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Annex G is inconsistent with the scope of NSF 61. NSF 61 is a comprehensive, nationally and internationally recognized, technically sound, test-based standard.

In contrast, Annex G has been crafted to afford manufacturers a means of demonstrating compliance with a material content requirement promulgated in legislation of a single state that is narrowly focused on one contaminant to the exclusion of all others, whose basis as appropriately protective of public health has been questioned and whose provisions are still unclear.

Annex G as currently written goes beyond establishing a method of determining compliance with the State of CA legislation; it accepts as normative that state’s 0.25 % lead content requirement, without evidence that this requirement is appropriately protective of public health. Consensus on a national lead content requirement should be reached prior to its inclusion in a nationally recognized standard. Consequently, if Annex G is adopted, we propose all references to 0.25 % as the lead content requirement be deleted. In that way, Annex G would embody a method for determining compliance with a weighted average lead content requirement, without actually setting a lead content requirement.

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