Part A-Methodologies For Testing and Accepting Compositions To Be Included in The Positive List of Compositions For Metallic Materials
Part A-Methodologies For Testing and Accepting Compositions To Be Included in The Positive List of Compositions For Metallic Materials
France, Germany, the Netherlands, the United Kingdom and Denmark work together in the
framework of the 4MSI Common Approach as laid down in the Declaration of Intent (January
2011). This common approach aims for convergence of the respective national approval
schemes for materials and products in contact with drinking water.
The 4MSI have adopted Part A of this document as a common basis for implementing the
concept of accepting metallic compositions. The document is subject to revisions agreed by
the 4MSI.
Part B of this document includes a Positive List of metallic compositions accepted in all of the
Member States of the 4MSI following the procedure described in Part A.
Part C includes the procedure and methods for accepting metallic products or components.
The structure of this document (Part A, B, C) follows the different implementing acts as
described in the new article 11 paragraph 2 (a), (b), (c) of the European Drinking Water
Directive.
Further information may be obtained from any of the competent authorities of the 4MSI.
Bundesministerium für Gesundheit (Deutschland)
Ministère du Travail, de l’Emploi et de la Santé (France)
Ministerie van Infrastructuur en Milieu (Nederland)
Department for Environment, Food and Rural Affairs (United Kingdom)
The Danish Transport, Construction and Housing Authority and Ministry of Environment
(Denmark)
Denmark joined the 4MSI after the development of this common approach, and has therefore
not assessed the content of the approach.
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Principles
Acceptance of metallic compositions
Council Directive 98/83/EC on the Quality of Water Intended for Human Consumption (DWD)
establishes a high level of protection for the consumer and requires Member States to
ensure that substances and materials used in preparation and distribution of drinking water
do not reduce that level of protection. The Directive’s point of compliance is at consumers’
taps. This implies a need for control of all products in contact with drinking water (PDW),
including pipes and fittings within consumers’ premises.
Most of the metals used in metallic PDW are controlled as parameters by the DWD.
Monitoring carried out by Member States provides evidence that metallic pipes and fittings
can increase concentrations of metals in drinking water.
Metal release into drinking water is caused by corrosion. This is a long-term process and
leads to the build-up of corrosion product layers which influence further metal release. Two
different periods of metal release from a PDW can be distinguished. The initial period about
three months (short term behaviour) is mainly influenced by the surface characteristics of the
product (e.g. lead film on the surface), whereas the long-term behaviour is characterized by
the corrosion of the bulk metallic composition. As it is the bulk metallic composition that
defines the long-term behaviour of products, it is possible to accept metallic compositions for
use with drinking water. For the acceptance of metallic compositions other factors affecting
the interaction between metals and water have to be taken into account, such as:
• chemical and physical characteristics of water
• design and construction of the distribution system (e.g. density of use of fittings,
design of products)
• flow regime, as determined by the water consumption habits of consumers
• contact time of the metallic composition with water
The procedure described in this document for accepting metallic materials (compositions)
takes reasonable worst-case situations of the above mentioned factors into account. The
procedure refers to EN 15664-1 as the testing method for metallic materials. The testing
conditions specified in this standard simulate the use of metallic materials in plumbing
systems within buildings.
The interpretation of test results can be very complex in some cases and it is recommended
to get advice from a “Committee of Experts” during the decision making process.
The acceptance will lead to a listing of the accepted compositions on a Positive List
(Composition List).
The acceptance of compositions and their listing in the Positive List requires a clear definition
of the material’s composition and test methods to identify the complete composition.
The Positive List in Part B of this document lists the metallic compositions (materials)
accepted by the 4MSI.
Acceptance of products
The acceptance procedure for metal containing products (see Common Approach on Metallic
Materials - Part C) is based on requirements for:
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• the short-term behaviour (product specific surface properties) and
• the long-term behaviour (composition specific properties)
The long-term behaviour of products is not tested; however, the product’s metallic
composition must be listed on the Positive List.
Test procedures for the surface properties are in development.
The scientific aspects considered in producing this acceptance procedure are given in
Annex A.
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A Reference Material is defined as:
a composition falling within a category for which the characteristics of metal release into
drinking water are known and reproducible, the composition is strictly controlled and the
elements of interest will be at or near the upper limit of acceptability. Possible effects of some
constituents to inhibit the metal release have to be taken into account.
Under each category commercially available metallic compositions accepted for use in
products will be listed. The compositions may only be used for certain products due to the
restrictions with respect to the surface area (Table 1).
Table 1: Product Groups for metallic compositions
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the conditions for safe use must assume the maximum possible percentage. The
acceptance of a composition for the use as pipes includes the acceptance for all uses
(e.g. fittings or components).
