Outcomes for Canada
In the early stages of the developments in California, CIPH became involved in the NSF lead task force and standards development work. Lead was not a critical challenge in Canada at the time. CIPH determined early involvement was in the best interests of not only its members, but also the Canadian industry. The 70 per cent of products coming from the U.S. are already, or will soon be, compliant.
In the Canadian context, the U.S.-style federal regulatory approach and route was unsustainable. Health Canada has little power to enforce this type of regulation as the water industry and sector have been governed mostly by the provinces. In 2009, CIPH wrote Health Canada indicating ‘blanket’ regulations were not desirable or necessary. Health Canada agreed to adopt low-lead criteria via the model national plumbing and NPC system in the country.
To achieve this strategy of adopting low-lead criteria into the model codes, the Canadian Standards Association (CSA) created a task force to work on adopting similar 0.25 per cent low-lead specifications and to propose requirements and definitions for inclusion into (American Society for Mechanical Engineers) ASME A112.18.1-2012/CSA B125.1-12, Plumbing Supply Fittings,and CSA B125.3, Plumbing Fittings. Manufacturer compliance to lead content requirements can be demonstrated through certification to the referenced standards.
By integrating low-lead requirements into the appropriate technical standards, this approach places the adopted lead content criteria into a system already well understood by manufacturers and regulators responsible for creating, importing, and enforcing of products under these standards.
The provinces and territories currently follow modified versions of NPC, which references the technical standards for plumbing products. CIPH believes all provinces should be directed to adopt any updated codes and fully use their present authority to eliminate the sale and installation of non-compliant products from the country’s marketplace. Comprehensive application of existing enforcement models will remove the need for any new Canadian federal regulation pertaining to lead content in plumbing products.
CIPH encourages the appropriate federal departments, including Industry Canada and Health Canada, to work together with the provinces and territories to ensure timing of such code adoption in the country will coincide with implementation of similar U.S. legislation.
In the meantime, this segment of the market can work closely with their manufacturers to see where low-lead fittings apply and to source them from certified manufacturers.
What’s left to do for Canada?
Currently, actions that must still be accomplished in Canada include:
- integrating the standard into other CSA standards for applicable products;
- referencing the latest versions of CSA standards into NPC; and
- having the provinces adopt the model NPC through building regulations.
CIPH urges Canadian regulators to consider a strategy to align Canadian lead content guidelines and timelines with the January 5, 2014 effective date stated in the U.S. legislation. Uniform requirements and effective dates in both countries will help protect the health and safety of the public by preventing any potential for dumping of non-compliant products. It also provides Canadian manufacturers with a clear strategy for developing products to be compliant for both domestic and export markets.
Conclusion
As the regulations outlined in this article become adopted into the supply chain, Canada’s specifiers, engineers, and other professionals will have to start looking at how they specify and design plumbing systems. Only the potable water systems anticipated or intended for human consumption will be affected. The rest will follow the established requirements.
Notes
1 Visit info.sen.ca.gov/pub/05-06/bill/asm/ab_1951-2000/ab_1953_bill_20060930_chaptered.html. (back to top)
2 DTSC’s Testing and Evaluation of Lead Content in Plumbing Products, Materials and Components and the regulatory Fact Sheet. More information can be found at www.dtsc.ca.gov/PollutionPrevention/LeadInPlumbing.cfm. (back to top)
Kevin Wong, B.Sc., MBA, CAE, is the executive director of the Canadian Water Quality Association (CWQA) and staff member at the Canadian Institute of Plumbing & Heating (CIPH). He is responsible for the execution of the association’s strategic plan, membership growth, and interface with regulatory bodies. Wong can be reached at k.wong@cwqa.com.
