Clean Water SRF and Drinking Water SRF
EPA State Revolving Funds BABA rules for iron & steel
How the Build America, Buy America iron & steel 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 iron and steel used in the project must be produced in the United States, meaning all manufacturing processes from the initial melting stage through the application of coatings occurred in the United States. This aligns with the pre-existing SRF American Iron and Steel requirement.
A worked example
Take galvanized guardrail supplied to a EPA State Revolving Funds project. The standard follows the steel from the initial melt through the application of coatings. Every one of these steps has to be in the United States.
- Initial meltUnited States
- Continuous castingUnited States
- Rolling and formingUnited States
- Galvanizing (coating)United States
Every step above is in the United States, so this example is compliant. Move a single step offshore, for example sending the guardrail abroad only for galvanizing, 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 iron & steel 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 iron & steel questions
What is the iron & steel standard for a EPA State Revolving Funds project?
All iron and steel used in the project must be produced in the United States, meaning all manufacturing processes from the initial melting stage through the application of coatings occurred in the United States. This aligns with the pre-existing SRF American Iron and Steel requirement.
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 iron & steel 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.