14-0926 v2.X General Red List: Water Meter

Question:

Our team is requesting a general red list exception for water meters. We have been in contact with three major manufacturers and have not found a manufacturer willing or able to disclose enough about the ingredients of their meter that we can be certain of its compliance.Of the three manufacturers, Badger has been most forthcoming, so we would like to select their equipment for use on the project. We will install at least five meters in order to meet the reporting requirements for LBC and for our state-issued rain water purification and gray water treatment systems.We have determined, with Badger's help, that the major bronze castings are lead free. Within the meter itself, there are several engineered polymer components for which we have been unable to determine the chemical ingredients. It is possible that an individual component might contribute more than 10% of the product’s weight, and thus not be considered a small component. It is also possible that these polymers are Red List free.In addition, the sending unit which is required for this meter to communicate with the building’s digital control system is confirmed to contain PVC and phthalates in its wiring harness. This is a separate item number, and thus not strictly speaking a small component of the water meter (though the water meter is incompatible with our building without this device. However, it is a necessary component given the requirement of interoperability with the building controls and the data logging that will feed the dashboard display. We seek permission to consider this a small component of the Badger water meter.Though the disclosure is incomplete, we believe that our email communications with these three manufacturers demonstrates that our due diligence has been completed. We will advocate for the complete disclosure of all ingredients in this product, and we will further advocate for the reformulation of the RTR unit to eliminate the Red List compounds.Our team is requesting a general red list exception for water meters. We have been in contact with three major manufacturers and have not found a manufacturer willing or able to disclose enough about the ingredients of their meter that we can be certain of its compliance.Of the three manufacturers, Badger has been most forthcoming, so we would like to select their equipment for use on the project. We will install at least five meters in order to meet the reporting requirements for LBC and for our state-issued rain water purification and gray water treatment systems.We have determined, with Badger's help, that the major bronze castings are lead free. Within the meter itself, there are several engineered polymer components for which we have been unable to determine the chemical ingredients. It is possible that an individual component might contribute more than 10% of the product’s weight, and thus not be considered a small component. It is also possible that these polymers are Red List free.In addition, the sending unit which is required for this meter to communicate with the building’s digital control system is confirmed to contain PVC and phthalates in its wiring harness. This is a separate item number, and thus not strictly speaking a small component of the water meter (though the water meter is incompatible with our building without this device. However, it is a necessary component given the requirement of interoperability with the building controls and the data logging that will feed the dashboard display. We seek permission to consider this a small component of the Badger water meter.Though the disclosure is incomplete, we believe that our email communications with these three manufacturers demonstrates that our due diligence has been completed. We will advocate for the complete disclosure of all ingredients in this product, and we will further advocate for the reformulation of the RTR unit to eliminate the Red List compounds.

Answer:

The described water meters are allowed under I11-E1 General Red List. Appropriate due diligence and advocacy documentation is required per the May 2013 v2.1 Materials Petal Handbook (MPH p. 11).In addition, the sending unit required for use with the water meter is allowed based on either I11-E20 Small Electrical Components or, if it does not meet RoHS, based on I11-E3 Small Component given that it is a necessary component for the operation of the water meter. Advocacy documentation is required per the I11-E20 requirements in the MPH (p. 11).


Post ID 2055

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