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About the Presentation: Water treatment products and technologies are regulated across a spectrum of federal, state, and local laws. The landscape is complex, ever changing, and unforgiving. From a federal perspective, there is often the misunderstanding that water treatment technologies are regulated primarily under the Safe Drinking Water Act or the Clean Water Act. However, products and technologies that control “pests,” such as bacteria, fungi, algae, protozoa or slime, are also regulated under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) administered by the U.S. Environmental Protection Agency (EPA) Office of Pesticide Programs. This presentation will provide an overview of the FIFRA compliance requirements associated with water treatment products. The presenter will also explain why industry certification to NSF and ANSI standards does not exempt water treatment products from FIFRA obligations.

About the Presenter: Erin Tesch, B.A., M.A., is the Senior Vice President and Managing Director at TSG Consulting, providing support and leadership to the company’s North American operations. Specializing in the registration and ongoing compliance of pesticide products, with an emphasis on antimicrobial products, Tesch assists companies with novel technologies to navigate the complex regulatory approval process. She provides advocacy and strategic positioning within the regulatory agencies to assist clients successfully obtain approvals. Her experience spans across all types of products including disinfectants, sanitizers, materials preservatives as well as biologicals that may be used to control public health pathogens.

Over her 25 year career, Erin has combined her background in environmental public policy with her regulatory knowledge to work with federal officials to address data requirements, prepare registration packages, develop label claims, coordinate product testing, and conduct in-house training and audits. She also serves as an expert witness in legal matters. Tesch has a B.A. in Political Science from George Washington University and an M.A. in Environmental Public Policy from Norwich University.

ASSE International and IAPMO have been working with EPA WaterSense to consider a WaterSense Technical Specification for residential reverse osmosis systems. EPA is considering the use of ASSE 1086, Performance Requirements for Commercial and Food Service Water Treatment Equipment Utilizing Drinking Water, for the Technical Specification requirements. If EPA decides to move forward, they will first issue a notice of intent on this topic, after which they will develop a WaterSense certification program for residential reverse osmosis systems. EPA Watersense has currently been having discussions with industry members, associations, and other EPA partners to determine if residential RO systems would be a good candidate for this program.

For further information, or to share your opinions on this effort, please contact Tom Palkon at tom.palkon@iapmort.org or Dain Hansen at dain.hansen@iapmo.org.

In Australia, water filters connected to the potable water supply system must be WaterMark certified to be legally installed – it's a mandatory requirement of the Plumbing Code of Australia which is legislated by all States and Territories of Australia and administered by the Australian Building Codes Board.

The following summary provides industry stakeholders with information on the two pivotal standards/specifications which water filtration products are certified to in the Australian and New Zealand market, as well as clarification on the material requirements for products that are in contact with drinking water.

AS 3497 is the product standard referenced in the WaterMark Schedule of Products for water filters and water treatment appliances where specific performance claims of contaminant reductions are made (e.g. 99.95% Cyst reduction, 98.9% lead reduction, etc.). These claims must be validated against laboratory testing undertaken to the relevant ANSI/NSF Standards referenced in AS/NZS3497. Currently, ANSI/NSF laboratory test reports undertaken by an ILAC MRA ISO 17025 accredited test lab may be able to be utilized for WaterMark certification.

The 2021 revision of AS 3497 has only recently been published and referenced in the WaterMark Certification Scheme. This allows easy access to the Australia market for manufacturers of drinking water treatment units currently certified to existing NSF/ANSI standards.

Water Treatment Systems (other than those specified in AS/NZS 3497)

WMTS-103 is the product specification referenced in the WaterMark Schedule of Products for water treatment system componentry, other than those specified in AS/NZS 3497, for use on domestic drinking water supply (private or public). It covers filtration system components such as storage tanks, deionizing tanks, strainers, water sanitizers, water treatment units (upstream of appliances for performance verification in accordance with AS/NZS3497 referenced ANSI/NSF Standards), and UV (for non-drinking water purposes, e.g., bathing).

AS/NZS 4020 specifies requirements for the suitability of products for use in contact with drinking water, with regard to their effect on the quality of water. This is a mandatory requirement in the Plumbing Code of Australia, and products in contact with drinking water are automatically evaluated to AS/NZS 4020 during the WaterMark certification process. These products include pipes, fittings, components, and materials used in coating, protection, lining, jointing, sealing and lubrication applications in the water supply and plumbing industry.

The standard requires that products intended for use in contact with drinking water be tested by exposure to test water. Where specified in the product standard a scaling factor may be applied to such tests, compensating for differences between an in-line installation compared with an end-of-line installation. The scaling factor is a variation to the surface area to volume ratio of a product or material to determine a representative test sample. Testing focuses on wetted parts only and is applicable to both metallic and non-metallic components/materials.

Any existing linkages with product certification based on NSF/ANSI/CAN 61 have recently been confirmed to require conformance with AS/NZS 4020 as a primary reference standard in the Plumbing Code of Australia – the exception to this is ion exchange, synthetic resin and RO membranes which require assessment to applicable NSF/ANSI standards.

For more information about WaterMark certification and these standards, contact IAPMO Oceana's Adam Wegmann at adam.w@iapmooceana.org.

Filtered Media is a free newsletter published by IAPMO R&T Water Systems. Its mission is to keep manufacturers of water quality products informed about the latest updates in the industry, including new contaminants, regulatory items, updates to codes and standards, requirements from individual sellers, and other pertinent industry information.