EPA Lead and Copper Rule Revisions LCRR (Ultimate Guide)

Lead is a heavy metal with some of the most serious health risks to humans.

It’s classed as a neurotoxin, and no amount of lead is safe in drinking water. With that said, between 6 and 10 million lead service lines still exist in the US, and we still continue to hear stories of lead poisoning epidemics around the country – with the most recent being the September 2022 discovery of dangerous levels of lead in Chicago’s public drinking water system.

The EPA is thankfully taking the matter of lead in water seriously, and has recently made public the Lead And Copper Rule Revisions (LCRR), which builds on the existing Lead and Copper Rule (LCR) with the goal of eliminating lead from our homes once and for all.

The new regulation is a high priority in the White House, and will hopefully fast-track the plans and processes in place to ensure all US communities have access to lead-free drinking water.

In this guide, we’ve done a deep dive into the EPA LCRR, sharing everything you need to know about this important subject.

Note: If you have specific questions about the LCRR that you want answering quickly and simply, check the FAQ section at the bottom of this article.

🤔 What Is The EPA Lead and Copper Rule Revisions (LCRR)?

The EPA Lead and Copper Rule Revisions (LCRR) is an update to the existing Lead and Copper Rule (LCR), produced by the United States Environmental Protection Agency (EPA) to address issues related to lead and copper contamination in drinking water. It was implemented on December 16, 2021. October 16, 2024 is the first compliance date.

The original Lead and Copper Rule was established in 1991, but had faced criticism for not doing enough to protect public health. The LCRR aims to strengthen regulations surrounding lead and copper in drinking water systems and ultimately reduce exposure to these harmful contaminants.

There are several aims of the LCRR, including introducing more stringent testing requirements, establishing a lower “action level” for lead (which requires corrective actions when exceeded), and improving public transparency through better communication with consumers about lead levels in their drinking water.

The rule also mandates the replacement of lead service lines – a significant source of lead contamination, especially in older communities.

These revisions are a vital step towards ensuring safer drinking water for all communities in the US, and preventing the kind of lead crises that we’ve seen in the past (such as the infamous Flint, Michigan case).

📆 What Are The Key Dates For The LCRR?

Here’s a timeline of dates documenting the implementation of the Lead And Copper Rule Revisions, from 2018 to 2024:

• 2018: The LCRR was included by the White House as a key objective in a federal action plan that aimed to protect children from lead. By this point, the EPA had already been gathering feedback on revisions for over 10 years.
• 2019: The EPA published a draft of the Lead And Copper Rule Revisions, allowing stakeholders to give their input.
• January 2021: The LCRR was officially implemented by the EPA, and the first compliance date – January 2024 – was set. Executive Order 13990 was issued, requiring federal agencies to determine the sufficiency of the existing rules in relation to scientific data, public health, and environmental protection. The outcome of this order was that the EPA needed to review the LCRR and an additional 47 other rules.
• March 2021: The EPA delayed the implementation of the LCRR because of the issuing of Executive Order 13990. The date was pushed back to June of the same year, but the EPA also requested comment on whether the implementation should be moved as far back as December for the sake of seeking public feedback. This same month, the American Jobs Plan was issued, proposing to “eliminate all lead pipes and service lines in our drinking water systems”.
• June 2021: The LCRR’s implementation date was pushed back to December by the EPA, and a new compliance date – October 2024 – was issued.
• April – August 2021: Over these months, the EPA met with stakeholders and held public hearings, requesting comments, with a focus on the communities disproportionately impacted by lead exposure in water.
• November 2021: The Bipartisan Infrastructure Act was signed by President Biden, and $15 billion was delegated for the identification and replacement of lead service lines within a period of 5 years.
• December 2021: The EPA reimplemented the LCRR and maintained its amended compliance date of 16 October 2024. This month, the White House also announced the Biden-Harris Lead Pipe and Paint Action Plan, with the aim of replacing all the lead pipes in the country.

🔎 What Is The Lead And Copper Rule?

Before we look in more detail at the Lead and Copper Rule Revisions, let’s jump back to look at the original Lead and Copper Rule.

The Lead and Copper Rule (LCR) is a federal regulation that was established by the EPA in 1991 to safeguard the quality of municipal drinking water and reduce our exposure to lead and copper in public water systems. The primary goal of this rule was to protect the public, especially vulnerable populations like children, from the concerning health effects associated with lead and copper contamination.

