Lead and Copper Rule for Drinking Water

Background

The State Water Resources Control Board, through the Division of Drinking Water (DDW), enforces the California Lead and Copper Rule (CA LCR), which is aligned with the U.S. Environmental Protection Agency’s (US EPA’s) Lead and Copper Rule (LCR). The CA LCR protects the public’s drinking water from metals that can adversely affect public health by requiring water systems to monitor lead and copper levels at the consumers’ taps. If action levels for lead or copper are exceeded, installation or modifications to corrosion control treatment is required. If the action level for lead is exceeded, public notification is required.

Lead and Copper Rule Revisions (LCRR)

On January 15, 2021, US EPA issued revisions to federal LCR. US EPA’s new Lead and Copper Rule Revisions (LCRR) aim to strengthen the LCR to better protect communities and children in elementary schools and childcare facilities from the impacts of lead exposure. On January 20, 2021, under federal Executive Order 13990, the LCRR was identified as an agency action requiring review. Consequently, US EPA delayed the effective and compliance dates established in the LCRR to December 16, 2021 and October 16, 2024, respectively, while engaging with local communities, states, local governments, utilities, and stakeholders for input on any changes that should be made to the LCRR.

On December 17, 2021, following US EPA engagement activities, US EPA published Docket No. EPA-HQ-OW-2021-0255 in the federal register. Within the Docket, US EPA committed to propose and revise the LCRR by October 2024 with the Lead and Copper Rule Improvements (LCRI). The LCRI is expected to delay the implementation of portions of the LCRR beyond the October 16, 2024 compliance date, however, US EPA maintains the October 16, 2024 compliance date for the lead service line inventories. Water systems are to keep their current tap sampling plans until the LCRR comes into effect on October 16, 2024.

In February 2022, the Association of State Drinking Water Administrators (ASDWA) held an 8-part webinar series on various lead service line inventory topics, such as case studies, funding for inventory, inventory templates, and other tools. Presentation slide decks and recorded webinars can be accessed at the ASDWA Lead Service Line Symposium page.

ASDWA also developed a framework for those starting the development of lead service line inventories while US EPA develops its LCRR inventory guidance.

Additional ASDWA papers, communications, webinars, and resources for the LCRR

US EPA LCRR Review and LCRI Fact Sheet

Lead Service Line Inventory

In September 2022, DDW released an inventory template that contains the minimum amount of information required for water systems to comply with the LCRR’s initial lead service line inventory requirement. Water systems are not required to use the inventory template and may choose an alternative format for their inventory such as a list, custom spreadsheet, database or map.

Each water system must maintain the required inventory information described in the FAQ and inventory instructions below.

All community and non-transient noncommunity water systems must complete and submit their inventory by October 16, 2024. More information regarding inventory submission will be released later.

The Association of State Drinking Water Administrators (ASDWA) is also hosting a webinar series: Implementation Tools and Best Practices for Lead Inventories and Replacements. This webinar series is open to the public and will be held on Thursdays from 10:00 to 11:30 AM PST. Please register for each webinar individually. Recordings for past webinars are available on their website

Session 1 (11/10/2022) – Technologies for Lead Service Line Inventories and Mapping
Session 2 (12/15/2022) – Consultants' Roundtable for Inventories and Mapping
Session 3 (1/12/2023) – Records Review for Inventory Development: https://attendee.gotowebinar.com/register/2106296368304198923
Session 4 (2/9/2023) – Service Line Material Field Validations: https://attendee.gotowebinar.com/register/3188832636059031819
Session 5 (3/9/2023) – Opportunities for Technical Assistance: https://attendee.gotowebinar.com/register/8553150856373547279
Session 6 (4/13/2023) – Regulatory Roundtable: https://attendee.gotowebinar.com/register/8488697484753368078

SB 1398 Lead Service Line Inventory Requirement

Lead service line inventory and replacement resources from the Lead Service Line Replacement Collaborative

For more information on Senate Bill No. 1398 (SB 1398) requirements, please visit the Health and Safety Code 116885 User Service Line Inventory page.

Guidance from US EPA

Lead Service Line Inventories

In August 2022, US EPA released Guidance for Developing and Maintaining a Service Line Inventory to support water systems. The guidance includes best practices and case studies for inventory development: https://www.epa.gov/ground-water-and-drinking-water/revised-lead-and-copper-rule.

US EPA has committed to issuing additional guidance for small water systems and states. More information to come.

Homeowner Tap Sampling Procedures

In February 2016, prompted by events in Flint, Michigan and other US cities, US EPA wrote to states about the need to enhance at all levels of government the implementation and enforcement of drinking water regulations, including the federal LCR. Included were specific recommendations on the need to address lead action level exceedances, to fully implement and enforce the LCR, to enhance public transparency and public access to data and compliance information, and to leverage additional funding sources to address aging infrastructure needs.

In an accompanying memo, US EPA also clarified tap sampling procedures for the Lead and Copper Rule, with specific recommendations for removal and cleaning of aerators, pre-stagnation flushing, and sample bottle configuration. The memo includes a revised version of Suggested Directions for Homeowner Tap Sample Collection Procedures, which is included below.

Memo from US EPA clarifying recommended tap sampling procedures for the Lead and Copper Rule; and the most recent version of the "Suggested Directions for Homeowners Tap Sample Collection Procedures" was last revised in May 2019.

EPA LCR Sampling Guidance Memo in Spanish

Public Education Provision

Guide: Implementing the Lead Public Education Provision of the Lead and Copper Rule for Community Water Systems

Guide: Implementing the Lead Public Education Provision of the Lead and Copper Rule for Non-Transient Non-Community Water Systems

Other Information for Public Water Systems

Outreach and Consumer Confidence Reports

Public water systems are required to provide information to their customers and consumers about the quality of their drinking water. This is commonly provided in water systems’ annual Consumer Confidence Reports. In February 2016, US EPA provided recommendations to enhance the implementation of the Lead and Copper Rule, to better communicate with water system consumers, and to clarify recommended tap sampling procedures (see below).

On March 7, 2016, DDW provided recommendations to California community water systems and non-transient noncommunity water systems about US EPA’s new recommendations to provide additional information to the public related to lead, particularly related to lead pipes or lead-containing fixtures.

Information About Health Risks Associated with Exposure to Lead and Copper

The toxicity of lead has long been of concern, particularly considering that it may be present in many environments, including air, soil, and water. Workplaces and consumer products are other potential sources of lead exposure. Regulations implemented by a number of state and federal agencies limit the amount of lead that can reach people through those various pathways.

Related to drinking water concerns, the Office of Environmental Health Hazard Assessment’s (OEHHA’s) technical support documents for public health goals (PHGs) include health risk evaluations for lead and copper.

OEHHA's Technical Support Document for the Lead PHG

OEHHA's Technical Support Document for the Copper PHG

Health information on lead in drinking water is also available from these federal agencies:

The Centers for Disease Control and Prevention

US Environmental Protection Agency

Questions about health concerns related to blood lead levels should be directed to the California Department of Public Health, Childhood Lead Poisoning Prevention Program.