This group also includes uncoated metallic pipelines in water supply systems and
water treatment processes.
Product Group B: up to 10% contact surface
Fittings or ancillaries can be produced from one composition or from slightly different
compositions throughout the building’s installation. The most common are made from
copper alloys. Due to their potential to release metals (e.g. lead) to water there is a
need to restrict the total surface contact of products made from these alloys. For
assessments of compositions for these products a contribution of 10% water contact
surface area is assumed.
This group also includes the main metallic parts of pumps and valves used in
buildings installations.
Product Group C: less than 1% contact surface
1) For technical reasons, there might be a need to produce small parts from
compositions not accepted for Product Group B. Other compositions with higher
release rates may be accepted in these parts as long as their use will not
significantly increase the total contamination of drinking water. The use of such
compositions should be restricted to parts (as sum) that do not exceed 1% of the
total surface in contact with drinking water; for example, the body of a water
meter would need to be produced from an accepted composition for Product
Group B but a moving part may be produced from a composition listed for
Product Group C. The sum of the water contact surfaces of all parts in one
product made from Product Group C compositions shall be less than 10% of the
water contact surface of the product.
2) This group also includes the main metallic parts of fittings and ancillaries used
with water mains and in water treatment works. For these products a permanent
flow of the drinking water has to be ensured.
Product Group D: trivial contact surface
Components of fittings and ancillaries in water mains and in water treatment works
(C2). The sum of the water contact surfaces of all parts in one product made from
Product Group D compositions shall be less than 10% of the water contact surface of
the product. For these products a permanent flow of drinking water has to be
ensured.
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Acceptance of a commercial composition in an existing category can be based on one of two
test procedures:
1. A comparative test (see chapter 8) against the reference material according to
EN 15664-1. For comparative testing it is sufficient to use a local drinking water,
provided that the water is suitably corrosive (see EN 15664-2).
2. An absolute test (see chapter 7) with the most critical test water(s) according to
EN 15664-1 and EN 15664-2. The most critical test waters are identified when the
reference compositions are tested and are listed in the European Positive List for
each Category. For one Category more than one critical test water can be required.
The following information shall be provided:
- Test reports according to EN 15664-1
- Test reports for the composition of the test specimens
- For each composition, information on the boundaries for major alloying constituent
elements and maximum values for impurities. Such boundaries will be tighter for
Reference Materials than for commercial alloys
- Existing applicable European standard(s) for the composition
- The composition characteristics
- Products to be manufactured from the composition and their uses (a-factor)
- The production process
- Other information considered appropriate in support of the assessment
3.2 Data required for the assessment of metallic compositions of Product
Groups A, B and C without testing according to EN 15664-1
In some cases, testing of a composition according to EN 15664-1 is not necessary for the
acceptance of the composition. This applies for the following cases:
a) For stainless steel or other passive compositions, the test according to EN 15664-1 is not
suitable to assess the hygienic fitness. This can be demonstrated based on the passive
behaviour of the composition.
b) For ferrous compositions used under permanent water flow the hygienic fitness can be
demonstrated by a scientific dossier. The use of ferrous compositions has to be limited on
certain water compositions (e.g. high oxygen concentration and redox potential) and flow
conditions (no stagnating water, turbulent flow). This has to be addressed in the scientific
dossier.
c) For copper alloys, a certain composition of test specimens may be representative for
different compositions. In this case it is sufficient to test the test specimens according to
EN 15664-1 to accept different compositions. This is only possible if:
1. Due to the composition and metallic structure the compositions exhibit a comparable
corrosion behaviour with respect to the release of metals into the drinking water than
the composition of the test specimens,
2. The compositions belong to the same category,
3. The compositions do not differ by alloying elements (constituents),
4. The composition of the used test specimens meets the requirements of the entire range
of compositions, and
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5. The constituents in the alloy composition have a Reference Concentration (RC) of
greater than or equal to 100 µg/l (i.e; Cu, Al, Fe, Zn, Sn)
Corresponding proof by means of a scientific dossier is required.
Requirements for the scientific dossier:
The scientific dossier must comprehensively address the corrosion chemical behaviour of the
compositions and its interaction to EN 15664-1 must be considered for case c). The dossier
will be used for the approval making process. It is recommended that the dossier is reviewed
by the expert committee.
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4.1 Reference material
The test specimens submitted for testing a new reference material and the test specimens
used as reference materials for the comparative testing have to meet the following
requirements:
Impurities to be analysed in the contact water (see chapter 5) shall be greater than
60% of the declared maximum content
For other non-copper alloys these requirements may be different. This has to be assessed
within the 4MSI.
