Now that Lead and Copper Rule revisions are here, your job just got more complicated. With revised mandates and some daunting net new requirements, it can be easy to feel overwhelmed by the changes and not quite know where to start. Don’t worry–many of your peers are feeling the same way. We recently brought together four industry experts to talk about the proposed changes and answer questions from the industry. Now is the time to learn from and lean on the expertise of our peers in the water sector–as a starting point, we’ve consolidated some of the key takeaways below.
Getting your customer data in order is step #1
While first and fifth sampling is a hot topic, getting data in order is the essential prerequisite to testing. Having clear customer data, both on the materials side and the communications side (addresses, phone numbers, etc) will be key as you launch these programs, allowing you to communicate with the right people at the right times throughout the program lifecycle. Once your data house and inventories are prepared, you can reconfigure your tier list to begin sampling. This is going to be a change in sampling methodology and it will stress the supply chain, but first things first – understand and familiarize yourself with how to create an LSLI.
Audit your inventory data now
The EPA is requiring a Lead Service Line Inventory that tracks everything from the water main to beyond the curb. If you only have data on the utility-owned pipes, you’ll have to work to acquire both pieces to fill in the inventory correctly. Take a look at existing records (codes, past practices, etc). Document what went in the ground to the extent that you can to build a basis for your inventory. Take that information and characterize LSLs in one of several buckets – either Lead, Galvanized (may need to be replaced), or non-lead pipe. Modern solutions such as 120Water’s Lead Service Line Probability Finder can help ingest data to fill out all the necessary requirements of your inventory, because trying to document the public AND private side is a daunting task. Your inventory will be the basis of your sampling programs, and you need to start today to understand what data you have and what is needed.
Systems with customer communications infrastructure will be at an advantage
Communicating with customers is a critical part of the revisions. Complying with these new expectations will require a robust infrastructure of customer data and systems to deliver the messages on time. Regardless of your current infrastructure, now is the time to audit and fill the gaps for 2024.
Outside of the rule, this is also a great time to evaluate your communications strategy. If you’re only communicating with customers to convey bad news or ask for a payment, consider adding additional touchpoints in your customer outreach. Build relationships in the communities you serve and map the information you need to convey through the channels that make the most sense. This is a great opportunity to be proactive about communicating with customers, and ultimately the new rule could be a catalyst in the water sector for sweeping changes in how we communicate with customers.
Lead sampling in facilities will require additional support
This net new requirement has sparked many questions from utilities about what will be required–and the bottom line is, utilities will need to lean on various sources for help. First, it’s important to identify exactly which facilities are a part of the requirement: For the first five years, utilities must sample at 20% of elementary schools (K-8) and 20% of all licensed childcare facilities each year. During that time, they will also need to sample schools upon request. After the initial five years, all schools and childcare facilities will be sampled upon request. Utilities will need to collaborate closely with school boards and facilities, and consider third-party partners. Communities, especially those with a large number of schools, can explore solutions like 120Water’s facilities testing platform that rolls up all sampling into one simple dashboard. In addition, it will fall on utilities to educate parents and other stakeholders–just as with residential customers, this is a great opportunity to communicate proactively.
To dive deeper into these takeaways and hear more from the expert panel, watch the webinar replay here. If you’d like to explore a yearly guide to preparing for an executing LCRR, check out our Compliance Pipeline here.
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