Consumer's Frequently Asked Questions about the LCRR Service Line Inventory

This page contains frequently asked questions by consumers about the Lead and Copper Rule Revisions (LCRR) and the LCRR required initial Service Line Inventory, which Public Water Systems were required to submit by October 16, 2024.

In 2021, revisions were made to the Lead and Copper Rule, called the Lead and Copper Rule Revisions (LCRR) which went into effect October 16, 2024. These revisions included a new requirement for Public Water Systems, to create and maintain a Service Line Inventory, make it accessible to the public, and to notify customers with service lines that contain or may contain lead. 

What are the Lead and Copper Rule Revisions?

In 1974, Congress passed the Safe Drinking Water Act. This law requires EPA to determine the level of contaminants in drinking water at which no adverse health effects are likely to occur with an adequate margin of safety. After the Safe Drinking Water Act was passed, EPA built on this act by establishing a treatment technique for lead, as lead contamination of drinking water often results from corrosion of the plumbing materials distributing drinking water to consumers. The treatment technique regulation for lead (referred to as the Lead and Copper Rule) requires water systems to control the corrosivity of drinking water, and therefore reduce lead contamination. EPA issued the Lead and Copper Rule in 1991 and revised the regulation in 2000, 2007 and 2021. 

The 2021 revisions of the Lead and Copper Rule were called the Lead and Copper Rule Revisions (LCRR) and went into effect on October 16, 2024. These revisions include the requirements for Public Water Systems to create an initial service line inventory, along with other actions that are meant to protect the public health and promote transparency between water systems and their consumers.

Since the release of the 2021 revisions, EPA has announced next steps to strengthen the regulatory framework on lead in drinking water by creating the Lead and Copper Rule Improvements (LCRI). The LCRI, announced by the EPA on October 8, 2024, expands on the changes in the LCRR, including prioritizing the replacement of all lead service lines as quickly as is feasible. This rule will be published in the federal register shortly, and will become law 3 years after it is published.

What is the Initial Service Line Inventory?

The initial service line inventory is a compiled list of all service lines in a Public Water Systems (PWSs) service area. A PWS service area is the entire area of piping they use to distribute water to customers. This inventory must include each service line’s location, material, year of installation, and PWS are encouraged to include the size of their service lines (diameter).

This is the first step to identifying all lead service lines in the United States, and removing them. Public Water Systems are required to submit a follow up baseline Service Line Inventory in the future, and will then be required to identify all service lines of unknown materials and replace all service lines containing lead within 10 years of the implementation of the Lead and Copper Rule Improvements (LCRI), an upcoming further revision to the Lead and Copper Rule (LCR).

What is a Service Line?

A service line is a pipe connecting the water main to the interior plumbing of a building. Service lines can be made of a variety of materials, such as plastic, copper, galvanized metals, or lead. Ownership of the service line varies by water system but is frequently split between the water system and the property owner. In cases where ownership is split, ownership of the customer tends to begin at the curb stop; though this is not the case for every system.

• A water main is a pipe that conveys water to a connector or customer's service line. In residential areas, it is usually located underground.
• A curb stop is an exterior valve located at or near the property line that is used to turn on and off water service to the building.

Which Public Water Systems are Required to Create a Service Line Inventory?

Community (COM) and Non-Transient Non-Community (NTNC) Public Water Systems (PWS) are required to submit a service line inventory.

A Community Water System is a PWS that serves at least 15 service connections used by year-round residents or regularly serves at least 25 year-round residents. Community Water Systems can include municipal water systems, Departments of Public Works (DPW), fire districts, or privately owned systems that serve a community.

A Non-transient Non-community Water System or “NTNC” is a PWS that is not a community water system and that has at least 15 service connections or regularly serves at least 25 of the same persons or more approximately four or more hours per day, four or more days per week, more than six months or 180 days per year, such as a workplace providing water to its employees.

What are the Basic Requirements for the Initial Service Line Inventory?  

• PWS must conduct an inventory of all service lines.
• Inventory must include all service lines connected to the public water distribution system regardless of ownership status; meaning, where service line ownership is shared, the inventory must include both the portion of the service line owned by the water system and the customer owned portion.
• Service line materials must be classified as one of the following:
  • Lead
  • Galvanized Requiring Replacement (GRR)
  • Non Lead (for example: Copper)
  • Lead Status Unknown
• PWS must go through all available records to verify their service line materials.

What are the Required Informational Sources that PWS Must Use to Create Their Service Line Inventory?

To identify service line materials, water systems must use information identified through previous materials identification and review the following sources of information:

• Utility records including customer complaint investigations, and all historical service cards;
• Building Permits;
• Plumbing Codes and Plumbing Permits;
• Distribution Maps and Drawings;
• Inspection and Maintenance Records;
• Meter Installation Records;
• Capital Improvement and Master Plans;
• Standard Operating Procedures;
• Operation and Maintenance Manuals;
• Permit Files;
• Existing Water Quality Data;
• Field/visual inspection with or without full excavation;
• MassDEP’s Crowdsourcing “app” for consumer service line material identification;
• Interviews with Senior Personnel, Building Inspectors, and Retirees; and,
• Community Survey.

