Raypak Water Heaters/Hot Water Supply Boilers Verified Low Lead
Raypak is pleased to announce effective January 1, 2010, all water heaters and/or hot water supply boilers will be verified by an accredited third party testing agency (CSA) to meet California’s newly enacted low lead requirements pursuant to AB1953. Similar low lead requirements have also been adopted in Vermont. History has shown that other states follow California’s lead, so additional state and federal requirements could be next. The new requirement is a weighted average maximum of 0.25% lead content for all wetted surfaces where the water may be used for human consumption. The California Statute applies to plumbing system components installed after January 1, 2010. In order to minimize future compliance questions regarding water heater/boiler inventories in CA and VT, Raypak water heaters/hot water supply boilers will bear our new low lead verification decal effective 1/1/2010. For additional information, please visit our site.
The above press release will appear in a number of magazines and other national and local media during the first half of 2010. It refers to Raypak's compliance, with independent verification, of all our water heating products to the new Low Lead requirements of California AB1953. The release is a brief factual summary of what is now the law in California and Vermont. History has shown that other states follow California’s lead, so other state and federal requirements could be next.
Background Details/Raypak's Interpretation and Conclusions:
Raypak has reviewed the requirements of CA AB1953 to determine their applicability to Residential and/or Commercial potable water heating systems. A copy of some pertinent pages is available. Click Here: We also consulted with state officials and regulatory agencies (like Department of Public Health and Department of Toxic Substance Control), plus industry groups that are familiar with this new law, to discuss its applicability and implementation.
While the scope of AB1953 has not yet been tested in the courts, the great preponderance of opinions we received was that all potable waterway components which can carry water for human consumption and are downstream from main water supply are covered by this statute. We concluded that this includes the waterways and connected components in water heaters, since heated water often has many uses including cooking , drinking (eg., hot tea or brushing teeth), and even sometimes water used in dishwashing. These therefore can be interpreted to fall within the definition of “human consumption”, and are, by many regulators.
Effective January 1, 2010 in CA, all entities involved in the manufacturing/supplier/installer/buyer chain became responsible for compliance with AB1953. This would include rental building owners. All concerned parties should also be aware that in CA verification by a recognized independent third party certification agency is a requirement to fully satisfy AB1953 requirements for any plumbing system components. The potential financial ramifications of non compliance should be considered as well.
In California the DTSC has been tasked as responsible for enforcement. The timing and focus of this enforcement will depend on many factors. Low Lead regulations are in effect in our home state and Vermont. History also indicates that, over time, California regulatory innovations spread across the nation, and enforcement grows. And in the U. S. Congress, HR 5289, very similar to California’s AB1953 has been introduced. DTSC is authorized to and plans to conduct annual testing of up to 75 samples to determine their compliance with the new CA law, to make the testing results publically available on DTSC’s website and to transmit them to California DPH and coordinate with DPH.
Most importantly, full compliance is the right thing to do now that the technology, while more costly, is widely available. As a responsible and prudent manufacturer it was Raypak's decision to adapt the correct materials, identify and procure internal waterway components with the necessary Low Lead content, and then obtain verification for all our water heating products before January 1. .
What Does This Mean for You?
Raypak has attempted in the above summary to offer you the history and facts behind our own decision to comply with the new CA and VT low lead requirements for all products used to heat potable water. Another reference for background on this subject is the Watts website www.watts.com . Products from Watts are used in Raypak waterways. By complying, we now have confidence that we and our customers won’t suffer the consequences that may result from getting singled out later by enforcement officials, or other investigatory parties. You should learn all you can from this website and other sources to make you comfortable in your own decision.
Please see documents below for details.