15-0619 v2.X PVC Sinking Hose for Rainwater System


We are writing to ask for an exception to use PVC for a sinking hose that will be part of the rainwater harvesting collection system designed for installation on our project. After review from the Massachusetts Department of Environmental Protection, the state agency with purview over public drinking water supply systems, the civil engineer has concluded that the PVC hose is necessary and that there is currently no substitute in the marketplace that will meet performance criteria.According to the technician that is working with us to supply components for the system, “Floating intakes need a hose that is dense enough to easily clear air, that is drinking water safe (NSF certified), that is very flexible and elastic, that won't collapse under suction, and that has a very long life. Over the years we have tested dozens of samples of everything we could find, but we didn't like any of them, regardless of price. We currently sell a PVC hose with stainless-steel spiral reinforcing custom made for us that meets all of our criteria.” This same person indicated that, “There may be non-PVC hoses that could work, maybe some polyurethane or EPDM compounds with a stainless-steel spiral reinforcing (not fabric reinforcing)” but they did not know of any. So our team set out to contact two of the major U.S. based manufacturers of hosing (Kentak and Hudson Extrusions).Technicians from each company replied that while they have LBC compliant products (LLDPE, PP, etc) they didn’t have hoses that would meet the criteria outlined above. Two sticking points seem to be that the polymers that LBC would allow float (PVC tubing apparently is comprised of clay that makes it denser than other tubing), and stiffness of non-PVC hoses are more easily impacted by low temperatures, a concern as our project is in the northeast.In addition to contacting suppliers of polymer tubing, we even contacted another major supplier of drinking water system components (they represent a number of manufacturers), and they admitted that they didn’t have a PVC-free alternate (they thought they did, but when we reviewed the MSDS for their product it turned out to contain PVC). Finally, our engineer notes that a sinking hose with floating intake has been identified by the American Rainwater Catchment System Association (ARCSA, the industry trade group) as the best practice for ensuring that only the highest-quality raw water is used out of the storage tank.Since LBC requires that our projects be able to meet all of our water needs, and in light of the fact that our research indicates that a PVC-free sinking hose does not exist in the market at this time, we are requesting that LBC provide an exception for use of PVC in this application. In return, we would advocate to the manufacturer to redesign their product to remove this Red List material, and we would also advocate to ARCSA to devise an industry-based solution that would eliminate PVC.


It is acceptable to use this product under I11-E1 General Red List. The team has conducted sufficient due diligence by contacting a minimum of three manufacturers and must now advocate to the selected manufacturer for elimination of PVC in their product. Advocacy to ARCSA is encouraged.

Post ID 2998

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