The original LCR required public water systems to monitor lead and copper levels in drinking water through regular testing. If their water supplies contained lead at levels that exceeded the action levels, water systems had to take corrective actions, like implementing corrosion control measures to reduce the leaching of lead and copper from pipes and fixtures.

The rule also required water utilities to notify the public of their test results and provide guidance on how to minimize exposure. Plus, lead service lines were mandated to be replaced over time, and the rule imposed a ban on lead-containing materials in plumbing.

🧐 What Was Wrong With The Original Lead And Copper Rule?

The original LCR has faced criticism over the years for not being sufficiently protective of public health, particularly in light of the Flint, Michigan water crisis.

One of the key issues was that the rule’s action level for lead was too high, allowing public water systems to exceed lead levels considered safe before they legally had to take action. As a result, the extent of lead contamination was underestimated in some areas.

The rule was criticized because it didn’t require the immediate replacement of lead service lines, allowing them to remain in use, which perpetuated the risk of lead leaching into drinking water.

Finally, the LCR also lacked transparency, as it didn’t require authorities and public water systems to sufficiently notify and inform their communities about lead contamination in water systems, so many residents were simply unaware of the potential health risks of this toxic metal.

We’ve seen numerous examples over the years that tell us the original LCR hasn’t been sufficient in protecting communities from lead in water. If the rule was 100% effective, there should have been no concealed or underplayed cases of lead contamination since its implementation. Unfortunately, this simply wasn’t the case.

🚰 Did The Original Lead And Copper Rule Do Anything Right?

Yes, actually – despite its criticisms, a lot of good came out of the original Lead And Copper Rule.

We’ve seen a 90% decrease in the number of large public water systems that exceed the lead “action level”, which is promising news.

And this figure has got better in recent years – only 3% of water systems reported exceeding this “action level” during the last three years.

Plus, the actions implemented as a result of the LCR, combined with other federal regulations, have helped to reduce the concentration of lead in the blood of children aged one to five by 95% since the 1976-1980 date range. Back then, the median concentration of lead in these children’s blood measured at 15 micrograms per deciliter, while in 2013-2014, the median concentration measured at just 0.7 micrograms per deciliter. Of course, we want to see a concentration of 0, but improvements have clearly been made.

We can see from these examples and other data that we’ve come a long way since the EPA Lead And Copper Rule was first implemented. But we still haven’t achieved the goal of eliminating lead from drinking water, and that’s where the Lead And Copper Rule Revisions come into play.

🔑 What Are The Key Revisions To The Lead And Copper Rule?

The key Lead And Copper Rule Revisions are:

• Lead testing at child care facilities and schools. Public water systems are now required to test for lead in schools and childcare facilities.
• Lead service line inventories. PWS must also provide information on their lead service lines for public viewing.
• Trigger level to mitigate lead exposure. If lower levels of lead are detected in municipal water supplies, PWS must now initiate mitigation based on a new “trigger level” of 10 µg/liter (lower than the action level of 15 µg/liter) for the contaminant.

The LCRR also builds on a lot of the measures that existed in the original Lead And Copper Rule, including the replacement of lead service lines, treatment to control corrosion, public education, lead drinking water sampling, and more.

Some of these additional changes to existing measures include:

• Better and more reliable lead sampling. The new regulation provides stricter guidance on the method of collecting samples and has updated the sample collection process.
• “Find and fix” initiative. The LCCR has also implemented a “find and fix” initiative that aims to help public water systems to identify high levels of lead in customer homes.
• Provide improved education. According to the revised rule, PWS must also provide more thorough education to communities to better protect the public.
• Increase the lead service line replacement rate. The rule also aims to increase the annual lead service line replacement rate and increase the program period to 1-2 years minimum.
• Additional lead service line replacement rules. There are a few specific mandates that tie into lead service line replacements, including avoiding delay to replacements and requiring a full replacement if a customer plans to replace their portion of a line.

✅ What Are The Lead And Copper Rule Improvements?

While the Lead And Copper Rule Improvements (LCRI) and the Lead And Copper Rule Revisions (LCRR) might sound like they’re exactly the same, but they’re not – the LCRI are the changes that have been made to the LCRR.

The purpose of these improvements was to acknowledge the Biden-Harris Lead Pipe and Paint Action Plan, which, as we mentioned earlier, was implemented in December 2021 and has big aims to replace all the lead pipes in the country. This new regulation is still being developed by the EPA and has not yet been issued – all we know is that it’ll be released before the initial compliance date of the Lead And Copper Rule Revisions (which are looking like they will likely be delayed due to changes to the regulation’s requirements).

