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The 2024 model codes are nearing completion for both the International Plumbing Code (IPC) and the Uniform Plumbing Code (UPC). As of this writing (December 2022), the dates and locations for the 2024 International Plumbing Code final action hearings are not published yet. The uniform code hearings will typically be held a little later in the year because they only go through one group of hearings in a three-year cycle.
When the dates and location are confirmed, the model code association will post the information online. The 2024 codes should be available in the fall or winter of 2023 (check each association’s website for the actual publication dates). State and local jurisdictions will begin reviewing the new codes for adoption in their jurisdictions. Depending on the jurisdiction, that can be anywhere from immediate adoption in a year or more due to the steps in the legal process to adopt the codes as governing law.
Whenever you start a project, make sure to contact the local jurisdiction and determine which edition of the code will be followed for that project, then document the codes to be followed. The code that will be followed for a given project is typically identified on the construction permit application and the cover sheet for the construction documents. This allows consistency throughout the design, construction and inspection process. Some larger projects can take many years more than a code cycle to design and build.
The next model codes that you can submit changes for would be the 2024 codes for publication in the 2027 codes. Typically, the model building code organizations operate on a three-year code update cycle. Prior to the first year of the code cycle, the deadline for proposed code changes will be published online, as well as in trade publications. So, the deadline for proposed code changes to the 2024 model codes will be published sometime in 2023.
Then, the proposed code changes for the next edition of the code are typically due early in the first year of a code cycle. So, for the 2027 model codes, the proposed code changes will be due in January 2024. Please check with each model code association’s website for the exact dates when you can start submitting code changes.
Anyone can submit a code change proposal through an online form once the online code change process opens. Code change proposals must be submitted through each model code association’s website. For the international codes, the International Code Council (ICC) uses software called cdpACCESS. For the uniform codes, the International Association of Plumbing & Mechanical Officials (IAPMO) has a web portal where code changes can be submitted.
I recommend that you keep track of your thoughts on code changes by marking your current code book with proposed changes in the margins for later reference when proposing code changes. The text that is proposed as new language will be underlined, and text that is proposed for deletion will have a line striking through it. There is also required a reason statement explaining why the code change is being proposed.
After the code change proposals are submitted, they are assembled into a proposed code change book that will be available for download sometime around March 2024. The publication of the book allows anyone to review the proposed changes and decide if they want to support or oppose each change.
One thing that the technical committees look for is whether a proposed code change is proprietary or attempting to promote one technology or product over another, or even mandate a particular manufacturer’s product or restrict a competitor’s product.
Next, the code hearings are scheduled mid-year during the first year of the code cycle, during which the technical committees hear testimony on each code change proposal. At the hearings, there is a moderator who calls for supporting and opposing testimony on each proposal.
The submitter of a proposed code change gives a few minutes of supporting testimony, the floor opens up for anyone in attendance to provide further support, and the opposition is heard. The floor is then closed to comments, allowing the committee to discuss and vote on each code change proposal.
The hearings offer code officials, architects, builders, engineers, designers, contractors and other interested parties the opportunity to provide input on proposed code changes to the model codes, but the final vote is with code officials only. If you don’t have time to submit a code change and testify, consider contacting a local code group or American Society of Plumbing Engineers (ASPE) legislative committee and ask if they will submit and testify for a code change on your behalf.
ICC Code Development Process
The ICC produces 16 model codes known as the I-Codes, which are divided into two groups, Groups A and B. Changes to each group are considered on a staggered basis and include these key elements:
• Code change review. At the beginning of each code cycle, the ICC publishes all proposals for public review.
• Committee action hearings (CAH). Approximately two months after code change proposals are published, the ICC holds public code development hearings where interested parties testify before the Code Development Committees in support of or in opposition to a proposed change. After testimony is complete, the committee recommends accepting or denying a code change proposal.
• Report and public comment. The ICC publishes the hearing results shortly after completion. The public is then invited to submit comments on the CAH decisions, which can include objections to the hearing results.
