January 1990 list, EPA determined that Halsey Taylor was the only manufacturer of water coolers with lead-lined tanks. Below provides a listing of model numbers of the Halsey Taylor drinking water coolers with lead-lined tanks that had been identified by EPA as of January 18,1990. Based upon an analysis of 22 water coolers at a U.S. Navy facility and subsequent data obtained by EPA, EPA believes the most serious cooler contamination problems are associated with water coolers that have lead- lined tanks. Since the LCCA required the CPSC to order manufacturers of coolers with lead-lined tanks to repair, replace, or recall and provide a refund of such coolers, the CPSC negotiated such an agreement with Halsey Taylor through a consent order published on June 1, 1990 (at 55 FR 22387). The consent agreement calls on Halsey Taylor to provide a replacement or refund program that addresses all the water coolers listed below as well as "all tank- type models of drinking water coolers manufactured by Halsey Taylor, whether or not those models are included on the present or on a future EPA list." Under the consent order, Halsey Taylor agreed to notify the public of the replacement and refund program for all tank type models. Currently, a company formerly associated with Halsey Taylor, Scotsman Ice Systems, has assumed responsibility for replacement of lead-lined coolers previously marketed by Halsey Taylor. If a school or child care facility has one of the Halsey Taylor water coolers noted below, contact Scotsman Ice Systems to learn more about the requirements surrounding its replacement and rebate program. Scotsman Ice Systems 775 Corporate Woods Parkway Vernon Hills, IL 60061 PH: (800) SCOTSMAN or 800-726-8762 PH: (847) 215-4500 Halsey Taylor Water Coolers with Lead-Lined Tanks The following six model numbers have one or more units in the model series with lead-lined tanks: WM8A WT8A GC10ACR GC10A GC5A RWM13A The following models and serial numbers contain lead-lined tanks: WM14A Serial No. 843034 WT21A Serial No. 64309550 WM14A Serial No. 843006 WT21A Serial No. 64309642 WT11A Serial No. 222650 LL14A Serial No. 64346908 ------- |