State to State
There are various requirements for Drinking Water Treatment Units (DWTUs) and Drinking Water Additives (DWAs) throughout the world depending on country, state and local codes, and requirements vary within the U.S. There are regulations governed by the U.S. Environmental Protection Agency (EPA), individual states and municipalities.
Manufacturers are required to have knowledge of these regulations for the areas in which they sell or install products. This article will cover requirements and submissions for DWTUs for the EPA and four specific U.S. states or health departments.
Registration with the U.S. EPA
The mission of the EPA is to protect human health and the environment. Specifically, the EPA develops and enforces regulations for environmental laws set in place by Congress, and they are authorized to issue sanctions or take other steps to enforce compliance with the environmental protection laws.
The main EPA regulation that affects DWTUs and DWAs is for products that contain active agents with microbial inhibiting characteristics. These agents generate ions of the substances that are used for pesticide purposes.
Silver is commonly used for this purpose, as manufacturers impregnate silver in filters to maintain the integrity of the filter for longer periods of time by inhibiting the growth of microorganisms. In order to sell silver-impregnated filters in the U.S., registration with the EPA must be obtained.
Registration can be obtained through a couple different methods: A manufacturer can submit its own application or use a certification agency that offers this application submittal as a service.
California maintains regulations that provide public safety protection as a valued requirement. The California Department of Public Health (CDPH) takes pride in ensuring that DWTU requirements are met by thoroughly reviewing each device submitted for certification.
The CDPH requires that only products making health claims obtain certification; therefore, products making only aesthetic claims, such as aesthetic chlorine or TDS, do not need to be registered with the CDPH. Currently, in order to submit a product to California for certification, manufacturers are required to provide the following information: a California-specific application that includes details regarding each test report used to qualify the unit for the health claims it is making; any technical justifications used for qualification of units that did not undergo complete testing; copies of all literature, including sales material; wetted parts lists with exploded diagrams; and the current website address, which will need to be compliant with CDPH’s regulations.
It is important to note that there are specific literature requirements for California that go above and beyond those listed in the NSF/ANSI standards. These requirements are detailed on the CDPH website.
Submission of the documents can be completed by the manufacturer itself, or a certification agency that offers this service may submit the information for the manufacturer. If manufacturers submit the application, the review process may take anywhere from two to 12 months; however, if the application is submitted through a certification agency that maintains a third-party approval through California, this process can be turned around more quickly. In this case, the certification agency conducts the review in place of California and the approval from California is typically given within a few weeks of submittal rather than a few months.
The Iowa Department of Public Health (IDPH) has set up the Water Treatment System Registration Program in order to ensure the following: that water treatment systems sold with claims to treat health-related parameters have appropriate third-party verification of the claims; the proper qualifications and capabilities of third-party agencies; and maintenance of a registry for water treatment systems that comply with Iowa law.
Like California, the IDPH requires only products making health claims to obtain registration; therefore, products making only aesthetic claims do not need to be registered with Iowa. Currently, in order to submit to Iowa, manufacturers are required to send in the following: listing with third-party certifier (if available); each test report used to qualify the unit for its health-related claims; the technical justifications used as applicable for qualification of units that did not undergo complete testing; copies of all literature, including sales material; and wetted parts lists with exploded diagrams.
It is important to note that Iowa also has specific literature requirements that go beyond those listed in the NSF/ANSI standards. Document submission can be completed by the manufacturer or a certification agency that offers this service.
The Board of Registration of Plumbers and Gas Fitters regulates these occupations in the Commonwealth of Massachusetts in accordance with the state laws and board regulations. Any products installed after the water meter of a residence are required to register with the state of Massachusetts. Thus, even if aesthetic claims are being made, registration is required when the product is plumbed in. However, the board has recently chosen to eliminate faucet-mount systems from this requirement.
The Massachusetts submission includes an application, third-party certification listing (if applicable), literature and review by the board members. Massachusetts also has specific literature requirements above and beyond those listed in the NSF/ANSI standards.
The board members meet once a month and the applications will be reviewed in order of receipt. The Massachusetts website must be checked in order to determine the date of upcoming board meetings.
If the applications are accepted, then the website will be updated after the board meeting. Document submission can be completed by the manufacturer or a certification agency that offers this service.
Wisconsin maintains a Plumbing Products Register Database, which includes pools, plumbing products and plumbing systems. Any products installed in or on a water supply system serving one- and two-family dwellings; two or less dwelling units in multifamily dwellings; and in-store, consumer self-service bottled water vending machines are required to register with the state of Wisconsin. Regardless of claims, health-related or not, these systems require registration.
The Wisconsin submission is different for third-party certified and noncertified products. If the products are certified to NSF/ANSI standards, then the following is required for submission: application, certifier listing and literature. If the products are not certified, additional items are required such as test protocols, each test report used to qualify the unit, the technical justifications used as applicable for qualification of units that did not undergo complete testing and wetted parts lists with exploded diagrams. Submission of the documents can be completed by the manufacturer or a certification agency that offers this service.
This general overview of DWTU registration requirements represents a small portion of the regulations found within the U.S. and around the world. Other regulations may be set at the local level rather than the state or federal levels. Additionally, the requirements for DWAs are different than those for DWTUs. Sales areas should be researched for requirements before entering the market.
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