Skip to main content

American Iron and Steel

The Water Investment Division has created Guidance Document 29 to help all parties involved in a project to understand their roles and obligations to meet the American Iron and Steel (AIS) Requirements.  Additional information about AIS is provided below.

  1. American Iron and Steel Overview
  2. Requirements and Product Certifications
  3. Waivers
  4. Items and Products Covered
    1. Commonly Used Products
    2. Municipal Castings
    3. Structural Steel
    4. Construction Materials
  5. Additional Guidance

American Iron and Steel Overview

Requirements of American Iron Steel apply to all projects that have gone to construction after January 17th, 2014.  Exceptions include projects whose plans and specification were approve prior to January 17th 2014.  The EPA accepts applications for AIS Waivers.  See Waivers Section below.

Requirements and Product Certifications

EPA requires the Owner to demonstrate products and items covered under the AIS regulations are in conformance.  Owners can demonstrate conformance using either Step Certification or Final Manufacturer Certification methods.

  • Step Certification:  Requires each handler (supplier, fabricator, manufacturer, processor,ect) of the iron and steel products in 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.
  • Final Manufacturers Certification:  Requires the final manufacturer that delivers the iron or steel product to the worksite, vendor, or contractor may provide a certification asserting that all manufacturing processes occurred in the United States.

Five Minimum Requirements for Information to Include in an AIS Certification:

  1. Name of Manufacturer (Note:  Should appear in the text of the letter and be on the company letter head.)
  2. The location of the manufacturing facility where the product or process took place (not its headquarters)
  3. A description of the product or item being delivered
  4. A named project / location that the product was delivered to
  5. A signature by a manufacturer's responsible party


 There are two types of of waivers national waivers that are available for any project to use and project specific waivers.

  1.  National Waivers (Two most typically used linked below).
  2. Project Specific Waivers
  • Public Interest Waiver: Applying AIS would be inconsistent with the public interest.
  • Example of Public Interest Waiver 
  • Availability Waiver: Iron and Steel products are not produced in the United States in sufficient and reasonably available quantities and of a satisfactory quality.
  • Example of Availability Waiver 
  • Expense Waiver: Inclusion of Iron and Steel products produced in the United States will increase the cost of the overall project by more than twenty five percent.
  • Example of Expense Waiver (None issued.)

Items and Products Covered under AIS include but are not limited to the following:

Commonly Used Iron and Steel Products:

  • Lined or unlined pipes or fittings

  • Manhole covers

  • Hydrants

  • ​Tanks

  • Flanges

  • Pipe clamps and restraints

  • Valves

  • Reinforced precast concrete

Municipal Castings:

  • Access hatches
  • Ballast screen
  • Benches (Iron and Steel)
  • Bollards
  • Cast bases
  • Cast Iron  and Steel Hinged Hatches (Square and Rectangular)
  • Cast Iron and Steel Riser Rings
  • Catch Basin Inlet
  • Cleanout/Monument Boxes
  • Construction Covers and Frames
  • Curb and Corner Guards
  • Curb Openings
  • Detectable Warning Plates
  • Downspout Shoes (Including Boot, Inlet)
  • Drainage Gates, Frames and Curb Inlets
  • Inlets
  • Junction Boxes
  • Lamp Posts
  • Manhole Covers (Including Rings, Frames and Risers)
  • Meter Boxes
  • Service Boxes
  • Trash Receptacles
  • Tree Grates
  • Tree Guards
  • Trench Grates
  • Valve Boxes (Including Covers and Risers)

Structural Steel:

  • Wide-flange shapes
  • Standard I-Beams
  • Channels
  • Angles
  • Tees and Zees
  • H-piles
  • Sheet piling
  • Tie Plates
  • Cross Ties
  • Any Special Purpose Structural Steel

Construction Materials:

  • Wire Rod
  • Bar
  • Angles
  • Concrete Reinforcing Bar
  • Wire
  • Wire Cloth
  • Wire Rope
  • Tubing
  • Framing
  • Joists
  • Trusses
  • Fasteners (i.e. nuts and bolts)
  • Welding Rods
  • Decking
  • Grating
  • Railings
  • Stairs
  • Access Ramps
  • Fire Escapes
  • Ladders
  • Wall Panels
  • Dome Structures
  • Roofing
  • Ductwork
  • Surface drains
  • Cable Hanging Systems
  • Manhole Steps
  • Fencing and Fence Tubing
  • Guardrails
  • Doors
  • Stationary Screens

Additional Guidance and Waivers

For additional guidance and FAQ on AIS Requirements, please refer to the March 20, 2014 EPA Memorandum for the Implementation of Amercian Iron and Steel Provisions.