• Final action hearing and publication. Approximately six months after code change proposals are released, the ICC holds another round of public hearings, allowing interested parties to offer testimony on the public comments and CAH recommendations. After testimony is completed, designated ICC voting members (largely code officials) vote for or against code change proposals. The ICC then incorporates all approved proposals into the next editions of the I-Codes.
• State and local adoption. The revised codes are not in effect until adopted by a state or local jurisdiction.
Group A includes the following codes:
International Building Code (IBC): egress, fire safety,
International Fire Code (IFC)
International Fuel Gas Code (IFGC)
International Mechanical Code (IMC)
International Plumbing Code (IPC)
International Private Sewage Disposal Code (IPSDC)
International Residential Code (IRC): mechanical and plumbing
International Swimming Pool and Spa Code (ISPSC)
International Zoning Code (IZC)
International Property Maintenance Code (IPMC)
International Wildland-Urban Interface Code (IWUIC)
Group A development schedule:
January 2024: Deadline for ICC receipt of Group A code change proposals
March 2024: Publication of proposed code changes
April-May 2024: Committee Action Hearings held
September 2024: Code change proposals are finalized at public comment hearings
October 2024: ICC voting members finalize 2024
Group A codes
Mid- to late 2026: Expected publication of 2027 I-Codes
Group B includes the following codes:
Administrative provisions for all I-Codes
International Building Code (IBC): structural
International Existing Building Code (IEBC)
International Energy Conservation Code (IECC), Commercial and Residential
International Residential Code – Building (IRC-B)
International Green Construction Code (IgCC)
Group B development schedule:
January 2025: Deadline for ICC receipt of Group B code change proposals
February 2025: Proposed code changes are released
March-April 2025: Committee Action Hearings held
September 2025: Code proposals are finalized at public comment hearings
October 2025: ICC voting members finalize 2027
Group B codes
Mid- to late 2026: Expected publication of 2027 I-Codes
ICC Water Policy and Technical Conference
On Oct. 18, 2022, the ICC hosted a water policy and technical conference titled “ICC Water: Standards for a Resilient Future” in recognition of the 50th anniversary of the Clean Water Act. The single-day conference brought together policymakers, contractors, engineers, code officials, academics, manufacturers and health authority experts to discuss best practices for codes and standards affecting water quality when planning for standards for the future.
The conference addressed three priorities in the water treatment and wastewater treatment infrastructure sectors: decentralized wastewater, water efficiency and public health and water reuse. The conference was intended to address the importance of clean water solutions, safe drinking water and wastewater treatment levels.
During the conference, the ICC announced it is moving forward with developing two new ANSI standards. ICC 825 Standard - Private Sewage Disposal Systems tackles climate risks associated with septic and other types of decentralized or on-site wastewater treatment systems while incorporating advances in technology.
ICC 815 Standard - Pipe Sizing for Water Distribution, Drainage and Venting Systems addresses water efficiency and the entire plumbing system by improving upon the outdated methods currently used in all plumbing codes, as well as accounting for post-COVID-19 usage patterns. Funding the National Institute of Standards and Technology (NIST) Plumbing Research bill is an important complement to this effort (http://bit.ly/3VQNEdj).
Development of these standards is intended to address bacterial health hazards in recycled water. However, any portion of a wastewater treatment plant that has a glitch could allow contaminated water into the effluent. If the effluent is to be drinking-water quality, these standards need to be closely monitored to assure health and safety, especially when relying on water treatment chemicals and filters that can fail.
These systems are being necessitated because of water conservation and water reuse and recycling efforts. We may need to have monitoring and backup systems for the backup systems to protect the health and safety of the public, especially when relying on private building owners to comply with drinking water standards.
We should consider training and licensing for all water and wastewater treatment plant operators. We also should seriously consider limiting development and the use of water in overdeveloped arid and dry regions.
Onsite water reuse is an important option for combating water scarcity and protecting public health. However, a lack of understanding of all the water reuse and reclaimed water systems types and the level of treatment required have hindered development of a standard for reclaiming and reusing wastewater for various applications.
