Galvanized Downstream of Lead Assessment

Purpose

Galvanized steel that sat downstream of a lead service spent years building a rust scale that took lead out of the water and held it. That scale does not care that the lead line was replaced in 1998. It goes on releasing, and it releases hardest when something disturbs it, which is why a house with a plastic service and a clean-looking meter can still be putting lead into a kitchen tap. This procedure guarantees the question asked is what was EVER upstream of that galvanized, not what is upstream today, that the inventory category follows from the answer, and that a customer who repipes half the house is told in writing what the other half still is.

Scope

Covers assessing interior galvanized piping in a house, duplex, small retail unit or small restaurant: its inventory category, its condition, the replacement scope, and the interim controls where the work is deferred.

Does not cover identifying the service line material, which the Plumbing service line material verification methods SOP owns, nor replacing the lead service, owned by the lead service line replacement standard. Does not cover the mechanics of a repipe, owned by the repipe of an occupied home phasing SOP. Does not cover any statement about whether the water is safe to drink, and does not cover the water system's own inventory duties beyond reporting what you found.

Roles and responsibilities

Procedure

1. Ask what was ever upstream of this galvanized, not what is upstream today. Acceptance: the current service material per side from the verification record, plus a records answer covering construction year, every plumbing permit on the address, any prior service replacement and its date, and the system's inventory history. What wrong looks like: reading a plastic service at the meter and closing the question there, which is exactly how a galvanized-requiring-replacement house gets recorded as non-lead. Stop rule: where the history cannot be established, the galvanized is recorded as galvanized requiring replacement, because the unknown defaults to the protective category rather than the convenient one. Hazard: none at this step, it is desk work done before the trace.
2. Trace the galvanized run by run and record what each run feeds. Acceptance: a written list or sketch of every galvanized run by size and location, the fixtures each feeds, and the drinking tap explicitly identified. What wrong looks like: a ticket reading "house is galvanized", which cannot scope a repipe or price one. Stop rule: a run that disappears into a finished chase and cannot be traced is recorded as untraced and carried through to the scope as remaining galvanized, never assumed replaced or assumed absent. Hazard: this step puts a body in a crawl space or an attic, so move on joists or planks rather than between them, keep the head clear of nail points, and do not disturb loose-fill insulation of unknown type, because disturbing it puts fibres and dust into the air you are lying in; vermiculite is left alone entirely pending testing rather than moved to see a pipe.
3. Confirm the metal is galvanized rather than black steel or brass, and grade the interior at a real opening. Clean a small spot, run a magnet and a scratch: galvanized is magnetic, scratches dull gray, and is usually threaded. Acceptance: material named per run with both tests recorded, plus an interior view at a removed fitting or an existing cut showing the remaining bore. What wrong looks like: calling every threaded steel pipe galvanized, when black steel on a gas line looks the same from three feet away. Stop rule: bright silver on a non-magnetic pipe is lead, not galvanized, and the lead procedures take over immediately. Hazard: breaking a threaded joint on old galvanized releases rust scale and standing water toward the face, so relieve the section first, open it with the joint below eye level behind sealed eye and face protection and gloves, and wash up before you eat or leave the site. Cutting, threading or breaking galvanized that was ever downstream of lead also releases the lead its scale accumulated, which makes the work an initial-determination trigger under 29 CFR 1926.62 for construction work or 1910.1025 in general industry: wet-cut or collect at the blade, no dry sweeping, no eating, drinking or smoking in the work area, and change out of work clothing rather than wearing it home. Never cut galvanized with an abrasive wheel or torch indoors, since heating or abrading zinc coating produces zinc oxide fume and iron oxide dust, an inhalation route that needs a respirator under a written program per 29 CFR 1910.134, and a reciprocating saw with a bimetal blade avoids the question.
4. Quantify the restriction with a flow test instead of describing it. Read static pressure at a hose bib with nothing running, then open two fixtures at once and re-read the same gauge, and separately measure flow at the kitchen cold tap with the aerator off by timing a known container. Acceptance: static pressure, flowing pressure at the same point, the percentage drop, and a measured gpm at the drinking tap. The shop's standing flag is a fall of more than about 30 percent of static under a two-fixture draw; tune it to your own housing stock. What wrong looks like: judging restriction by how the shower feels. Stop rule: a static pressure above the code ceiling for the building points at a failed or missing pressure reducing valve, which is a different job and gets fixed before any restriction conclusion is drawn. Hazard: removing an aerator releases hot water and spring parts on a mixer, so shut and relieve the fixture and catch the parts over a towel.
5. Assign the inventory category in writing, with the basis beside it. Acceptance: the category recorded as galvanized requiring replacement or as galvanized not requiring replacement, with the record that supports it quoted. What wrong looks like: a category with a blank basis, which the next reader treats as verified. Stop rule: galvanized that was ever downstream of a lead service is galvanized requiring replacement under the federal lead and copper rule as your state's primacy agency has implemented it, and pull the current text from that agency rather than from this card, because the replacement provisions are mid-cycle. Replacing the lead line does not move it out of that category, because the scale is where the accumulated lead sits and the scale is still in the house. Hazard: none at this step, it is a records decision, but a wrong category propagates into a public inventory nobody re-checks.
6. Scope the replacement to everything that was ever downstream, or write the scope as partial and name what stays. Acceptance: a scope that reaches the last fixture on every affected run, or a written partial scope listing each run left in place with its category. What wrong looks like: repiping the accessible basement runs and writing the job up as resolving the problem. Stop rule: a partial interior repipe is never recorded as clearing the category, and the customer gets that in writing before they authorize it, not after. Hazard: none at this step, it is estimating.
7. Where the work is deferred, set the interim controls and a date to come back. Acceptance: a filter certified to NSF/ANSI 53 for lead reduction, in the current version of that standard, which binds the manufacturer's certification and is what the state and the water system will look for, fitted at the drinking tap with its cartridge date written on the housing, the written flushing instruction delivered, and a re-check date on the calendar. What wrong looks like: a deferral that leaves nothing behind but a quote. Stop rule: a customer declining the work is recorded declining it in their own words, and the interim controls go in anyway or the refusal of those is recorded too. Hazard: a cartridge run past its rated capacity can release accumulated lead rather than hold it, so the date goes on the housing in marker.
8. Report the finding and move the record. Acceptance: the category and its basis reported to the water system wherever it differs from their inventory, the run-by-run map attached to the customer file, and the untraced runs listed separately. What wrong looks like: a finding that lives only on a paper ticket in a van. Stop rule: the job is not closed while any run is unlisted. Hazard: none at this step, it is paperwork, but the shop does not say whether the water is safe or estimate exposure; that question routes to the lead, who sends it to the water system, a state-certified laboratory and the local health department.