5. Water analysis
If a new reference material is tested the contact water according to EN 15664-1 has to be
analyzed for all elements exceeding 0.02% in the composition of the declared composition
with the exception of:
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6. Acceptance criteria
Table 2 gives the acceptable contributions from metallic PDW to the overall concentrations of
metals at consumers’ taps. It is based on the acceptance values for chemical and indicator
parametric values in the DWD. The acceptable contributions were derived using the following
principles:
- 90% for elements for which metallic PDW constitute the only major source of
contamination;
- 50% for elements for which other sources of contamination are possible
In the case of other parameters not listed in the DWD, the following criteria have been used:
- Zinc: this element is not toxic at the concentrations encountered in water supply
systems where galvanised steel pipes have been used. However, zinc can give rise to
complaints about the taste and appearance of water. The proposed reference value
has been set to ensure that zinc does not reduce the aesthetic acceptability of water
(WHO, 2004).
- Tin, bismuth, molybdenum, titanium: these reference values are based on provisional
values recommended by a toxicology expert (Fawell, 2003).
- Other metals: advice will be sought from toxicology experts on an appropriate
reference value as necessary
In order to allow time for the development of natural protective layers, the test procedure
simulates a conditioning period of three months, in which a non-compliance with the
reference concentration is tolerated.
Table 2 Acceptable contributions and reference concentrations for acceptance of metallic constituents of metallic
PDW
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Tin 50% 6000 3000
Titanium 50% 15 7.5
Zinc 90% 3000 2700
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(I) MEPa(T) * a ≤ RC for T = 16, 21 and 26 weeks
Criterion B is considered fulfilled, if
(II) MEPa(Tb) ≥ MEPa(T) for {Tb, T} = {12, 16}, {16, 21} and {21, 26} weeks or
(III) a negative slope of a linear fit of the c*EP(T,4h) for T > 12 weeks is obtained or
(IV) c*EP(T,4h) * a ≤ 0.5*RC for T = {16 - 26 weeks}
The test may be extended up to 1 year, if criterion B is not met after 26 weeks.
In this case Criterion A is considered fulfilled, if
(V) MEPa(T) * a ≤ RC for T = 16, 21, 39 and 52 weeks
Criterion B is considered fulfilled, if
(VI) MEPa(Tb) ≥ MEPa(T) for {Tb, T} = {26, 39} and {39, 52} weeks or
(VII) a negative slope of a linear fit of the c*EP(T,4h) for T > 26 weeks is obtained or
(VIII) c*EP(T,4h) * a ≤ 0,5*RC for T = {26 - 52] weeks
The application of the acceptance criteria has to be based on expert judgement (see 1.1 for
the use of a Committee of Experts). Deviations of results to the criteria in formula (I) to (VIII)
might be justified.
In some cases, compliance to the formula (I) – (VIII) can be difficult to establish clearly
because of deviations (outliers) due to uncertainty of the determination and/ or minor
variations in the test water composition. In such cases, the complete set of available data
has to be considered. For the test rig according to EN 15664-1 these are:
• Results of individual test lines,
• 4h stagnation results,
• parameters of water composition,
• temperature of the test rig
• stagnation samples that were in addition to the requirements in EN 15664-1
An expert judgement is also required to decide, whether the data available is of sufficient
quality (e.g. no major difference of the three test lines, interpretation of outliers) for an
assessment to be carried out.
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- Results from comparative testing using the pipe rig test EN 15664-1 relative to the
Category’s Reference Material
Note: The assessment of the results by comparative testing proved to be difficult due to the
uncertainties of measurements. Instead of the assessment by comparative testing further
compositions can be accepted in an existing Category when the composition is tested with
the most critical test water according to EN 15664-1 and EN 15664-2 and the test results
comply with the requirements for absolute testing (7.2).
See Figure B for a schematic of the procedure.
The application of the acceptance criteria has to be based on expert judgement (see 1.1 for
the use of a Committee of Experts). Deviations of results to the criteria in formula (I) to (VIII)
might be justified.
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In some cases, compliance to the formula (I) – (VIII) can be difficult to establish clearly
because of deviations (outliers) due to uncertainty of the determination and/ or minor
variations in the test water composition. In such cases, the complete set of available data
has to be considered. For the test rig according to EN 15664-1 these are:
with:
Epit: pitting potential according to EN 16056
Free corrosion potential: potential at the beginning of the test (open circuit potential),
which corresponds the potential of oxygen in the neutral test water
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Figure A: Procedure for accepting reference materials for a Category and approval testing of compositions not
falling under a listed Category
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FIgure B: Procedure for the addition of a commercial composition to the list of accepted composition
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The residence time for water in a domestic distribution system depends on:
- the capacity of the system;
- the consumer’s water consumption habits, including activities such as toilet flushing and
use of washing machines.
