By October 2024, water systems must develop an inventory of LSLs.  The inventory must identify whether the service line in the public right-of-way and the service line on customer property falls in one of the following categories:
  1. Lead
  2. Galvanized requiring replacement
  3. Lead status unknown
  4. Non-lead

Galvanized requiring replacement is a category that includes galvanized pipe that is, has been, or may have been preceded by an LSL. 
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All water systems must make the inventory publicly accessible and systems serving more than 50,000 people must make the inventory available online. The inventory must be updated over time and the state informed of progress to improve service material accuracy and to track LSL replacements. The primary data sources of information for the inventories include:
  1. Distribution system maps and drawings
  2. Historical records on each service connection  
  3. Meter installation records  
  4. Historical capital improvement or master plans
  5. Standard operating procedures
  6. Inspections and records of the distribution system that indicate the material composition of the service
  7. Construction and plumbing codes, permits, and existing records
  8. Other data sources provided or required by the State

Importantly, the inventory must:
  • Identify service lines that are lead whether the portion that is lead is on public or private property. These are called “lead.” Note: the inventory does not have to include mains that are not connected to the public distribution system.
  • Include service lines where galvanized pipe is or has ever been “downstream” of lead service line pipe. These are “galvanized requiring replacement.”
  • Identify when a service line may be made of lead but available information is incomplete to know for certain. These are “lead status unknown.”

The LSL inventory serves multiple purposes within the rule including:
  • Informing the system and public as to which structures in a community have a service line that warrants replacement because of its potential to contribute lead to water at the tap
  • Providing a means of evaluating progress when active LSL replacement is occurring or required by the rule
  • Supplying information for sample site selection for water system compliance monitoring
  • Determining risk communication and delivery of pitcher filters when LSLs are replaced 
Opportunities to Accelerate Replacement
The inventory is an essential tool to develop plans, set priorities, and communicate to the public. Over the next three years, water systems will be sprinting to develop LSL inventories that meet regulatory requirements.  While LSL inventory is in development, there is an opportunity for communities to build awareness about LSLs, and how to recognize them, and use that awareness to facilitate action.
Questions to ask include:
  • Are the local commissioner of revenue, building inspection, and planning offices prepared to support inventory development?
  • Are community residents aware of how to identify LSLs and communicate that information to the water system?
  • Have local leaders established policies that facilitate LSL identification (e.g., notification at time of property sale or rental)?
  • How does this inventory connect with similar inventories of homes with lead-based paint and other information about lead gathered by health departments, schools, and other organizations?
  • In developing an inventory, has the community considered multiple types of ownership situations, such as homeowner associations that own the water mains, and the opportunity to partner with such groups in advance to improve communications and awareness of service line pipe materials as well as define the water system’s compliance requirements for those groups?
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