These sources create the “records review” category of approved MassDEP service line verification methods.

What Methods Can a PWS “Verify” Service Line Materials With?

There currently 6 approved categories of verifications that PWS can conduct:

1. Field Inspection by PWS: This is considered the most accurate verification method that uses a physical and visual inspection by a trained staff person. Typically, the inspection is done at the time of meter replacement, service line replacement, or special inspections such as pot holing and vacuum excavation.
2. Records Review: This verification method includes review of PWS current or past records. Including Tap/tie cards, distribution system main replacement or leak detection or any projects where service line material may have been recorded by PWS.  Other potential sources of information in a community might include plumbing and building permits, or inspectional services records, or year of construction. This is the only required method PWS must use when they create their initial service line inventory, though PWS are encouraged to do further verification with other methods when possible.
3. Statistical Analysis: For this verification method, the system and/or a qualified consultant uses statistical modeling and/or machine learning to predict the presence of lead service lines, or the absence of them if using a statistical model.
4. Customer Self-Identification: This verification method uses information collected from building occupants, and typically in includes photos of the service line.  The MassDEP Crowdsourcing application or a similar software solution can be used to collect the and verify the information.
5. Sequential Monitoring: This verification method can be used if physical inspections, records review, or statistical analysis methods are not feasible. This method employs a process of taking five consecutive 1-liter samples and analyzing the samples for lead to determine if the service line is likely lead.
6. Other MassDEP-Approved Method: Alternative methods. Examples – electrical resistance acoustic wave, eddy current, other technologies that may be developed. DEP can and will review these approaches for validity and accuracy.

Multiple methods of verification may be used for one service line, such as if there is a record available for a privately owned service line segment, and the public service line segment is inspected physically. 

How Can a Lead Service Line Affect Me?

Lead can leach into tap water if the service line that connects your home to the water main in the street is made of lead. Lead primarily enters drinking water through plumbing materials and service lines. Source waters are rarely the cause of elevated lead levels in finished drinking water. Corrosive (e.g., low pH or acidic) water can result in the leaching of lead from service lines and plumbing materials into drinking water. To combat this, Public Water Systems (PWS) are required to sample water from homes and test drinking water for lead; if their sampling results show a higher lead level, or their sampling results are above the federal action level of 15 ppb, the PWS is required to act and replace lead service lines and adjust their water treatment.

The pipes that carry water in the street are usually made of iron or steel, and do not add lead to your water. However, if your residence was built before 1986, there is a chance that your service line may be lead, depending on the age of your home, location, and the ordinances of your Public Water System.

The goal of this service line inventory is to find the location of every lead service line in the United States and remove them.

For more information on how lead gets into drinking water, visit the MassDEP Is There Lead in my Tap Water webpage.

How Do I Know if I Have a Lead Service Line?

The best way to check if your service line is lead, or what material it is, is to contact your Public Water System (PWS)! Your PWS can let you know what the material is, and if it is unknown, you can schedule an appointment with your PWS to check the material of your service line. You may also check your PWS’s website before contacting them, they may have their inventory online and immediately available for review, or instructions on how to view their inventory.

If your water meter is in your home, or if you have a basement for your residence, you may be able to check your service line on your own, from where it enters the building. See the EPA's Protect Your Tap Quick Check For Lead webpage for guidance on how to check your service line. 

How Can I Test my Drinking Water for Lead?

If you are interested in getting your water tested, you should first contact your local Public Water System (PWS) to see if they provide lead testing. Your PWS's contact information should be included in the service line material notice you received or you can locate your PWS contact information in the “PWS, Active Sources, and Contacts Spreadsheet”, which is hosted in the Reporting & Public Notification section of the Water Supplier Operations webpage.

If your PWS does not offer testing, we recommend that you use a laboratory certified by MassDEP to test for lead in drinking water. You can search for a laboratory in the list of laboratories offering drinking water analytical services for private well owners and residential customers, at the top of the How To Find a Certified Laboratory for Water Testing webpage.

For more information on how lead gets into drinking water, visit the MassDEP Is There Lead in my Tap Water webpage. 

How Am I Being Informed of This Inventory and My Service Line Material?

What are the Public Education Requirements for Known or Potential Lead Service Lines?  

Public Water Systems must provide information to all persons served by service lines that contain lead, or may contain lead. These service lines that contain or may contain lead are classified as lead, galvanized requiring replacement, and lead status unknown service lines. This information must be provided in the form of a consumer notice by November 15, 2024. Systems must then continue to notify consumers served by these three types of service lines annually until the service line is identified as a non lead service line or replaced if it does contain lead.

All new customers must be provided with a consumer notice upon the initiation of their water service, if they have a lead, galvanized requiring replacement, or unknown service line. 

A consumer is defined as any building or structure served by a public water system that receives water. This includes businesses, schools, residences, hospitals, and other buildings. 

How Would I Receive a Consumer Notice?

