Positive Lead Swab Result During a Customer Service Inspection (CSI)..

You have a positive lead swab while conducting a Customer Service Inspection. What do you do next?

Check the year of construction

If the building was constructed before July 1st, 1988, then the CSI inspection is compliant if there are no other cross connection issues identified.

Note: there are times when a building built prior to 1988 has undergone remodeling. In this case, any fixture, piping, and solder used must adhere to the appropriate guidelines based on the year of the remodel. While it is sometimes difficult to identify fixtures and piping that are a part of a remodeling effort, some plumbers, building officials, and inspectors, can discern the difference.

Confirmation

Lead swabs do not always function as intended for a variety of reasons, including:

• Receiving a bad batch from the manufacturer
• Leaving the swabs in hot environments for some time
• Swabs may be old

For these reasons, it is highly recommended that additional swabs (2-3) be taken, preferably from a different batch. If the swabs still come back positive with the additional swabs, then it is recommended that the inspector report their findings to the administrative authority.

Communication

Different water purveyors have different protocols for communicating results of a CSI inspection to the property owner.

Ineffective communication of the CSI results can cause undue frustration and panic to the building owner.

Byron Hardin, CPM

If the CSI inspector is required to or has the authority to communicate the results to the property owner, he or she needs to explain that a positive lead swab is only an indication of the possibility of lead (and not conclusive proof) and that the administrative authority will be in touch if further action is needed.

Laboratory Testing

For a building constructed after July 1st, 1988, with a positive lead swab, the administrative authority may choose to collect scrapings to be sent to a lab for analysis to determine the exact amount of lead.

This is an optional step that some purveyors have opted to take to ensure that water is only turned off when necessary.

Lab results

If the building is constructed between July 1st, 1988 and January 3rd , 2014, the lead content must be no more than 8% for piping/fittings and less than or equal to 0.2% for solder/flux.

If the building is constructed on or after January 4th, 2014, the lead content must be less than 0.25% for piping/fittings and less than or equal to 0.2% for solder/flux.

HAC TIPS:

• Check for labeling on brass fixtures which sometimes will have different approved certifications that indicate acceptable lead content. ?E.g., NSF 372, NSF/ANSI 61G. Some brass manufacturers use 8% lead content with internal coating that meets the EPA/TCEQ requirements since the 0.25% lead content only applies to wetted surfaces.
• When fixture labeling is not available, a CSI inspector can sometimes find the label information online.

For more information, please visit www.hactexas.com, or call us at 972-823-8800.