Public Workspaces

There are many reasons that the proposed ballot should not be adopted into the current NSF/ANSI 61 standard.

- NSF/ANSI 61 is a performance based test standard, divergent to the proposed Annex G which contains prescriptive and design related requirements.

- The proposed Annex G is formulated based on the California Assembly Bill AB1953, in which a weighted average is used to determine compliance for lead content in a plumbing device and is intended to cover all national lead content requirements. To date California AB1953 is the only lead content law in which a weighted average system is used, therefore Annex G would only be related to California AB1953 and the “Single State” argument is still true.

- Many States (including California) have had prescriptive lead requirements for many years without requiring or relying on a national/international consensus standard to enforce the law. It is unclear why it is necessary now.

- To date, no scientific data has been presented to the committee demonstrating that products meeting the prescriptive 0.25% weighted average for lead, would reduce the amount of lead leached into water from a device and thus be more protective of public health.

- Annex G does not give any sufficient guidance to certifiers as to what would be acceptable to verify the % leaded content in individual plumbing components. This interpretation would have to be decided by each individual certifier resulting in an inconsistent application of this annex.

- The proposed Annex G is written as an optional requirement to the NSF/ANSI 61 standard. I feel that this will lead to confusion in the field.

- The proposed language in clause 3.5 is discriminatory towards lead. Is it ok to internationally add other hazardous material to plumbing products? If this type of language is to be incorporated in the standard then we would have to list all hazardous substances that should not be added intentionally to a product.

- There is a calculation/editorial error in Table G1; the sum of column 5 (contributing % lead) computes to a weighted average lead content of 0.22% not 0.23%

I agree with Richard W. that a national consensus on lead content should be established prior to including them into a national consensus standard.

Please see the attachment for the response to your comments. A reply indicating your intent to either change or maintain your vote is appreciated on or before July 4, 2008. If no response is received, we will assume that you are maintaining your negative.