Lead Free in 2014 By Darnell Wesson

Lead Free: What is it about? Codes and Standards Bradley and Lead Free Bradley and Lead Free Review Questions & Answers Overview

What does lead free mean? –Lead free refers to <0.25% weighted average lead content in relation to wetted surface of pipes, fittings, and fixtures in systems delivering water for human consumption What is a wetted part? –A part in a plumbing fixture that touches water during its operation What is potable and non-potable water? –Potable water is anticipated to be used for human consumption, non-potable water is not anticipated to be used for human consumption Lead Free: What is it about?

State Level Laws –Assembly Bill 1953 –Senate Bill 1334 –Senate Bill 1395 Federal Level Law –Safe Drinking Water Act (SDWA) EPA standards for drinking water quality –Reduction of Lead in Drinking Water Act 2011 Amends SDWA “lead free” definition – 0.20% max lead for solder and flux – 0.25% max lead for products by weighted average Law Harmonization Section 1417 (a)(1) of SDWA states –“no person may use any pipe or plumbing fitting or fixture, any solder, or any flux, in the installation or repair of any public water system or any plumbing in a residential or nonresidential facility providing water for human consumption that is not “lead free” Implementation January 4, 2014

Codes and Standards NSF/ANSI 61, Annex G –Specifically created to address the levels of lead in plumbing products NSF/ANSI 372 –Supersedes NSF61, Annex G –Harmonizes state and federal laws into one standard What are compliant products? –Products that meet the SDWA requirements but are not 3 rd party certified What are certified products? –Products that meet the SDWA requirements and are 3 rd party certified to NSF 372 What are exempt products? –Products not required to meet compliance

Bradley and Lead Free December 2, 2013 implementation date Wetted components in the following products are anticipated to meet NSF372 by 12/2/13: –Washfountains: Multi-Founts, Multi-Stations, Sentry, Terreon Deep Bowls, Classics, and Service Parts –Patient Care: LC, TDWL, HSL1, and Service Parts –Security: COMBI Units, Lavatory, and Service Parts –Lavatory/Faucets: Omni 3000/4000, VERGE, Advocate, CRS, EXD, MG, SS, Frequency, Futura Faucet, Misc. Faucets, and Service Parts

Bradley and Lead Free Exempt Product Definitions –As quoted directly from the law, “(A) Pipes, pipe fittings, plumbing fittings, or fixtures, including backflow preventers that 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 or (B) 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”. Products interpreted by Bradley to be exempt from the law –Shower Product Line and Shower Service Parts –EFX Product Line and EFX Service Parts

Bradley and Lead Free How do I know what is or isn’t lead free? HFA PM70 Screen “Lead” field identifies component status –Y=Compliant Wetted Component –N=Not a Wetted Component –S=Showers Components Exempt –E=EFX Components Exempt –T=Transition Wetted Components Being Converted to Compliant –Blank Field=Component Not Evaluated

Bradley and Lead Free How will lead-free components be identified when shipping out to customers? –There will be an “Pb” identifier on the label that signifies if the product is compliant

Bradley and Lead Free Review Law effective January 4, 2014 Bradley anticipated to be ready by December 2, 2013 Wetted components in each product line compliant/certified by December 2, 2013, with the exception of exempt parts Model and part numbers will not change No price increase planned currently Product not returnable for lead-free