WaterMark Update | Plumbing Code of Australia introduces new lead content requirements

Joanne HurstScheme / Program Update, WaterMark

The below information was issued from the Plumbing Code of Australia.

Please note that the Building Code of Australia / Plumbing Code of Australia, is now called National Construction Code (NCC) and we would like to inform you of a significant change which as been introduced as a new requirement, to NCC 2022 volume 3 as follows:

New requirement:

  • A5G4 (2) Any copper alloy product that is intended for use in contact with drinking water must have a weighted average lead content of no more than 0.25% verified in the form of either
  • (a) a test report provided by an Accredited Testing Laboratory, in accordance with NSF/ANSI 372; or
  • (b) a WaterMark licence issued in accordance with (3), if it includes compliance with NSF/ANSI 372.

Key considerations:
Whether it is through a Watermark license or not, this new requirement is far reaching and will have significant consequences for supplier of plumbing products, the plumbing industry and the certification industry.

At a minimum, any plumbing products that have copper alloy in contact with drinking water will need to be tested to demonstrate compliance. In many cases, it can be anticipated that the current design will not satisfy NSF/ANSI 372 and a change of copper allow material will be needed. This, in turn, will likely trigger additional work requirement to maintain/demonstrate compliance.

For instance a currently Watermarked certified tap with a copper alloy body will likely not pass the lead content 0.25% threshold. Changing the material of the body will require a complete re-evaluation of the product against AS/NZS 3718.  In many cases, if not all, trigger new series of tests such as AS/NZS4020, hydraulic strength test, resistance to bending moment and endurance to name a few.

Next steps:
The exact timing and transition requirements are not defined yet and we are aware of work being done to address this gap. Regardless of these arrangements,  the magnitude of the work needed across all the plumbing product categories is such a that it is a very significant change. We believe that testing and certification capacity have the potential to become scarce. In this environment, we are of the opinion that suppliers of plumbing products should consider evaluating and planning their transition as early as possible.

For more information:
Don’t hesitate to contact our office or your Global-Mark Client Manager if you have any concerns or queries about this transition or go visit the ABCB website for more information.