Recordkeeping for Iron and Steel Products

The Consolidated Appropriations Act of 2014 (Public Law 113-76) includes an "American Iron and Steel (AIS)" requirement that requires Clean Water State Revolving Fund (CWSRF) and Drinking Water State Revolving Fund (DWSRF) loan recipients to use iron and steel products that are produced in the United States for projects involving the construction, alteration, maintenance, or repair of a public water system or treatment works if the project is funded through a State Revolving Fund (SRF) loan.  We highly recommend all SRF loan recipients review USEPA’s AIS Guidance Documents in order to understand how to comply with AIS requirements.  

Iron and steel products subject to the regulation include the following items:


  • Lined or unlined pipes or fittings
  • Manhole Covers
  • Municipal Castings 
  • Hydrants
  • Tanks (Construction materials (those articles  articles, materials, or supplies made primarily of iron and steel, that are permanently incorporated into the project, not including mechanical and/or electrical components, equipment and systems). 
  • Flanges
  • Pipe clamps and restraints
  • Valves
  • Structural Steel
  • Reinforced precast concrete

Loan recipients must be able to verify that products used in their projects comply with the AIS requirements. USEPA recommends loan recipients use a “Step Certification” process to ensure that producers adhere to the AIS requirements.  Step certification is a process under which each handler (supplier, fabricator, manufacturer, etc.) of the iron and steel products certifies that their step in the process was domestically performed.  Each time a step in the manufacturing process takes place, the manufacturer delivers its work along with a certification of its origin. A certification can be quite simple as long as it includes the name of the manufacturer, the location of the manufacturing facility (not company headquarters), a description of the product or item being delivered, and a signature by a manufacturer’s responsible party. An example of this type of certification follows.  

Another type of certification involves the final manufacturer who delivers the iron/steel products to the worksite provides certification that all manufacturing processes occurred in the US.  While this type of certification is easier and acceptable, it may not provide the same degree of assurance and additional documentation may be needed. Regardless of the method, documents regarding the country of origin for iron and steel products should be collected and maintained by all loan recipients. Having a good paper trail is invaluable during an inspection or audit.  

If you have any questions regarding AIS requirements, call the Infrastructure Financial Assistance Section at 217-782-2027.  Information is also available at http://www.epa.illinois.gov/topics/grants-loans/water-financial-assistance/state-revolving-fund/guidance/index.

Sample Certification

The following information is provided as a sample letter of step certification for AIS compliance. Documentation must be provided on company letterhead.

Date

Company Name
Company Address
City, State Zip

Subject: American Iron and Steel Step Certification for Project (XXXXXXXXXX)

I, (company representative), certify that the (melting, bending, coating, galvanizing, cutting, etc.)
process for (manufacturing or fabricating) the following products and/or materials shipped or provided for the subject project is in full compliance with the American Iron and Steel requirement as mandated in EPA’s State Revolving Fund Programs.

Item, Products and/or Materials:
1. Xxxx
2. Xxxx
3. Xxxx

Such process took place at the following location:
_____________

If any of the above compliance statements change while providing material to this project we
will immediately notify the prime contractor and the engineer.

Signed by company representative