19-1025 Lead Levels Regulation in Oceania

QUESTION:
Whilst lead is a naturally occurring metal with a wide variety of uses in manufacturing due to its malleable and corrosion-resistant properties, it is not beneficial or necessary for humans, and can be harmful to health.
In Australia, municipal drinking water supplies are treated and regulated by state and territory health legislation, requiring routine monitoring, including for lead, in accordance with the Australian Drinking Water Guidelines. However, in Australia and across much of the world, lead is still used in the manufacture of a range of plumbing products. Australian Standards prescribe maximum allowable lead content of alloys in contact with drinking water, i.e. allowable lead concentrations for metal and metal alloy components in contact with hot and cold drinking water are limited to a maximum of 4.5%. This is problematic, as products are sometimes marketed as ‘lead-free’ whilst still containing up to 4.5% of lead.

To move towards real “lead-free” products, regulation must change. Without proper enforcement and without public legislation, asking suppliers to change lead content will do nothing to eradicate the proliferation of non-compliant building products within the plumbing sector of Australia. In addition to advocating to suppliers, advocacy to National Standards organizations and other regional authorities having jurisdiction should be progressed, requesting that maximum allowable lead content levels need to be significantly reduced, and the designation of the term “lead-free” should be redefined to align with leading authorities elsewhere in the world, e.g. a maximum 0.25%.

ANSWER:

The Institute recognizes that there are circumstances in which established law specifying thresholds for Red List ingredients exceeding those endorsed by the Institute, combined with a remote location, make it difficult for teams to source compliant products and creates a situation in which the local market is unlikely to be shifted by advocacy to manufacturers alone. The Institute has therefore created the following exception:

I10-E28 Lead Regulation Limitations
In regions where:

  • enacted law provides for a higher lead concentration in products than permitted by US S. 3874 (111th): Reduction of Lead in Drinking Water Act, effective January 1, 2014 (0.25% lead level or lower), and
  • importing compliant products is infeasible for individual projects,

teams may request to use products that instead comply with the laws applicable in their location. Proposed products must also fully disclose the percentage of Red List ingredients present. The project team must submit to ILFI for prior approval, documentation of:

  • allowable lead levels,
  • due diligence demonstrating the infeasibility of importing lower lead products,
  • full disclosure of the percentage of Red List ingredients in the product.


Project teams in the following locations, where barriers to sourcing compliant products have already been demonstrated to the Institute, do not need to receive prior approval for use of products with lead concentrations exceeding the requirements of this Imperative:

  1. Oceania


To use the Lead Regulation Limitations exception, all project teams must advocate:

  • to each selected supplier to reduce lead levels for future products [without increasing other Red List ingredients, such as arsenic].
  • to the Authority Having Jurisdiction to reduce the maximum allowable lead content of metals and alloys in contact with drinking water to levels protective of human health.

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