The U.S. Environmental Protection Agency has issued two guidance documents to support public water systems in meeting lead service line identification and replacement requirements under the Lead and Copper Rule Improvements (LCRI). The documents, titled Access Tips and Service Line Inventory Tips, present existing federal requirements in plain language and include worked examples that address frequently encountered field and documentation questions. By clarifying expectations, the guidance aims to streamline implementation for utilities and state regulators.
Both documents were opened for public comment in April 2026 and finalized in August 2026. Their release is part of a broader effort to pair plain-language instructions with funding and hands-on support so water systems can accelerate removal of lead service lines. The package is positioned to work in concert with technical assistance and other outreach tools introduced this year.
Under the LCRI, systems completed an initial inventory of service line materials in October 2024 and must submit a baseline inventory update by November 1, 2027, followed by annual updates. Most systems have until December 31, 2037 to resolve any service lines still categorized as unknown. These milestones establish a multi-year pathway for progressively refining records and guiding field verification and replacement work.
The Service Line Inventory Tips document details acceptable evidence sources beyond direct visual inspection for determining service line materials. Examples include construction and plumbing code records, documented statements from experienced water system personnel, and statistical or predictive modeling, including AI-based methods, when approved by a state primacy agency. The guidance also clarifies how a system can show that a galvanized line is not considered galvanized requiring replacement by demonstrating it was never located downstream of a lead line, using neighborhood-level documentation such as historical local ordinances that banned lead pipe installation during specific building periods.
The Access Tips document addresses circumstances where a water system cannot physically access a service line to replace it. The LCRI requires replacement of lead and galvanized requiring replacement lines that are under the control of the water system, and it is up to each system to determine and document when that control is lacking. Common barriers include a property owner refusing consent after a documented reasonable effort, defined as four contact attempts using at least two communication methods; local ordinances that limit excavation to periods of water main work; or state laws requiring the use of state-contracted crews operating on fixed schedules.
Worked examples in the Access Tips show how systems can remain in compliance by documenting barriers, continuing to report status, and reassessing access as conditions change, such as when new funding becomes available or an ordinance expires. The guidance sits alongside other EPA initiatives this year, including a redesigned lead information hub, a new children’s health StoryMap, and continued support through the Real Water Technical Assistance program. According to the agency’s announcements in 2026, nearly $3 billion is being directed to lead service line identification and removal efforts.