The Village of Bellaire
For Police, Fire or Emergency Dial 911
Ohio Environmental
Protection Agency
Division of Drinking and Ground Waters
Guidelines for Lead Mapping in Division: DDAGW
Systems Number: PWS-04-001
Category: PWS - Guidance
Status: Final
Issued: 01/06/2017
I. PURPOSE
The purpose of this document is to provide guidance on how to map a distribution system to identify areas that
are known to contain or likely to contain lead service lines and identify characteristics of buildings servede by
community water systems that may contain lead piping, solder or fixtures.
II. BACKGROUND
In June 2016, HB 512 was passed to enact section 6109.121 of the Ohio Revised Code (ORC) to establish
requirements governing lead and copper testing for community and nontransient noncommunity public water
systems and to revise law governing lead contamination from plumbing and fixtures. The law requires community
water systems to identify and map areas of their distribution systems that are known or likely to contain lead service
lines. These systems are also required to identify and provide a desscription of the characteristics of buildings served
by the system that may contain lead solder, fixtures or pipes. Single building community and nontransient
non community water systems are required to map areas of the system that have solder, fixtures and pipes
containing lead. Water systems are encouraged to work with their local building authorities when identifying
distribution areas with lead service lines, as described in section IV of this guidance document.
IV. IDENTIFYING DISTRIBUTION AREAS WITH LEAD SERVICE LINES - COMMUNITY PUBLIC WATER SYSTEMS:
Community public water systems (CWS) can use a variety of records to identify areas that are known or are likely
to have lead service lines. Details to help with identification can be found in plumbing codes and other regulatory
changes, historical permit records, and information obtained during maintenance activities, such as meter
replacements, water main breakes and other instances when service lines have been directly observed provide
conclusive information. CWSs are encouraged to utilize customer self-reporting as a way to identify areas with lead
service lines. The different data sources are discussed further below.
Service line ownership may complicate determining where lead service lines are located. Typically, the CWS owns,
and may have records of the service line material from the water main up to the property line. However, the service
line from the property line into the home is typically under the ownership of the property owner. This service line
may or may not be the same service line material as on the water utility-owned side. This should be considered
in situations where the CWS has done main replacement work in an area which would include removing the CWS-
owned portion of the lead service lines. This area should still be considered as having lead service lines since the
property owners' side of the lines in the area could still be made of lead.
1. Local Code and Regulatory Changes. Knowing the dates of changes which may have called specifically for
lead pipe installation or the prohibition of lead pipe may help to targer certain ares. For example, many
cities proactively prohibited the use of lead somewhere in the 1930's to 1950's time range. Local plumbing
permits and municipal codes may also require specific material to be used in service lines. Performing
searches of local records may yield cutoff dates before which a pipe may likely be lead.
2. Historical permit records. Research into building and plumbing permits may yield information as to the
material used in the service line. A survey of many of these permits in a particular area can allow a water
system to classify a particular area as having a high, low or no risk of having lead lines. CWSs may also have
information by reviewing their own main installation records and drawings. Often times the water main
installation records and "as built" drawings will note the service line material used in a particular project.
Some CWSs may have a system of "tap cards" or other type of system, specifically for keeping track of the
service line materials used during the main tapping. These records should also be reviewed to determing
areas with lead service lines.
3. Maintenance and Operation Records. CWS.s have opportunities to directly view the service line materials
during a variety of maintenance activities. Excavations during main breaks, main repairs, valve installations,
etc. that uncover nearby service lines allow crews to view the line and determine materials used. Water
meter replacement projects are another type of activity that can yield information about service line
material on both public and private side of the curb stop. CWSs may have captured service line
information during these activities they can use. Even if CWSs have not captured this information in the
past, they should begin capturing this data in order to improve their system knowledge and to better
position themselves to answer questions about service line material, in assition to updating their maps
every five years as required by this law.
