The EPA has issued an industry-critical guidance and interpretation, which states
that compliance with the federal Safe Drinking Water Act (SDWA) can be achieved using practical
implementation of home water treatment technologies.
It was written as part of the "Arsenic Guidance," but in the future, the
same principles can be transferred to other contaminants and other POU and POE technologies as well.
The good news concerning this release is that it should remove public water system
and state concerns about meeting the letter of the law when considering POU or POE treatment strategies
by municipalities. Important agency determinations that WQA sees includes:
- "If
the water system and state have developed a rigorous maintenance
program, strong public education, and representative monitoring
regime. POU (and POE) devises can provide public health benefits
required by the SDWA."
- Federal recognition that proper unit operation
can be confirmed with rapid field test (e.g. a conductivity meter
for RO or hardness test kit for a water softener).
- The SDWA regulatory monitoring requirements in
CFR 141.23 can be met with compliance monitoring at a percentage
of homes annually that will be statistically representative of the
full community, or by sampling one-ninth of the units each year.
- Recognition the the requirement for a device to
be in each customer’s home may be satisfied by use of ordinances
and compliance agreements to address the small number of customers
who may be reluctant to allow installation of or access to a household
treatment unit.
This guidance is now out for comment and for presentation
in the USEPA's Office of Ground Water and Drinking Water training on
the arsenic rule.