WASDA continues to address lead free brass issues amongst members in the manufacturing and distribution parts of the supply chain. Readers may recall a previous article, "Frequently Asked Questions on the Federal Lead Rule", written by Gary Bryant of Ford Meter Box Company, which provided an overview of what the new law entails. WASDA continues to share information on these topics because, if not properly understood and planned for, WaterWorld readers could face many challenges including increased cost, wasted product and inventory shortages.
Below are responses to questions we posed to members who, as distributors, are preparing for the change, and as manufacturers, are responsible for product compliance. They share key tips and experiences that will better prepare utilities to successfully implement this change with little disruption to their business.
Members who participated in this article include: Richard Campbell, Western Water Works Supply Company, Chino Hills, CA, Distributor; Edward Nugent, Utility Supply Company, Indianapolis, IN, Distributor; Andy Gidney, Everrett J. Prescott, Inc., Gardiner, ME, Distributor; Ken Clark, Mueller Company, Decatur, IL, Manufacturer; Rob McDonald, A.Y. McDonald Manufacturing Company, Dubuque, IA, Manufacturer.
Richard Campbell, Western Water Works Supply Company, shares his experience about compliance with the lead free law:
Engineers, cities, water districts, distributors and contractors need to move quickly and decisively to manage this process; if they do not, there is the potential for significant financial impacts and obsolete material write-offs. In most, if not all cases, manufacturers are not in a position to take material returns on inventory that becomes non-compliant.
Inventories of standard brass materials are significantly larger than most people and agencies realize, due to "hidden inventories." These hidden inventories include: stock in city yards and utility store rooms, distributors' warehouses, contractors' shops and garages, buckets and boxes of miscellaneous valves and fittings on service trucks and in the odds and ends parts piles in yards around the country. Once the cut-off date passes, this entire inventory becomes obsolete and illegal to install. The emergency repair stock, the material that is on the ground waiting to be installed, or the stock in the store room, becomes dead inventory.
Engineers, cities and water districts need to move quickly to update specifications to the new standards. Many utilities have specs that have not been updated in many years and now every spec must be reviewed and updated. Inspectors need to be trained on the new specifications, paying close attention to transition dates and changes to the materials.
Also important to understand is the cost implications associated with this transition. There is a significant increase in the cost of the new material, ranging 30-40% higher on most items. This increase has a significant impact on engineers' estimates, project budgets and on bidding projects. Project bids will require an added level of scrutiny during transition periods depending on the specification for the job. Bids will be submitted that may include standard vs. no-lead brass and the price differentials can be significant. Owners may be challenged on projects and contracts that are awarded based on quoting the wrong material.
There is some good news. There may be, in some cases, alternative applications for the standard brass material for use in non-potable and reclaimed water systems. It does become incumbent on the inspection side to monitor the use of these materials and in making sure that they are not used in or cross-connected to the potable systems.
Field level training is also needed for contractors, utility workers and maintenance staffs regarding the new materials. The no-lead brass possesses different malleability properties than standard brass. It is a more brittle alloy that is more susceptible to cracking and other damage if it is not installed properly. Over tightening can easily lead to leaks and cracked valves or fittings.
What new developments relating to the lead-free law will the industry see in 2012?
Andy Gidney (Everett J. Prescott, Inc., Gardiner, ME, Distributor):
Some of our accounts are already prepared to follow NSF61 and change over by July of this year. One of the states in our region will be changing over in July, with the exemption that you can use your existing leaded inventory, and replace it with lead free.
Ed Nugent
(Utility Supply Company, Indianapolis, IN, Distributor):
I believe there will be very long lead times in getting lead-free product. While California, Vermont, Louisiana and Maryland have already started this process, the rest of the country needs to catch up. This will cause severe shortages and backorders; many distributors and manufacturers will be greatly impacted.
Ken Clark
(Mueller Company, Decatur, IL, Manufacturer):
The reduced lead leach limit means that many 1" and smaller valves and fittings that were previously certified to NSF61 using standard waterworks brass will no longer qualify to Annex F. Therefore, these products will have to be supplied in a low lead version to customers who require Annex F compliance.
Rob McDonald
(A.Y. McDonald Manufacturing Company, Dubuque, IA, Manufacturer):
With the new NSF/ANSI Standard 61 taking effect, July 1, 2012, leaded product, primarily ¾" and 1" sizes, which previously met the certification, will no longer qualify. These products will now need to be produced from a lead free alloy.
How will these developments impact readers of WaterWorld Magazine?
Gidney: We find that most of the utilities are not aware or prepared for the change.
Nugent: Depending on enforcement, the readers will probably experience delays in receiving materials. Having to use up old stock prior to the deadline will also be something new and different for the end-users.
Clark: Inventory levels should be carefully managed to insure a smooth transition to low lead brass. In addition, the cost of low lead service brass product is significantly higher than the same item in standard waterworks brass.
McDonald: A change in the alloy will increase the cost of this product due to the cost difference between leaded and lead free alloys.
What steps should readers start taking to prepare for the change?
Gidney: Use the inventory that is in stock and replace it with lead free. Scrap the "D" items while there is still a scrap value.
Nugent: At some point in the near future, they should begin to evaluate their stock and their purchasing. We have the luxury of time today, but that will quickly be gone and implementing the switch will have to take place. Education and preparation are my suggestions.
Clark: Specifications for service brass products should be reviewed to take into account the July 2012 changes to NSF/ANSI 61 as well as the federal deadline of January 2014. Frequent communication with your distributor or manufacturer's representative about your transition plan will help all involved to minimize any disruptions to the supply chain.
McDonald: Education for all steps in the supply chain is a must. The manufacturer, distributor, and end-user must be cognizant of the standard change and whether their state or local municipality follows the NSF 61 standard. Some may be mandated by law which is important to know.
Are there other pertinent details that should be shared with the industry?
Gidney: Currently I am not aware of any fines that have been levied in Vermont or California however the first one will probably be eye opening.
Nugent: As an organization, WASDA is educating distributors on the upcoming deadline and its implications. This education process also has to reach the end-user at some point soon. My company will be really pushing this information out in the second half of 2012.
Clark: From a manufacturer's perspective, forecasting this industry wide transition is imperative to making sure we have the low lead product available when our customers make the switch. We are also working to minimize the inventory of standard waterworks brass on our shelves for the January 2014 deadline.
McDonald: The NSF 61 standard change is a "rolling" change, meaning that product manufactured and certified to NSF 61 under the former protocol retains its certification. This will not be the case January 2014, when the federal no-lead law takes effect. For this law change, manufacturer, distributor, and end-user current inventories will become obsolete. Therefore, diligence will be required in effectively managing inventories, both new and old, with this federal law change.
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