vvEPA FACT SHEET EPA's Final Lead and Copper Rule Improvements Technical Fact Sheet: Public Education Requirements October 2024 This fact sheet contains information on public education and outreach requirements under the final Lead and Copper Rule Improvements (LCRI). This fact sheet also includes related public notification (PN) and Consumer Confidence Report (CCR) requirements. Water systems must begin complying with these requirements starting on the LCRI compliance date, unless otherwise noted. Improved Messaging The LCRI includes clearer and more complete messaging about lead in drinking water, including updated lead health effects language, steps consumers can take to reduce exposure, and strengthened translation requirements for public education. Water systems must provide the updated health effects language in PN and all public education materials. Community water systems (CWSs) must provide updated health effects language in the CCR. Water systems must use the LCRI health effects language starting on the LCRI compliance date. To ensure greater protection of consumers with limited English proficiency, water systems serving a large proportion of consumers with limited English proficiency must develop public education materials that contain: • Information in the appropriate language(s) regarding the importance of the materials, and • Contact information for persons served by the water system to obtain a translated copy of the materials or assistance in the appropriate language, or the materials must be translated into the appropriate language. o ~ Keep In Mind: Water systems must submit a copy of all written public education materials to the State prior to delivery. The State may require the system to obtain approval of the content of written public education materials prior to delivery. Service Line Related Outreach Notification of Service Line Material • The LCRI maintains the 2021 LCRR requirement for water systems to annually inform all persons at a service connection with a lead, galvanized requiring replacement (GRR), or lead status unknown service line of the material of their service line. In addition to notifying persons at the service connection, the LCRI also requires water systems to provide the notice to customers if different than the person served at the connection. • A water system must provide notification no later than 30 days after completion of the baseline inventory and repeat the notification no later than 30 days after the deadline for each annual update to the service line inventory until the entire service connection is no longer a lead, GRR, or lead status unknown service line. For notifications to new customers, water systems must provide the notice at the time of service initiation. EPA 816-F-24-015 ------- • Water systems must include the same notification content for lead and GRR service lines, including instructions for consumers to notify the water system if they think the material categorization is incorrect, among other information. • All notices (lead, GRR, and unknown service lines) are required to include information about accessing the service line replacement plan, steps consumers can take to reduce exposure to lead in drinking water, a statement that the consumer can request to have their tap water sampled, among other information). Notification of Service Line Disturbances • Water systems must deliver notice and educational materials to customers and persons served by the water system at potentially affected service connections during water-related work that could disturb lead, GRR, or unknown service lines, including disturbances due to inventorying efforts. • For disturbances resulting from the replacement of an inline water meter, a water meter setter, or connector, or from the replacement of a water main whereby the service line pipe is physically cut: The water system must provide the persons served by the water system at the service connection with a pitcher filter or point-of-use device certified by an American National Standards Institute (ANSI) accredited certifier to reduce lead, instructions to use the filter, and six months of filter replacement cartridges. Additional Outreach to Encourage Participation in Service Line Replacement • If a CWS does not meet the mandatory service line replacement rate calculated across a cumulative period, the CWS must conduct additional public outreach activities to encourage customers to participate in the service line replacement program. For more information see the mandatory service line replacement rate fact sheet. • Starting after the third program year, the CWS must conduct outreach and distribute public educational materials at least once per year following the year the system does not meet the required cumulative average replacement rate. This must continue annually until the system meets the required cumulative average rate, or there are no more lead, GRR, or unknown service lines in its inventory. • Outreach activities are specified in the rule and include but are not limited to conducting a public meeting, participating in a community event, and contacting customers by phone, text, email, or door hanger. Systemwide Lead Action Level Exceedance (ALE) Under the LCRI, a systemwide lead ALE occurs when the 90th percentile level of a system's lead tap sample results exceeds 0.010 mg/L. Tier 1 PN All water systems must continue to issue Tier 1 PN within 24 hours following a lead ALE as required under the 2021 Lead and Copper Rule Revisions (LCRR) and outlined here. Beginning on the LCRI compliance date, water systems must: • Issue Tier 1 PN when the lead 90th percentile exceeds the new action level of 0.010 mg/L. • Include the updated mandatory lead health effects language from the LCRI. Public Education All systems must provide public education to all customers and persons served by the water system when the lead 90th percentile exceeds the new action level of 0.010 mg/L. The LCRI made additional changes to public education requirements after a lead ALE, including related to content and delivery. EPA 816-F-24-015 ------- • CWSs and NTNCWSs must conduct the public education activities within 60 days of the end of the tap sampling period in which the exceedance occurred. A water system must repeat the public education activities until the system is at or below the action level. • If a State grants an extension for a water system to conduct the public education activities, the deadline must not extend beyond six months after the end of the tap sampling period in which the lead action level exceedance occurred. • The public education materials must be written, meaning they can be printed (i.e., delivered by mail or hand) or electronic (i.e., delivered by email) materials. However, the public education cannot be oral (i.e., delivered by phone call or voice message), unless this is done in addition to one of the other allowed delivery