Using Standards to Improve Water Quality

2020 Status Update

Using Standards to Improve Drinking Water Components

NSF/ANSI/CAN 61: Drinking Water System Components

EPA’s Office of Research and Development (ORD) participates in the NSF International committees responsible for developing NSF/ANSI/CAN 61. In FY 2020, the Office of Ground Water and Drinking Water (OGWDW) within EPA’s Office of Water undertook rulemaking under the Reduction of Lead in Drinking Water Act (RLDWA). ORD and OGWDW worked closely to ensure that, as much as possible, modifications to NSF/ANSI/CAN 61 could be made to keep it consistent with RLDWA so that use of NSF/ANSI/CAN 61 could fulfil EPA’s needs specified in the final rule “Use of Lead Free Pipes, Fittings, Fixtures, Solder, and Flux for Drinking Water.” The revised NSF/ANSI/CAN 61 contains aspects that fulfill the RLDWA - as well as other aspects that go beyond the RLDWA – without imposing additional testing burden on the plumbing and plumbing products industry. This modification helped increase industry acceptance of the final rule since many plumbing manufacturers have a history of reliance on NSF/ANSI/CAN 61.

EPA has also been working within NSF/ANSI/CAN 61 to get the acceptance criterion for lead release certification under NSF/ANSI/CAN 61 Section 9 lowered, to provide better health protection against lead contamination for products used in schools and day care centers, as well as residences and commercial buildings. This revision to the NSF/ANSI/CAN 61 standard was done through the NSF standard Task Group process. With the 2020 edition of NSF/ANSI/CAN 61 the lower lead acceptance criterion became a voluntary test with new product labeling requirements to help consumers identify the lowest lead-leaching products. There is also a multi-year phase in to make the lower lead acceptance criterion a mandatory component of NSF/ANSI/CAN 61 in the future.

2019 Status Update

Safe Drinking Water Act (SDWA)

Engaged The NELAC (National Environmental Laboratory Accreditation Council) Institute (TNI) on updating and implementing their VCSs that focus on laboratory accreditation and the laboratory proficiency testing (PT)/performance evaluation (PE) programs. This collaboration helps to improve the national consistency of the various state laboratory certification programs, as essential components of an effective state drinking water primacy program.
Coordinated method development priorities with VCS analytical method development organizations (e.g., Standard Methods, ASTM International) and considered the applicability of new methods to support compliance monitoring.
Participated in the development of VCS for illness and injury from microbial, chemical, and physical hazards in building water systems.

Clean Water Act (CWA)

EPA’s Office of Water attends all of the ASTM D19 meetings and the Standard Methods Joint Editorial Board meetings.
EPA’s Office of Water currently participates in multiple ASTM Work Groups to develop ASTM Standards for adsorbable organic fluorine and other PFAS contaminants.
Throughout FY2019, EPA’s Office of Water collaborated with The NELAC (National Environmental Laboratory Accreditation Council) Institute (TNI) on updating and implementing TNI standards that focus on laboratory accreditation as it relates to the Clean Water Act (CWA). This collaboration helps to improve consistency of the various state wastewater laboratory certification programs, as essential components of each state’s National Pollutant Discharge Elimination System (NPDES) permit program.
EPA’s Office of Water completed a collaborative effort with the Standard Methods Committee (which is responsible for developing Standard Methods for the Examination of Water and Wastewater) that began in FY2018 to develop a method for the analysis of peracetic acid (PAA) in wastewater. EPA supported the design of the method and a unique interlaboratory method validation study that brought together multiple analysts in a single location in order to validate the method for an analyte with a very short holding time (e.g., minutes). A proposed version of Standard Method 4500-PAA PERACETIC ACID (RESIDUAL) was published in October of 2019. EPA expects to propose the method for inclusion at 40 CFR 136 in a future rulemaking effort.
EPA’s Office of Water is finalizing a Methods Update Rule (MUR) to allow the use of additional Voluntary Consensus Standards (VCSs) for determinations of microbial and chemical pollutants in wastewater. EPA proposed to revise 40 CFR 136 (October 22, 2019, 84 FR 56590), which lists analytical testing procedures (methods) required to be used by industries and municipalities when analyzing the chemical, physical, and biological properties of wastewater and other environmental samples for reporting under the EPA’s National Pollutant Discharge Elimination System (NPDES) permit program. (https://www.federalregister.gov/documents/2019/10/22/2019-22437/clean-water-act-methods-update-rule-forthe- analysis-of-effluent) EPA worked directly with the Standard Methods Committee and the ASTM D19 Committee to include, enhance, or clarify the quality control requirements associated these methods, where feasible. EPA then requested that these organizations submit to EPA new VCSs and revised versions of older VCSs to be considered for inclusion in a proposed Methods Update Rule (MUR) related to the NPDES permit program. Standard Methods and ASTM International submitted these revised VCSs with changes clearly identified and new VCSs with supporting performance data. EPA reviewed all information to ensure the methods were appropriate for use as alternatives to the existing EPA-approved methods for NPDES compliance monitoring. EPA published the proposed rule on October 22, 2019 and took public comments on the incorporation of these VCSs into the regulations at 40 CFR 136.3. All of these VCSs were favorably received by the public. EPA promulgated these methods into the 40 CFR 136.3 regulations on May 3, 2021. The MUR contained four revised microbiological and 27 revised chemical methods from Standard Methods, and 46 revised chemical methods and minor editorial changes from ASTM.

2018 Status Update

Clean Water Act

Standard Methods: EPA participated in the Standard Methods Joint Editorial Board’s workgroup to validate and publish methods for peracetic acid and hydrogen peroxide. Standard Methods has performed the multi-laboratory validation and drafted the methods. Standard Methods hopes to revise and finalize the methods, and then submit them to EPA to propose in a future Methods Update Rule for 40 CFR Part 136. The current absence of an approved method for these parameters is stifling innovation. Some publicly owned treatment works want to implement the use of peracetic acid as a disinfection technology but are encountering regulatory hurdles since there is no approved National Pollutant Discharge Elimination System (NPDES) method for these parameters. The Standard Methods Joint Editorial Board submitted method revisions and new methods for consideration in the Office of Water’s next Clean Water Act Methods Update Rule for the Analysis of Effluent, which is scheduled to be proposed in the near future. This proposal affects 40 CFR Part 136. Additional methods submitted by Standard Methods provide increased flexibility for the regulated community.

ASTM D19: ASTM D19 Committee submitted method revisions and a new method for consideration in the Office of Water’s next Clean Water Act Methods Update Rule for the Analysis of Effluent, which is scheduled to be proposed in the near future. This proposal affects 40 CFR Part 136. Additional methods submitted by the ASTM D19 Committee provide increased flexibility for the regulated community.