EPA opened drafts of both guides for public comment in April 2026 and finalized them in August 2026. According to the agency’s release, the guidance complements an ongoing effort to pair regulatory clarity with technical assistance and funding for lead service line work. Related initiatives this year include a redesigned lead information hub, a new children’s health StoryMap, and continued support through the Real Water Technical Assistance program, noted as part of nearly three billion dollars announced in 2026 for lead service line identification and removal.
On inventories, the guidance reiterates LCRI timelines. Water systems completed an initial inventory of service line materials in October 2024. A baseline inventory update is due by November 1, 2027, followed by annual updates. Most systems have until December 31, 2037 to resolve service lines that remain classified as “unknown.”
The Service Line Inventory Tips document details acceptable evidence sources beyond direct visual inspection when identifying service line materials. Examples include the following, when appropriate and documented:
- Construction and plumbing code records that indicate materials used during specific periods.
- Documented statements from experienced water system personnel with knowledge of historical practices.
- Statistical or predictive modeling, including AI‑based approaches, when approved by the state primacy agency.
The guidance further clarifies how to determine whether a galvanized line is not categorized as “galvanized requiring replacement.” Systems may make that determination by documenting that the galvanized segment was never downstream of a lead line, using neighborhood‑level records such as local ordinances that prohibited the installation of lead pipe during the relevant construction period.
The Access Tips document addresses circumstances in which a system cannot physically access a service line to complete a replacement. Under the LCRI, replacement of lead lines and galvanized lines requiring replacement applies to segments “under the control of the water system,” and each system must determine and document when it lacks such control.
Common barriers to access outlined in the guidance include: a property owner’s refusal of consent after a documented “reasonable effort” (defined as four contact attempts using at least two communication methods); local ordinances that limit excavation to periods tied to water main work; and state laws that require the use of state‑contracted crews operating on fixed schedules. Worked examples show how systems can remain in compliance by reporting the barrier, maintaining documentation, and reassessing access as conditions change, such as when new funding becomes available or when an ordinance expires.
Together, the Service Line Inventory Tips and Access Tips are intended to reduce uncertainty for utilities and regulators by translating rule language into specific, repeatable documentation practices. They align with ongoing federal technical assistance and funding programs intended to support the long‑term effort to identify, document, and remove lead service lines on the timelines established in the LCRI.
