Lead & Copper Rule Revisions

Final LSL Initial Material Inventory Template

The Lead and Copper Rule Revisions (LCRR) require all community and non-transient non-community public water systems (PWS), regardless of size or other water system characteristics, to develop a service line inventory that identifies materials used to construct and repair all service lines connected to the public water distribution system. The initial material inventory must be submitted to the state Department of Public Health Drinking Water Section (DPHDWS) by October 16, 2024.

DPHDWS recently released the final version of the lead service line initial material inventory template which requires PWS to identify not only the lead service lines, but also galvanized service lines, service lines whose material composition is unknown, and service lines of known materials. PWS must identify the gooseneck, pigtail, or connector material if the system service line and/or the customer service line material is lead in compliance with existing regulations. However, DPHDWS strongly recommends PWS identify the connector, gooseneck, or pigtail materials and the internal plumbing materials during the information review process to facilitate compliance with other LCRR requirements.    

Of particular note, the instructions direct water systems to include all service lines, including non-potable applications and lines connected to buildings with service turned off, as follows:

"4. Water systems must include all service lines connected to the system, regardless of the actual or intended use. These include non-potable applications such as fire suppression or emergency use, and service lines connected to vacant or abandoned buildings with service turned off."