What can we expect to see in the Lead And Copper Rule Improvements? The EPA hasn’t yet released the exact planned contents of this regulation, but it has announced that the LCRI will focus on four key areas:

1. Improving lead sampling practices
2. Replacing all lead service lines
3. Ensuring that resources and funding for lead service line replacements are equitable
4. Providing clarification on the “trigger” and “action” levels for lead in drinking water, and reconsidering whether the “trigger” level is necessary.

The EPA is also in the process of determining whether to reduce the implementation-to-compliance period of three years (as outlined in the Safe Drinking Water Act) for the Lead And Copper Rule Improvements, preventing the unnecessary delay in implementing public health improvements.

How aggressive will the LCRI be?

Again, we don’t know how aggressively the EPA will amend the Lead and Copper Rule Revisions with the LCRI.

One argument is that the changes made to the initial regulation are only minor, since it’s set to be implemented soon. If major changes were to be made, the EPA could take years – even decades – to update the regulation, which is far from ideal given the pressure from the government to replace lead as a service line material in all water systems in the country within a decade.

With that said, the EPA might provide a fast turnaround and make aggressive changes to the regulation – again, because of the pressure to remove all lead service lines and eliminate this source of lead in drinking water as quickly as possible.

📖 Helpful Terms To Be Aware Of

To get a more thorough grasp of the new Lead And Copper Rule Revisions, it’s worth being aware of a few helpful terms.

These are:

Lead Service Lines

Lead service lines are pipes made of lead that were originally widely used to connect homes and buildings to the public water supply. Lead was historically used for this purpose because of its durability and malleability.

We now know that lead poses a significant health risk and can leach into drinking water, which is why Congress amended the Safe Drinking Water Act in 1986, banning the use of lead in new service lines.

Unfortunately, this ban didn’t require existing lead service lines to be replaced, but efforts have since been made to replace lead service pipes with those made from safer materials, like copper or plastic.

In the revised Lead And Copper Rule, “lead service lines” is often shortened to LSR.

Lead Service Line Replacement

Following on from the above, when a public water system or a resident replaces part of, or all of, the lead pipe connecting the water main to their home, it’s referred to as a lead service line replacement.

You’ll see this mentioned in the Lead And Copper Rule Revisions because there are several new requirements or updates to the original regulations that relate to the subject.

There are typically two sides to a lead service line: one side that’s owned by the customer and one that’s owned by the water utility. Customers must pay for the replacement of their side of the lead service line, but the new regulation requires utilities to replace their side of the line when the customer informs them that they plan to make this replacement.

Water systems are working on identifying and replacing lead service lines in their communities, but the sad reality is that many customers can’t afford to replace their side of these lines.

“Lead service line replacement” is often abbreviated to LSLR in the Lead And Copper Rule Revisions.

Corrosion control treatment

Unlike most other trace contaminants in drinking water systems, lead rarely enters the water from the environment. The majority of cases of lead exposure in drinking water are the result of leaching from lead pipes.

While replacing lead service lines is ultimately the best solution to the problem of lead in municipal water, it’s also an expensive one. In the meantime, many public water systems use corrosion control treatment: a method or set of measures employed to prevent or minimize the lead corrosion of metal pipes and plumbing components in a water distribution system. The primary goal of corrosion control is to ensure that the water remains safe to drink, while also protecting the infrastructure from damage.

The exact methods of corrosion control treatment vary depending on the situation, but common methods include adjusting pH, increasing water hardness or alkalinity, or using corrosion inhibitors, like silicates and orthophosphate or sodium polyphosphates.

Corrosion control treatment is usually abbreviated to “CCT” in the Lead And Copper Rule Revisions.

Lead Sampling

Lead sampling was, and remains, a big part of the Lead And Copper Rule. In the revisions made to the rule, there are updated requirements that public water systems must adhere to when taking and documenting lead water samples.

There are now very precise rules for lead sampling, which specify how and where a lead sample should be conducted. The rules also mandate the frequency of sampling, and from whom lead samples should be taken.

A water system must take action if lead is detected in levels higher than the standards set by the EPA. This action may involve implementing corrosion control treatment, replacing a lead service line, or even distributing lead removal water filters for municipal drinking water customers affected by the lead contamination.

Lead Service Line Inventory

A lead service line inventory is a comprehensive record-keeping system that municipalities and water utilities use to track and manage the presence of lead pipes or components in their drinking water distribution systems.