formats. • All water systems, including NTNCWSs, must include information in the public education materials about lead in plumbing components, steps consumers can take to reduce exposure to lead in drinking water, how consumers can get their water tested, among other information. • Systems with lead, GRR, or unknown service lines and lead and unknown connectors must include information about the service line inventory in the public education materials. Systems with lead, GRR, or unknown service lines must include additional information about replacement of lead and, GRR service lines, and identification of unknown service lines. Consumer-Requested Sampling Water systems must offer to sample for lead in the tap water of any person served by the water system who requests it if: • The water system has a lead ALE, or • The consumer is served by a lead, GRR, or lead status unknown service line. At sites served by a lead, GRR, or lead status unknown service line, the samples must capture both water in contact with premise plumbing and water in contact with the service line (e.g., first- and fifth-liter samples). Systems must deliver results of this on-request sampling within three business days after learning of the results. Consumer Notice of Tap Sampling Results Consumer notice of tap sampling results informs consumers of their individual tap sampling results when their home or building's drinking water is tested for lead and copper. • The LCRI requires water systems to provide consumer notice of lead or copper tap sampling results as soon as practicable but no later than three business days of the system learning of the results. • Consumer notification is required in the same time frame regardless of lead or copper levels and includes both tap sampling results from lead and copper tap water monitoring compliance samples as well as consumer-requested tap sampling. • Water systems can deliver the notice either electronically (e.g., email or text message), by phone call or voice message, hand delivery, by mail (postmarked within three business days of the system learning of the results), or by another method approved by the State. Water systems that choose to deliver the notice orally by phone would be required to follow up with a written notice hand delivered or postmarked within 30 days of the water system learning of the results. Outreach to Local and State Health Agencies CWSs must annually provide public education materials and information about Distribution System and Site Assessment Activities (DSSA) to local and State health agencies. EPA 816-F-24-015 ------- • CWSs must provide DSSA information from the previous calendar year, including the location of the tap sample site that exceeded 0.010 mg/L; sample results for initial tap sample, follow-up sample, and water quality parameter monitoring; and any distribution system management actions or corrosion control treatment adjustments made. • CWSs must also provide copies of public education materials for actions conducted in the previous calendar year. • CWSs must send materials by mail, email, or another method approved by the State. Multiple Lead ALEs Water systems with multiple lead ALEs (i.e., at least 3 lead ALEs in a 5-year period) must conduct additional public outreach activities and make filters available. The LCRI requires water systems to take preparatory action after two lead ALEs. Filter Plan Within 60 days after a water system exceeds the lead action level for the second time in a rolling five-year period, the water system must submit a filter plan to the State. The plan must include: • How the system will make pitcher filters or point-of-use devices certified by an ANSI accredited certifier to reduce lead and replacement cartridges available (e.g., operating distribution facilities or delivering filters when requested by the consumer); and • How the system will address any barriers to consumers obtaining filters. The State must review and approve the filter plan within 60 days. Filters and Public Education Within 60 days after the tap sampling period during which a water system exceeds the lead action level for the third time in a rolling five-year period, the water system must make pitcher filters or point-of-use devices, six months of replacement cartridges, and instructions for use available to all consumers. Within six months of the start of the tap sampling period after the most recent lead ALE in which the system meets the criteria for multiple ALEs, a water system must conduct at least one outreach activity. This activity is in addition to the public education required after a single lead ALE. Outreach activities are specified in the rule and include but are not limited to conducting a public meeting and contacting customers by phone, text, email, or door hanger. A water system must conduct an outreach activity every six months and continue to make replacement cartridges available until the system no longer has at least three lead ALEs in a rolling five-year period or if the State allows the system to discontinue these activities sooner given certain conditions. Consumer Confidence Reports Starting with the first CCR distributed after the LCRI compliance date, CWSs must include the following lead- related content: • Updated informational statement about lead. • Updated mandatory lead health effects language. • Informational statement about sampling for lead in schools and child care facilities that directs the public to contact their school or child care facility for further information. • Information about corrosion control efforts. • A statement that a service line inventory (including inventories indicating no lead, GRR, or lead status EPA 816-F-24-015 ------- unknown service lines, known lead connectors or connectors of unknown material) has been prepared and include instructions to access the publicly accessible service line inventory. CWSs with lead, GRR, or unknown service lines must include information on how to obtain a copy of the service line replacement plan or view the plan online. Disclaimer: This document is being provided for informational purposes only to assist members of the public, States, Tribes, and/or public water systems in understanding the Lead and Copper Rule Improvements (LCRI). It includes descriptions of regulatory requirements. In the event that there are any differences, conflicts, or errors between this document and the LCRI, States, Tribes, and/or public water systems should refer to the LCRI. This document does not impose any legally binding requirements on the EPA, States, Tribes, or the regulated community. Further, this document does not confer legal rights or impose legal obligations on any member of the public. In the event of a conflict between the discussion in this fact sheet and any statute or promulgated regulation, the statute and any promulgated regulations are controlling. EPA 816-F-24-015 ------- |