4. Customer Self-Reporting. Through the use of public education efforts, CWSs may be able to encourage
customers to abserve their own water lines coming into their building to determine if they may be made of
lead. Some utilities have developed videos and photographic guides which instruct customers how to do a
"scratch test" to identify a lead line. Although this effort may be prone to errors, it can produce very useful
information as to the material on the customer-owned side of the service line and be able to help identify
areas containing lead service lines.
Various public water systems have made diagrams and videos available for use for identifying lead service
lines at hames and businesses.
Once the available information is reviewed, CWSs should use it to identify areas of distribution which meet the
characteristics of having or likely to have lead lines. CWSs should be conservative in their estimates and assume
that lead could have been used for service line materials unless the age of the area or specific information exists to
rule out lead.
V. IDENTIFYING CHARACTERISTICS OF BUILDINGS WITH LEAD PIPING, SOLDER OR FIXTURES
In 1986, the SDWA was amended to ban the use of lead solders which contain more than 0.2% lead. The lead ban
provisions of the act became effective in Ohio Plumbing Code on March 30, 1998. The SDWA amendments also
require the use of lead-free flux, pipes and fittings in new installations and repairs of public water systems, or any
plumbing within a residential or nonresidential facility which provides water for human consumption. Lead-free
was defined at the time as having no more than 8.0% lead (note this 8.0% was lowered to 0.25% in 2014).
In 1996, the SDWA was further amended to state the following is unlawful:
1. For any person to introduce into commerce any pipe, pipe fitting, plumbing fittimg or plumbing fixture, that
is not lead free, except for a pipe that is used in manufacturing or industrial processing; or
2. Any person engaged in the budiness of selling plumbing supplies; except manufacturers, to sell solder or
flux that is not lead free; or
3. Any person to introduce into commerce any solder or flux that is not lead free unless the solder or flux
bears a prominent label stating that it is illegal to use the solder or flux in the installation or repair of any
plumbing providing water for human consumption.
In 2011, SDWA Section 1417 was amended for the prohibition on use and introduction into commerce of lead pipes,
solder and flux. These new requirements became effective on January 1, 2014. The amendments specifically
modified the applicability of the prohibitions by creating exemptions for certain non-potable applications, changed
definition of "lead-free" by reducing lead content from 8% to a weighted average of not more than 0.25% in the
wetted surface material (primarily affects brass/bronze), eliminated the provision that required certain products to
comply with "voluntary" standards for lead leaching, and established a statutory requirement for calculating lead
content.
The exemptions to the SDWA Section 1417 are pipes, pipe fittings, plumbing fittings or fixtures, including backflow
preventers, which are used exclusively for non-potable services, such as manufacturing, industrial processing,
irrigation, outdoor watering, or any other uses where the water is not anticipated to be used for human
consumption. The exemption also applies to toilets, bidets, urinals, fill valves, flushometer valves, tub fillers, shower
valves, service saddles, or water distribution main gate valves that are 2 inches in diameter or larger. In addition to
the SDWA, the Community Fire Safety Act of 2013 exempted fire hydrants from this requirement.
As a result of these amendments, buildings constructed after 2014 are the leastlikely to have plumbing containing
lead materials, so these consumers are at the lowest risk of exposure to lead from drinking water.
Because it is practically impossible to determine the lead content of an installed fixture, fitting or pipe, it should be
assumed that the manufacture or installation date is the primary indicator of the lead content. Therefore, the
characteristics of buildings and piping solder or fixtures would be buildings in Ohio prior to 1998 or that use
plumbing material or solder manufactured before 1998 may have materials with greater than 8% lead and are at
a higher risk of contributing lead to the drinking water than materials manufactured after 1998. In addition,
buildings built and plumbing materials manufactured after 2014 were required to have less than 0.25% lead by
weight and have the lowest risk for contributing lead to the drinking water. It should be noted however that
although prohibited, some use of leaded solder or leaded components may have occurred after the prohibitions
became effective.
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