The level of treatment for wastewater to go from raw sewage to drinking water is much higher than the level of treatment for greywater to be reused for flushing or rainwater to be recycled for flushing or evaporative cooling and similar applications. There needs to be more training and education on the levels of water quality required for each application and the consequences of chemical equipment or component failures.
With any water that is reclaimed, recycled or reused, there needs to be strict oversight, inspections and consistent regulatory approaches for the health and safety of the public.
With water conservation efforts by voluntary water conservation programs focusing on energy and water conservation by reducing fixture flow rates without addressing the existing sanitary drain and building sewer system sizing, we are seeing drain line transport issues increasing and the phenomenon of “dry drains” is leading to an exponential increase in drain line blockages.
Without addressing the entire plumbing system, issues such as sanitary drain back-ups and sanitary sewer overflows can negatively impact public health. Drains may need to be smaller to increase the hydraulic depth of flow, or minimum flows need to be established for various fixture types to be effective for their purpose.
Private Sewage Disposal Systems, ICC 825
It is anticipated that ICC 825 will incorporate engineered packaged sewage treatment systems and other advances in decentralized waste technology.
The presentations at the conference brought out the following issues on private sewage disposal systems:
1. About 20% of homes in the United States rely on private sewage disposal systems, often referred to as septic systems or packaged decentralized wastewater treatment systems.
2. When decentralized wastewater treatment systems fail, the results are serious for the environment and local waterways as sewage makes its way into streams, rivers and lakes.
3. Decentralized wastewater treatment systems must be able to separate solids and discharge liquid waste to the ground. When they cannot discharge liquid waste properly, either because of solid rock or clay in the ground or because the water table is elevated, then an engineered septic field must be designed in soil that will percolate at a rate to handle the absorption of the liquid waste.
4. Changes in flood plains, such as rising sea levels brought on by climate change, can exacerbate system failures and may require engineered wastewater treatment systems.
5. Most states have developed their own codes, enforced by the local health department or by local jurisdictions, for private sewage disposal or decentralized wastewater treatment systems. Many states have adopted the ICC’s IPSDC, which helps protect the environment and provide clean water for streams, rivers and lakes.
6. Federal funding sources, such as an EPA program authorized by the bipartisan infrastructure law, can assist with the development of future technologies to improve decentralized wastewater treatment systems.
With respect to water flow from low-flow fixtures, the reduced water flows are less than 20% of the flow rates from prior to the Energy Policy Act of 1992 that significantly reduced water flows from plumbing fixtures. Reduced water flow rates can work in densely populated areas where there are many other fixtures contributing to flows in sewers.
However, in rural areas or in large buildings with very few fixtures and long horizontal drains, drain line transport of solids is a serious issue that may warrant periodic flushing of an adequate amount of water to move solids down a long drain pipe of a given size.
Contributing to this issue are voluntary water conservation programs that call for ultra-low-flow fixtures to be installed on older, large building drains, building sewers and public sewers. As flows are reduced, many older, larger sewers look like a dry river with a meandering channel of flow through debris and solids on the bottom of the pipe.
With the advent of flushable wipes, flushable toilet seat covers, heavy-duty bathroom tissue, and a variety of feminine hygiene products that get flushed, ultra-low-flow fixtures do not perform well with respect to drain line transport of solids. If the solids build up in the building drain, the fixtures eventually back up and sewage overflows in the building.
If the solids make it out of the building drain to the public sewer in the street, the public sewer can become blocked, and the raw sewage backs up into buildings or out of the nearest manhole openings in the street, where it drains into the nearest storm drain and into nearby waterways. Sanitary sewer overflows have grown significantly in recent years and have been related to fish kills and polluted waterways.
Ultra-low-flow fixtures in buildings also contribute to aging water in the utility water mains in the streets.
However, reducing the size of water pipe in buildings only addresses a small portion of the problem; sewers in the streets are often oversized. The utility water mains are sized with outdated American Water Works Association (AWWA) standards that include fire flows because the mains serve fire hydrants and water mains.
