Advice for plumbing practitioners on the new lead requirements

You will soon notice increasing numbers of plumbing products containing reduced levels of lead in the marketplace. The 2022 edition of the National Construction Code (NCC) will introduce a new limit for the allowable level of lead in plumbing products used for drinking water. This requirement will come into effect on 1 September 2025.

From this date, copper alloy plumbing products containing more than 0.25% lead will no longer be authorised for installation in a plumbing system used to convey drinking water.

During the transition period between 1 September 2022 and 1 September 2025 plumbing practitioners may continue to install existing products as well as those with a reduced level of lead, providing the products are all certified in accordance with the WaterMark Certification Scheme. However, from 1 September 2025 only products that are compliant with the lead requirements of the NCC will be authorised for use.

Currently, a small amount of lead is used in the manufacture of some copper alloy plumbing products. While existing products are safe, health officials recommend that where exposure to lead can be reduced, it should be reduced.

If your customers wish to minimise the potential for lead in their drinking water there are a few recommendations that you could make such as:

• Running the tap water before drinking to flush the pipes and fittings when the water has been stagnant for an extended period of time.
• Using cold water only for drinking, cooking and making baby formula. Remind your customers that boiling does not remove lead from the water.
• Regularly cleaning the aerator in tapware to remove any sediment and debris.
• If a water filter is used, checking that the correct type of cartridge is installed and the filter is replaced when necessary.

Clause A5G4 of NCC 2022 Volume Three (Plumbing Code of Australia) will specify that all copper alloy plumbing products in contact with drinking water must limit the allowable lead content of copper alloy plumbing products in contact with drinking water to a weighted average lead content of not more than 0.25%.

The ABCB agreed to a three-year transition period to allow industry to make the necessary changes to provide products to the market in compliance with this requirement. The three year transition period will commence on 1 September 2022.

The ABCB commissioned Macquarie University in 2018 to undertake a literature review to determine to what extent plumbing products may contribute to lead levels in drinking water in excess of those permitted by the Australian Drinking Water Quality Guidelines.

Macquarie University’s Lead in Plumbing Products and Materials Report (the Report) confirmed that, although Australia’s drinking water is of a high quality and meets the Australian Drinking Water Quality Guidelines, there is potential for lead to leach from copper alloy plumbing products in contact with drinking water.

In response to the Report’s findings, the ABCB released a Regulation Impact Statement (RIS) for public consultation. The RIS analysed whether the allowable lead content in plumbing products should be reduced, and assessed alternatives to address the issue. The Decision RIS was used to assist the ABCB in deciding to reduce the allowable level of lead in certain plumbing products.

All copper alloy products that are in constant contact with drinking water will be required to comply with the lead requirements of the NCC. These include: fittings, valves, backflow prevention devices, taps, mixers, water heaters, water dispensers (boiling and cooling units) and water meters.

The WaterMark Schedule of Products outlines all plumbing products which require WaterMark certification to be authorised for installation in a plumbing or drainage system. The schedule will also be used to outline which products must comply with the lead requirements of the NCC.

During the transition period, products will start to be manufactured with labelling on the product to indicate compliance with the NCC’s lead requirements. This will help you easily identify compliant lead-reduced products.

No, the lead requirement does not apply to all plumbing products. Some products that are not in constant contact with drinking water and have a low likelihood of being used for drinking water consumption are exempt.

These include products such as shower heads; washing machines; dishwashers; commercial boilers (associated with HVAC systems); emergency deluge showers and eyewash equipment.

Copper alloy products used in fire-fighting equipment, irrigation systems and recycled water systems are also exempt from the lead requirement because they are not in contact with drinking water.

Existing copper alloy products in the marketplace that are not compliant with the NCC’s lead requirement can only be used until 1 September 2025. Beyond this date these products may be used in other applications that are exempt, such as systems that are not used to convey drinking water.

The ABCB have worked with industry to develop an Implementation Plan to achieve the lead requirements of the NCC.