There are variations in residence time even when consumption is averaged over a certain
period (e.g. a week). For most consumers the average residence time prior to consumption
will show a distribution of between 15 minutes, in the most favourable situations, and several
hours, in realistic worst-case situations.
It is proposed that an assumption of a residence time prior to consumption of four hours will
be used as a basis for sampling in acceptance testing. The assumption of an average
residence time of four hours includes the possibility of a few situations with residence times
prior to consumption of 12 hours. This approach will provide an adequate level of protection,
given that an authoritative study has demonstrated that the concentration of metals after a
half-hour stagnation provides a reasonable estimate for a weekly average (EUR 19087,
1999).
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A.6 Contribution of metallic PDW to overall metals concentrations
Metals in drinking water are derived from a variety of sources. It is therefore necessary to
take account of the contribution that other sources, apart from metallic PDW, make to the
overall concentrations of metals at consumers’ taps by setting a percentage contribution level
for each metal.
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Method
Before stagnation, the installation should be flushed thoroughly. It is possible to monitor
displacement of standing water by checking its temperature; when mains water has
displaced standing water, its temperature vs. volume flushed will become constant.
Alternatively the approximate volume need to displace standing water can be calculated after
surveying the premises.
After the 4 hour stagnation period, the first 250 ml of the stagnation water should be run to
waste (Alternatively it can be used to assess copper, nickel or lead concentrations arising
from the tap). The next 1000 ml of water should be collected in a plastic container and
stabilised using acid and reserved for copper analysis. It is recommended that as well as
copper analysis, other parameters are measured (after flushing) that characterise the water
composition and its corrosive tendency (e.g. pH and temperature on site, TOC, alkalinity,
hardness, conductivity, copper in running water). For the second and third samples from
each premise, it is acceptable to measure only the copper concentration in the 1000 ml
sample and a limited selection of parameters to confirm that the composition of the water is
unchanged.
Interpretation of results
The exposure level in each of the premises should be calculated from the average of the
results of copper in the three 1000 ml samples. Where premises show results of less than
100 µg/l copper in the stagnation samples, it should be assumed that copper plumbing is not
present. This data should be excluded from the data evaluation process for the water supply
area.
Where 3 or more premises in 15 show average copper concentrations over 3 sampling
occasions of greater than 2000 µg/l after 4 hours stagnation, then the water supply area can
be considered as an area where the use of copper needs to be restricted.
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Interpretation of results
The exposure level in each of the premises should be calculated from the average of the
results of zinc in the three 1000 ml samples. Where galvanised pipe has been installed and
all of the sample results show low zinc and elevated iron concentrations, it may be assumed
that the zinc layer has been removed by corrosion. In this case, the water supply area can be
considered as an area where the use of galvanised steel needs to be restricted.
Where more than 3 premises in 15 show average zinc concentrations over 3 sampling
occasions of greater than 3000 µg/l after 4 hours stagnation, then the water supply area can
be considered as an area where the use of galvanised steel needs to be restricted.
Samples
The rig shall contain three commercially available pipes with an inner diameter of (13±1) mm
shall be used. Where this diameter is not commercially available then the next largest
commercially available size shall be used. The length of the pipes is at least 3 m.
Test water
Test water is the water as supplied from the water works that supplies the area under
investigation.
Method
Through each line 145 l/day flows according to a complex running/static flow regime. The
flow rate of the water is about 0.5 m/s.
The test rig shall be constructed in accordance with the instruction as given in the standard.
Duration and sampling
The duration of the test shall be a minimum of 26 weeks and a maximum of 104 weeks.
Stagnation curves shall be determined every month up to 6 months for the relevant metal.
When applicable, further sampling shall be carried out 39, 52, 65, 78, 91 or 104 weeks after
the start of the operation of the test rig and the determination of stagnation curves shall be
continued.
Presentation of test results
The results shall be presented as graphs of the average concentrations of the released
metals MEP(T) against the period of operation (T).
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References
Australian/New Zealand Standard AS/NZS 4020 (1999) Products for use in contact with
drinking water
American National Standards Institute ANSI/NSF 61 – 1999a Drinking water system
components – Health effects
BS 7766 (1994) Assessment of the potential for metallic materials to affect adversely the
quality of water intended for human consumption
DIN 50931-1 (1999) Korrosion der Metalle - Korrosionsversuche mit Trinkwässern – Teil 1:
Prüfung der Veränderung der Trinkwasserbeschaffenheit
CEN WI 00164182 Influence of metallic materials on water intended for human consumption
- Dynamic rig test for assessment of metal leaching
Council Directive 98/83/EC on the quality of water intended for human consumption. Official
Journal of the European Communities, L330/31-54, Brussels 1998
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Oliphant R. (2000) A review of the national standards currently used to determine the
potential of metallic materials to contaminate potable waters RG-CPDW 0….
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