As in the past, I have suggested that with the recent infrastructure funds and with newly designed water mains, AWWA and local water utilities need to consider separating the fire water mains from the domestic/drinking water mains.
This will allow the water mains to be about 20% or less of the volume or area of the old water mains and the water to move through the utility water distribution system at a higher velocity. It also will reduce the amount of time that water resides in the water main from the time it is treated in the water treatment plant until it reaches a customer’s water meter near the end of the system.
We are currently experiencing aging water or water that has been in the utility water main and building water distribution piping long enough to have the water treatment chemicals dissipate down to a level that will not control bacteria growth. If we want to address the water quality in the larger water mains and not install a new smaller domestic water main, we should consider installing smaller water return mains.
Circulating the water back through local water treatment plants or to the main water plant to retreat or polish the water allows the system to maintain water quality with filtering and the addition of water treatment chemicals at the beginning and intermediate points along water utility mains. There need to be engineering studies of these concepts and maybe some pilot projects built to study improvements in water quality.
If you are a design professional and your project is at or near the end of a water distribution system where water quality is questionable, consider adding valved tees and a lockable bypass for easy installation of a secondary water treatment chemical injection station. It will require wall space for the controls and flow-proportioning chemical injection pumps and floor space for chemical totes or tanks.
There should be a large-diameter flushing valve (full size up to 1 1/2-inch max) with a hose connection for adequate flushing of stagnant water when needed. There also should be a small sampling valve for collecting water samples at the building water service entrance. This will allow flushing and testing of the building water supply main or service piping.
IAPMO has been working on researching and developing a water demand calculator that reduces the old, outdated Hunter’s Curves, which were developed from research done by Dr. Roy B. Hunter of the National Bureau of Standards, now called the National Institute of Standards and Technology. Hunter’s research was conducted about 82 years ago. Since that time, there have been many mandatory and voluntary reductions in fixture flow rates. The ICC standard appears to be duplicating the IAPMO effort.
The Clean Water Act
The Clean Water Act is the primary federal law in the United States governing water pollution. Its objective is to restore and maintain the chemical, physical and biological integrity of the nation’s waterways; to recognize the responsibilities of the states in addressing pollution and providing assistance to states to do so, including funding for publicly owned treatment works for the improvement of wastewater treatment; and to maintain the integrity of streams, lakes, rivers and wetlands.
Technically, the name of the law is the Federal Water Pollution Control Act (FWPCA). The first FWPCA was enacted in 1948 but took on its modern form when completely rewritten in 1972 — The Federal Water Pollution Control Act Amendments of 1972. Major changes have subsequently been introduced via amendatory legislation, including the Clean Water Act of 1977 and the Water Quality Act of 1987.
The Clean Water Act does not directly address groundwater contamination. Groundwater protection provisions are included in the Safe Drinking Water Act, the Resource Conservation and Recovery Act and the Superfund Act.
Mark Your Calendars
The World Plumbing Council has deemed March 11 of each year as World Plumbing Day. Plumbing organizations throughout the world are invited to undertake a range of activities with the aim of raising awareness of the important role played by today’s plumbing industry
Mark your calendar and post pictures on social media of what you are doing to raise awareness.
The WPD logo illustrates four key elements with which plumbing is associated: water, health, energy and environment. The logo was launched by the World Plumbing Council, and it is hoped that the logo will be used widely, drawing awareness to the fact that plumbing is far more important than many people in both developed and developing countries realize.
Across the ocean, the International Sanitation and Heating (ISH) Trade Fair is scheduled for March 13-17, 2023, in Frankfurt, Germany, at the Messe Frankfurt Trade Fair Complex (ish.messefrankfurt.com/frankfurt/en.html). The complex has eight multi-story exhibit space buildings. The ISH show offers an experience that you cannot see in the United States. l
Ron George, CPD, is president of Plumb-Tech Design & Consulting Services LLC. Visit www.plumb-techllc.com for more information.
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