The record this produces

One assessment record per address, holding: the permit and inventory history with dates; the run-by-run map with the drinking tap marked and every untraced run named; the material tests and the interior view per run; the four flow figures; the assigned category with its basis quoted; the scope marked full or partial; the interim controls and their dates; and the report sent to the water system.

The estimator reads the map to price the repipe without a second visit. The lead reads the untraced list before promising a customer that a scope is complete. The next tech reads the flow numbers to tell a new restriction from the one that was already there.

One worked pass, including a failure

A 1954 single-family house. The service at the meter is plastic. The customer says it has "always been plastic".

Step 1: the permit history shows a 1998 service replacement, and the system's inventory history carries the prior entry as lead. So the interior galvanized sat downstream of lead from 1954 to 1998, 44 years, and the customer's recollection is about the last 27 years rather than the house. Basis recorded as the 1998 permit plus the prior inventory entry.

Step 2 fails. Basement, crawl and first floor trace cleanly: 1/2 in galvanized off a 3/4 in header, feeding kitchen, laundry, main bath and a hose bib. The branch serving the upstairs bathroom leaves the header and enters a finished wall chase with no access, and cannot be traced. Stop rule taken: it is recorded as untraced and carried forward as remaining galvanized rather than assumed replaced during a 1980s bathroom remodel the customer half remembers.

Step 3: magnet holds, scratch reads dull gray, joints threaded, so galvanized confirmed on every accessible run. A union broken at the laundry shows the bore closed to roughly half its original opening by rust nodules.

Step 4: static at the hose bib 62 psi with nothing running. With the kitchen cold and the tub both open the same gauge reads 28 psi, so 62 minus 28 leaves 34 psi of drop, and 34 divided by 62 is 54.8 percent of static, well past the 30 percent flag. Kitchen cold with the aerator off fills a 1 gal jug in 42 seconds, which is 60 divided by 42, or 1.43 gpm.

Step 5: category assigned galvanized requiring replacement, basis the 1998 permit. Step 6: scope written as a full repipe of every traced run, marked PARTIAL overall because the untraced upstairs branch stays, with that branch named in the scope and in the customer's copy. Step 7: the customer defers to spring, so a filter certified to NSF/ANSI 53 for lead reduction goes on the kitchen cold tap with its change date on the housing, the flushing instruction is delivered, and a re-check date is set. Step 8: category, basis and the untraced branch reported to the water system, whose inventory had the address as non-lead on the strength of the plastic service.

References

• The EPA Lead and Copper Rule Revisions and Lead and Copper Rule Improvements, administered through your state's primacy agency, for the galvanized-requiring-replacement category and the ever-downstream test that defines it.
• 29 CFR 1910.134 for the written respiratory program that any respirator use depends on, including work that heats or abrades galvanized coating.
• NSF/ANSI 53 for lead reduction, which is the certification an interim point-of-use filter needs; NSF/ANSI 42 covers aesthetic effects and makes no lead claim.
• See related: the Plumbing service line material verification methods SOP, the lead service line replacement standard, the repipe of an occupied home phasing SOP, and the customer notification and flushing instructions SOP.