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The EPA Office of Inspector General Identifies Ambiguity in American Iron and Steel Requirements for Clean Water Fund Recipients

For Immediate Release, June 27, 2024

WASHINGTON – The U.S. Environmental Protection Agency Office of Inspector General today issued a report identifying that Clean Water State Revolving Fund, or CWSRF, recipients and American manufacturers need clear and precise guidance for defining applicable products for projects that require adherence to American Iron and Steel, or AIS, requirements.

The CWSRF program has an American Iron and Steel, or AIS, requirement for funding recipients requiring them to use iron and steel products that are produced in the United States for construction, alteration, maintenance, or repair of a public water system or treatment works. While a 2014 EPA memorandum provides implementation guidance, conflicting opinions from EPA subject matter experts regarding whether certain products containing PVC complied with the requirement have led to ambiguity, highlighting the need for updated guidance. 

“Clean Water State Revolving Fund recipients and manufacturers committed to complying with AIS requirements are hitting a roadblock due to the EPA’s ambiguity on products with PVC components,” said EPA Inspector General Sean W. O’Donnell. “Clear, current guidance is not just helpful—it’s essential for ensuring industry compliance and effective government enforcement.” 

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About the EPA OIG

The OIG is an independent office within the EPA that performs audits, evaluations, and investigations of the EPA and the U.S. Chemical Safety and Hazard Investigation Board. For more information, visit our website and follow the OIG on X, LinkedIn, and Instagram. Anyone with knowledge of potential waste, fraud, and abuse relating to EPA operations and programs is encouraged to report it to the OIG Hotline at (888) 546-8740 or OIG.Hotline@epa.gov.