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Issue Date: Vol. 54, No. 1, January 2014, Posted On: 12/30/2013

Plumbed Brewers, Coolers And Vending Machines Must Meet New 'Lead-Free' Standard By Jan. 4

by NAMA Government Affairs
TAGS: vending, office coffee service, Reduction of Lead in Drinking Water Act, amended Safe Drinking Water Act, lead in plumbing, coffee brewer, point-of-use water purification system, coffee vending machine, postmix cold drink vender, lead-free definition, National Automatic Merchandising Association, Eric Dell, Sheree Edwards

Congress enacted the Reduction of Lead in Drinking Water Act in January 2011. The law amended the Safe Drinking Water Act by reducing the allowable amount of lead in plumbing used for water that is available for human consumption. It provided a three-year transition period during which industry could make the changes needed to comply with the new requirements. This transition period ends on Jan. 4, 2014.

The Act applies to pipes, fittings and fixtures, solder and flux. Supplies that do not meet the new standard cannot be used to repair existing equipment, and must be discarded.

Any coffee brewer, point-of-use water purification system, coffee vending machine or postmix cold drink vender that is plumbed to a building's water supply must comply with the new standard. The rules also apply to ice machines.

The New Standard:

The new standard is based on substantially lower lead content in water-contact surfaces than was permissible under the older rules The Act changes the earlier requirement of not more than 8% lead content to not more than a weighted average of 0.25% lead, with respect to the wetted surfaces of pipes, plumbing fittings and fixtures in contact with potable water.

Labeling of products and parts that are compliant is not required in the new regulations. Therefore, it is recommended that operators question manufacturers, or look for the NSF/ANSI 372 standard label to determine compliance with the new "lead free" definition.

Application to Equipment and Repairs:

Operators also should understand the application of the revised law to equipment and repair procedures. An important industry issue is whether or not currently installed equipment that does not meet the updated "lead-free" standards has to be replaced. The answer is no.

A pipe, fitting or fixture that was installed in a public water system or a facility providing water for human consumption prior to Jan. 4 does not need to meet the new definition of "lead-free." However, if repairs are made to existing installed equipment, the replacement parts must meet the new lead-free definition. When making repairs, it is very important to return the repaired or refurbished equipment to its exact location to ensure compliance with the Act.


Enforcement will be done by the state, city or municipal level through health and plumbing codes. Failure to comply could result in fines and lawsuits.

In anticipation of these changes, the U.S. Environmental Protection Agency has released a summary of the requirements of the lead ban provisions and some answers to frequently ask questions regarding the law.

Helpful information on this topic may be found at NAMA's online portal:


NAMA Government Affairs: The National Automatic Merchandising Association's government affairs team includes Eric Dell, senior vice-president; Sheree Edwards, regional legislative director; and Sandy Larson, senior director and counsel. The three legislative experts work with government officials to obtain fair and equitable treatment for the vending, office coffee service and foodservice management industry. They also keep NAMA members informed on the legislative issues impacting their businesses.

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