To whom it may concern:
Please accept the following comments regarding the recently circulated draft of NSF 375 – Sustainability Assessment for Water Contact Products.
The Water Quality Association (WQA) and American Society of Plumbing Engineers (ASPE), as well as the undersigned companies, strongly object to NSF 375, and the process through which it was developed, for three main reasons:
(1) Lack of industry representation: Manufacturers of drinking water treatment units (DWTUs) do not have adequate representation on the consensus body. WQA, as the trade association that represents manufacturers of drinking water treatment systems, applied to represent the industry on the consensus body, but was denied voting status. Similarly, the consensus body is conspicuously devoid of individual DWTU manufacturers with voting status.
(2) Impropriety of scope: The standard simply lacks the specificity necessary for it to be effective. NSF 375 addresses a wide variety of “water contact products” in extremely broad strokes. Drinking water treatment units are lumped in with everything from pipe and plumbing fixtures to wastewater treatment equipment. However, NSF 375 fails to provide any specific criteria for drinking water treatment products,
despite a clear mandate to that effect by the DWTU manufacturing companies that have already been participating in the WQA/ASPE standards development process for some time.
(3) Standards Already in Existence: WQA has been working on the development of sustainability standards for drinking water systems and process media since 2011. WQA S-802: Sustainable Activated Carbon Media for Drinking Water Treatment and WQA S-803: Sustainable Drinking Water Treatment Systems have already been published and in use by WQA since 2013. WQA partnered with ASPE, an ANSI accredited Standards Development Organization (SDO), in developing these standards, which are currently in the final stages of being adopted as American National Standards. In addition, these standards include product-specific criteria, developed with substantial input from across the water treatment industry, thereby rendering NSF 375 superfluous at best.
The undersigned will not support the acceptance of NSF 375 until drinking water treatment systems and media are removed from the scope. There is no need for NSF to pursue a general standard for sustainability covering drinking water treatment systems and process media when product specific standards have already been developed by WQA and ASPE.
Tom Palkon, CWS-VI, Interim Executive Director
Water Quality Association
Jim Kendzel, MPH, CAE, Executive Director/CEO
American Society of Plumbing Engineers
Des Plaines, Illinois
Nabil AlSaleh, National Sales Director
Lassie Health Water Company
Jeddah, Saudi Arabia
Jonathan Ben-David, CEO
Waterlogic International Plc
Bill Hildebrand, President
Carlon Meter, Inc.
Grand Haven, Michigan
Larry B. Horinbein, President/Owner
Southlantic Water Systems
Myrtle Beach, South Carolina
Ben C. Jarvis, Owner/General Manager
Logan Water Conditioning, Inc.
Danielle Jessup, Executive Director
Florida Ground Water Association
Roger Lutz, CEO
Oakville Pump Service
Terry Reeh, Partner
Steve Reif, VP Engineering & Regulatory
Paragon Water Systems, Inc.
Greg Reyneke, Managing Director
Red Fox Advisors
Linwood M. Sawyer, Vice President
Water Purification Consultants, Inc.
Winston-Salem, North Carolina
Elizabeth Scheopner, Owner
Scheopner’s Water Conditioning LLC
Garden City, Kansas
Shayron Barnes-Selby, VP of Government Affairs & Quality Services
DS Services of America, Inc.
Brent Simmons, Vice President
Omnipure Filter Company