Clean Water SRF and Drinking Water SRF
EPA State Revolving Funds BABA rules for construction material
How the Build America, Buy America construction material standard applies to a project funded by Environmental Protection Agency Clean and Drinking Water State Revolving Funds. The cited rule, a worked example, and the waiver options.
Run it in the calculatorAll manufacturing processes for the construction material must have occurred in the United States, per the OMB-defined construction materials list.
A worked example
Take HDPE pipe, a plastic and polymer-based construction material, supplied to a EPA State Revolving Funds project. Every manufacturing process has to occur in the United States.
- Resin productionUnited States
- CompoundingUnited States
- ExtrusionUnited States
- Finishing and markingUnited States
Every step above is in the United States, so this example is compliant. Move a single step offshore, for example extruding the pipe abroad from US resin, and the whole item is non-compliant. There is no percentage that rescues it; the standard is all-or-nothing.
How to check a line
- 1
List every manufacturing step
List each manufacturing process the construction material goes through, from the earliest stage to final finishing.
- 2
Record the location of each step
For each step, record the country where it was performed.
- 3
Confirm all steps are in the US
The item passes only if every listed manufacturing process occurred in the United States. One offshore step fails the whole item.
- 4
Handle any shortfall
If any step was performed abroad, the item is non-compliant. Check whether a waiver category applies before relying on it.
EPA State Revolving Funds construction material questions
What is the construction material standard for a EPA State Revolving Funds project?
All manufacturing processes for the construction material must have occurred in the United States, per the OMB-defined construction materials list.
Is there a percentage to hit?
No. This is an all-or-nothing standard: every manufacturing process must occur in the United States. A single offshore step fails the item, regardless of cost.
What if a construction material line fails the standard?
It is non-compliant unless a recognised waiver applies and is granted by the agency. EPA State Revolving Funds recognises 5 waiver categories. A waiver is never a pass on its own.