The inventory records the following data:

• The known lead service lines in the community
• The material type for the service lines
• Any galvanized service lines that need to be replaced (if they’re downstream of lead pipes)
• Documentation of “lead status unknown” if the pipe has not yet been properly assessed for lead

The purpose of creating and regularly updating a lead service line inventory is to enable authorities to prioritize the replacement of lead-containing pipes, implement corrosion control measures if necessary, and communicate effectively with residents about their potential risks and necessary precautions they should take.

Lead service line inventories are often referred to as LSL inventories in the Lead And Copper Rule Revisions.

📈 What Are The EPA’s Projections For The Lead And Copper Rule Revisions?

We know the goals and intended outcomes for the revised Lead And Copper Rule – but what does the Environmental Protection Agency project for the future once the new rules have been implemented?

The EPA anticipates that between 213,500 and 350,000 lead service lines will be replaced in the next 35 years simply as a result of increased community awareness and lead service line inventories.

Once all the revisions to the LCR are taken into account, the EPA estimates an even better figure for lead service line replacements: between 339,000 and 555,000.

This should mean that water utilities make significant process compared to the previous lead service line replacements under the original Lead And Copper Rule.

🧾 Are There Any Non-Regulatory Actions That The EPA Is Taking?

Yes, there are a number of non-regulatory actions that the EPA is taking to help fulfill the White House’s clean water plan and address concerns held by stakeholders.

These are:

1. Collaboration with federal agencies and partners to ensure that facilities like child care centers and schools have the support and funding they need to protect their facilities from lead in water. Without this collaboration, the EPA’s authority over these facilities is limited.
2. Raising awareness in communities by providing templates and guidance to water systems, states, and tribes, to increase awareness of the risks of lead exposure. The EPA will also be revising the Consumer Confidence Report Rule so that water systems must make customers aware when corrosion control treatment is being used, and how a utility is mitigating a case of lead presence above the EPA action level.
3. Funding to provide grants for lead reduction efforts, accessed from funding resources including WIIN, WIFIA, DSRF, and the Bipartisan Infrastructure Law. The EPA will put particular focus on providing this funding to disadvantaged communities that may otherwise struggle to implement expensive changes to eliminate lead in drinking water.
4. Assisting disadvantaged communities by providing technical assistance and support to with states and tribes, ensuring that corrosion control treatment is used where necessary and lead sampling is implemented as required.
5. Encouraging complete lead service line replacements, advocating that water utilities fully replace lead service lines rather than only partially. This will include working with vulnerable or disadvantaged communities, connecting them with funding, and providing tools and guidance to support the replacement of lead connectors.
6. Providing support to water systems, including updating the Safe Drinking Water Information System to provide information on case studies, templates, best practices, and guidance on data analytics.

📑 Final Word

There’s a lot to learn about the EPA LCRR, and an overwhelming number of documents to read.

Hopefully, this article has provided you with a good summary of all the information we know so far about this regulation and its elements, including developing service line inventories, identifying service line material, replacing lead pipes, testing for lead in public water systems, and more.

If you’re impatient for the initial compliance date of the LCRR and the implementation of the LCRI, keep an eye on the EPA website, which will be the first to share news and updates when they become available.

Got specific questions about the LCRR? We may have answered them in our FAQ section below.

❔ FAQs

What are the Lead And Copper Rule Revisions?

The Lead And Copper Rule Revisions (LCRR for short) is the revised version of the EPA’s initial regulation for copper and lead in drinking water. There are several reasons why this revision was made: to better protect children and communities from lead exposure (with a particular focus on child care facilities and schools), to provide information to communities on lead in drinking water, and to encourage better testing, corrosion control practices, and lead service line replacement with funding and guidance.

When was the Lead and Copper Rule revised?

The initial LCR was revised over a more-than decade-long period, and the first draft of the LCRR was published in 2019. The initial compliance date is currently set to October 2024, but this date is likely to change due to the planned implementation of the LCRI – amendments to the LCRR.

What are the requirements for LCRR sampling?

The key requirements for testing for lead in drinking water, according to the LCRR, are that water systems must only sample the first liter of tap water after leaving the water in a service line undisturbed for at least 6 hours. These requirements are slightly different for homes with known lead service lines – in this case, water systems must sample the fifth liter of tap water instead.

What are the action levels for lead and copper?

The current action level for lead in drinking water is 0.015 mg/L (15 PPB), while the current action level for copper is 1.3 mg/L (1300 PPB).

What is the holding time for lead and copper?

The current holding time for lead and copper is a minimum of 6 hours. That means water must sit undisturbed in pipes for this time period before opening the faucet and taking a sample.