
Erik C. Helm, Ph.D.
Senior Economist
U.S. Environmental Protection Agency
OW, OGWDW, SRMD,
Targeting and Analysis Branch
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460

Eric:

Thank you for opening dialogue with the American Foundry Society and providing the opportunity to discuss the pending rulemaking relating to the Reduction of Lead in Drinking Water Act. Representing the copper alloy metalcasting industry, AFS appreciates the chance to answer some of your questions regarding the manufacturing of cast copper based components for water applications. 

Below is a copy of your questions with our responses. I have also included under separate cover a brief overview of the metalcasting process, as well as a copy of our previous position paper that was submitted to EPA in 2013. 


   1. EPA:  What are examples of current lead free labeling on products and product packaging?  What percentage of RLDWA lead free products are already labeled on the product and on the packaging?  Are there any current industry norms for this type of labeling?
         * AFS:  Almost all RLDWA lead free cast metal products produced in the US are labeled in some way. Cast metal parts are labeled depending on the size of the part. If the part size can accommodate lettering, it is cast directly on the component as part of the manufacturing process. Typically, most foundries use the "NL" designation. Other foundries cast in the NSF 372 designation to indicate the specification and testing protocol. These have become accepted as industry standard labeling. 
[See:  NSF 61, NSF 372 and Lead Content - NSF International - 
http://www.nsf.org/newsroom_pdf/nsf61-372_lead_insert_LWD-1350-0513.pdf]

   Example of cast in lettering:
                                         
         * Most of the time, smaller RLDWA lead free parts are shipped with packaging that denotes the component complies with the new specification.
         * For example, one foundry cast NL into the most product, but for some lower volume products, there may be a metal attached with the `NL' stamped on it. Alternatively for valves, this foundry uses an adhesive sticker sanctioned by an NSF approval body indicating NSF 372 compliance.
 
   2. EPA:  For typical product categories (e.g. valves, pipe, faucets...) what percentage of the production is labeled when cast, or through etching, on product printing, attaching a Tyvek tag, attaching an adhesive sticker, bagged with printing on the bag, , or packed in preprinted box?
         * AFS:  Our best estimate is that over 90 percent of all cast RLDWA lead free components manufactured for potable water applications and made in the U.S are designated using one of the above noted labels. This is most often done in the manufacturing (casting) process.  

   3. EPA:  At what point or points in the production process are products labeled?
         * AFS:  On cast parts, the pattern or tooling is labeled and this label is then reproduced onto the cast part. For example, on a sand cast meter, a wood, plastic or metal pattern is used. The `NL' is added to the pattern (called tooling) as raised lettering.  When the tooling is pressed into the sand, the lettering in reproduced and becomes an integral part of the cast component. 
                                            
                                            
         * Each component has a distinct tooling and it is common for an individual foundry to have thousands of patterns. Since this marking protocol has already been used for many years, the cost to change the NL designation would be quite significant since every individual piece of tooling would need to be changed, for example the lettering would have to be removed and replaced on each part and each pattern (there are often many individual parts of a single pattern).  

            An example of a pattern that will be used to cast a single component. Many pattern have multiple parts on the plate. As indicated above, raised lettering can be added to the pattern that will be reproduced onto the cast component.  
NOTE: In foundry terminology, the `cope' refers to the top half of the pattern (and the forms the top half of the sand mold) and the `drag' is the bottom.  
An example of a pattern that will be used to cast a single component. Many pattern have multiple parts on the plate. As indicated above, raised lettering can be added to the pattern that will be reproduced onto the cast component.  
NOTE: In foundry terminology, the `cope' refers to the top half of the pattern (and the forms the top half of the sand mold) and the `drag' is the bottom.  
            
            
            
            
            
            
            
            
            An example of a plumbing ball valve pattern. This pattern plate will produce 6 cast components. In this case, each of the 6 master patterns would have to be modified for many changes in alloy designation. Smaller parts may have 30 or more master patterns on the tooling plate. 
An example of a plumbing ball valve pattern. This pattern plate will produce 6 cast components. In this case, each of the 6 master patterns would have to be modified for many changes in alloy designation. Smaller parts may have 30 or more master patterns on the tooling plate. 
            
   4. EPA:  How long does your production line printing and labeling equipment last before it must be replaced?  How often are printer heads replaced?  When this equipment is replaced, is the purchase financed and through what financing mechanism? 
         * AFS:  Not applicable to cast product. 

   5. EPA:  What is the typical time period between product packaging redesign?  Does this vary by type of product?
         * This will vary with the type of product and customer requests. 

   6. EPA:  What are the different types of casting techniques used in the industry and what types of products are being produced by these different types of casting techniques?  For each of the casting methods what process is most commonly used for lettering and marking the casting molds (e.g. electric diode machining)?
         * AFS:  Most water-related parts that run from the water main to the meter in the house (meters, valves, etc.) are manufactured by sand casting. Faucets can also be produced by permanent molding, where molten metal is poured into a metal mold. The larger parts include cast-in lettering, and smaller part would be designated by packaging or etching onto the part. 

   7. EPA:  What type of production line downtime is typically built into production runs to account for necessary equipment maintenance?  Typically, how long do molds last for the different casting techniques before they must be refurbished or replaced?  Are extra molds held in reserve to minimize production line downtime when changing or repairing molds?
         * AFS:  For cast parts, the tooling is designed to handle the wear and tear of the foundry manufacturing process, and has a long life.  The individual patterns are not generally replaced unless there is a substantial design change that requires modifying the pattern, excessive wear creating the need for refurbishing, or the component has been discontinued.  



There are several key issues related to the RLDWA that are of concern to metalcasting facilities:

         * Timing: The copper foundry industry has been in conversation with EPA about this certification for several years and has submitted documents with our concerns and suggestions. A change in labeling at this point would be most difficult and costly.
         * Cost: For cast-in labeling, a change in marking protocol would involve modifying thousands of individual of patterns. 
         * Productivity: There would be also be lost time and productivity related to retrofitting all existing patterns with a common labeling. 
         * Inventory: Furthermore, we have produced thousands of RLDWA castings that have been provided to our customers and suppliers that are already in inventory with the current marking protocol. Oftentimes, our castings sit on the shelves for years before they are utilized.   
         * Training: The current labeling has been accepted as industry standards and previous discussions with governing bodies have indicated that the currently accepted standards would be adequate. AFS members companies have invested considerable time educating their customers over that past few years on the lead free markings and labeling requirements under the RLDWA. A change in labeling protocol at this time would be confusing and require additional training and education. 
         * Import Material: All components designed to water applications that fall under the RLDWA regulations should all be held to the same standard, including imported components manufactured outside the U.S.  
      

Contact Information
      Steve Robison
      Sr. Technical Director
American Foundry Society
1695 N. Penny Lane
Schaumburg, IL 60173
      800-537-4237
SRobison@afsinc.org