Consumer Notices must be sent by mail or another MassDEP approved method. Notices are required to be sent to both the occupant of a building/structure and the owner of the building/structure, if these are not the same person.

What Information Will This Consumer Notice Include?

Consumer Notices are required to include the following information:

• A statement that your service line material is either lead, galvanized, or unknown,
• an explanation of the health effects of lead, including MassDEP required health language,
• steps you can take to reduce your exposure to lead,
• information on opportunities to replace your service line if it is confirmed lead or galvanized requiring replacement, and
• information on opportunities to verify the material of the service line if it is unknown. 

What Should I Do If I Receive a Notice?

If you were notified that you have a lead or a galvanized requiring replacement service line serving your home, reach out to your water system for details about the replacement process, and to learn how service line replacement costs are accessed. If you are planning to replace your lead service line on your own, contact your water system prior to replacement so that you can coordinate your efforts.

See the section below titled "Lead Service Line Replacements?" For more information.

If you were notified that your service line material is unknown, your water system will continue to investigate its material. Reach out to your water system for instructions on how to verify your service line material or to schedule an appointment for water system staff to visit your home. You can also refer to the  guidance in the additional resources section below for how to self-identify your service line material.

If you were not notified that your service line material is lead, galvanized requiring replacement, or unknown:

You may not have received a notice in the following instances:

• You may be served by a service line made of a non lead material, such as copper, plastic, or another non lead material.
• You may not be served by a Non-Transient Non-Community or Community system, such as if you are served by a private well.

If you did not receive a consumer notice, and would like to confirm this, contact your Public Water System. 

Can I Access my Public Water System's Service Line Inventory?

Yes! A requirement of the Lead and Copper Rule Revisions (LCRR) is that as of October 16, 2024 Public Water Systems (PWS) must make their service line inventory publicly accessible if it contains lead service lines, galvanized requiring replacement (GRR) service lines, and/or unknown service lines. Your PWS may make their service line inventory publicly accessible by using one of the following methods:

• Publishing their service line inventory online. This is required for any PWS that serves over 50,000 people.
• Posting their inventory in their water system office or a similar public location.
• Making their inventory available upon request by (e)mail.
• Making their inventory available upon request for in person review.
• Making their inventory available  by another method that is approved by MassDEP in writing.

A great way to find out how to access a PWS inventory is to:

1. Check your PWS website to see if they have posted their inventory online, or posted online the instructions on how to access it.
2. Starting October 16, 2024, PWS are now required to include instructions on how consumers on Community PWS can access their inventory in the Consumer Confidence Report (CRR). The CCR is an annual report that Community PWS provide to its costumers each year. Non-Transient Non-Community systems are expected to provide their customers with a copy of their CCR when one  is provided to them by MassDEP.
3. Reach out to your PWS directly (by email or phone number) to ask how to access their service line inventory. Your PWS's contact information should be available on your last water bill, or you may look up their contact information on their website.
4. MassDEP has also created an interactive map with Public Water System's Service Line Inventory (SLI) Submissions for public viewing. SLIs are available after they have been received and reviewed by MassDEP.  Public Water System SLI, this Map also contains the contact person for your PWS  for any questions you may have. The Massachusetts Service Line Inventory is available here: Massachusetts Service Line Inventories Hub Site.

For summary statistics of how many Non Lead, Unknown, Galvanized Requiring Replacement (GRR) and Lead service lines, see the Service Line Inventory Summary Sheet.

What is a Galvanized Requiring Replacement Service Line?

A Galvanized Requiring Replacement (GRR) service line is any galvanized service line that is or has ever been downstream of a lead service line, a service line of an unknown material. These lines must be identified in the service line inventory, and replaced, when possible, as they have demonstrated the ability to absorb lead from a lead service line and release it in the future. Replacing these lines can reduce a source of lead to the customers. 

Lead Service Line Replacement?

Contact your Public Water System (PWS)! Your PWS can provide you with a contact who can discuss replacing your lead service line after you have scheduled an appointment with them. Make sure to check their webpage and other available resources, such as your homeowner’s insurance, prior to replacing your service line. Some PWS may be offering a free or discounted service line replacement program, and some homeowner’s insurance may provide reimbursement or funding for service line replacements.

Do I Have to Pay for my Lead Service Line Replacement?

Cost of replacement depends entirely on the town you live in and the PWS you are served by. If you are in the typical situation where the homeowner own’s half of the service line (the service line from the curb stop to the home), you will likely need to pay for the replacement of the service line under your ownership. However, the PWS will need to pay for the replacement of the service line under their ownership. 

If your town/PWS owns the entire service line, you are not required to pay for the replacement, this would be the financial responsibility of the PWS.

If you own the entire service line up to the water meter, as some consumers do after the town/PWS has “gifted” service line ownership to consumers, homeowners would be required to pay for the entire service line replacement.

Consumers should be aware that if they have a lead service line, Massachusetts drinking water regulations do not require consumers to replace their service line. However, MassDEP strongly encourages consumers to replace any lead service lines found. PWS are also required to send annual consumer notifications if you have a lead service line, regardless of your stance on replacement of the service line.