Group comments regarding draft of NSF 375

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.

Sincerely,

Tom Palkon, CWS-VI, Interim Executive Director

Water Quality Association

Lisle, Illinois

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

Omaha, Nebraska

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.

Logan, Utah

Danielle Jessup, Executive Director

Florida Ground Water Association

Tallahassee, Florida

Roger Lutz, CEO

Oakville Pump Service

Oakville, California

Terry Reeh, Partner

EcoWater Systems

Fremont, Nebraska

Steve Reif, VP Engineering & Regulatory

Paragon Water Systems, Inc.

Tampa, Florida

Greg Reyneke, Managing Director

Red Fox Advisors

Beaverton, Oregon

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.

Atlanta, Georgia

Brent Simmons, Vice President

Omnipure Filter Company

Caldwell, Idaho