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.

More Information: US EPA LCRR Review and LCRI Fact Sheet

Lead Service Line Inventory Resources

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.

REMINDER: 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.

Small water systems: DDW training videos that provide an overview of the rule requirements and tips for inventory development are available to view. Each video is approximately 10 to 15 minutes long.

ASWDA Resources

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.

On October 16, 2023, ASDWA held a webinar on lessons learned an information gaps for initial lead service line inventories.

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

For additional questions on lead service line inventories, please contact ddw-lslreports@waterboards.ca.gov.

SB 427 Lead Service Line Inventory Requirement

Lead service line inventory and replacement resources are available at the Lead Service Line Replacement Collaborative website.

For more information on Senate Bill No. 427 (SB 427) requirements, please visit the Health and Safety Code 116885 User Service Line Inventory page.

Lead Service Line Replacement Funding Program

Funding is available to community water systems and nonprofit noncommunity systems to complete LSL inventory and replacement. For more information, please visit the Division of Financial Assistance Lead Service Line Replacement Funding Program page or contact DFA-LSLR@waterboards.ca.gov.

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.

Guidance for Developing and Maintaining a Service Line Inventory

In June 2023, US EPA released Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide to support small water systems.

Developing and Maintaining a Service Line Inventory: Small Entity Compliance Guide

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.

Public Education Provision

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.

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

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

Links to Other Lead- Related Information