In the early morning hours of June 24, 2021, a 12-story condominium in the Miami suburb of Surfside, Florida, partially collapsed killing 98 people. As a result of the tragedy, Florida intensified its focus on building safety and code enforcement. In May 2022, Florida Gov. Ron DeSantis signed Senate Bill 4-D into law. The law targets the structural integrity and long-term financial planning of condominiums and cooperatives, ushering in mandatory inspections, reserve studies and public disclosures.
Once these inspections started, however, inspectors found problems caused by improperly installed cured-in-place pipe repairs.
The proper technique for CIPP requires creating a continuous, fully sealed liner throughout the piping system. But inspectors discovered that some contractors were using a shortcut called “gapping,” which leaves small sections of aged, corroded pipe unlined at branch connections. Over time, these gaps can lead to leaks and hidden structural damage.
Recently, the Florida Plumbing Technical Advisory Committee (TAC) and the International Code Council closed a controversial loophole that allowed contractors to use gapping.
The issue came to a head during a TAC meeting last August, where opponents of stricter standards cited an ICC Evaluation Service document that appeared to endorse the gapping method.
However, the ICC-ES revised the report last October, making clear that gapping is not an approved method under national standards or Florida’s plumbing code. Days earlier, the TAC had voted to reinforce language requiring continuous installation with no gaps, aligning with state and national standards.
The decision ensures that any CIPP installation showing gaps during final inspection will automatically fail, giving building officials clear enforcement authority.
Last fall, Gloria Salazar, executive director for the Miami Plumbing Contractors Association, put us in touch with Michael Wilson, a Florida plumbing contractor who specializes in CIPP.
Wilson had been leading this fight for proper CIPP service for the past decade. Since founding Pipelining Technologies Inc. in 2005, Wilson has led the company to international recognition as one of the world’s foremost trenchless cured-in-place pipe lining firms.
We talked with him to find out more about the issue in Florida and how it may play out throughout the country.
PHCPPros: For readers unfamiliar with the issue, what exactly is “CIPP gapping,” and why is it considered flawed or non-compliant under ASTM F1216 and F1743?
Wilson: CIPP gapping refers to the practice of cutting out gaps in a felt liner and placing segments of the cut material into the pipe, stopping short of the branch connections or fittings. This process is repeated multiple times within the same pipe, leaving sections of the original pipe exposed. Each cut-out liner creates a top edge where debris can catch, while water is able to make its way between the new material and the original host pipe, creating weak areas where hazardous wastewater collects.
ASTM F1216 and F1743 were written to define what compliant cured-in-place pipe lining must be. A key requirement of a compliant CIPP installation is that the liner must be continuous and fully structural, restoring the pipe’s integrity as an uninterrupted system. When gaps are introduced, that continuity is lost, along with structural performance and hydraulic reliability. In simple terms, you’re no longer rehabilitating the pipe; you’re doing patchwork inside it. That’s why gapping fails to meet both the intent and the technical requirements of ASTM standards.
PHCPPros: How did contractors exploit ambiguity in prior Florida building code language, and what clarification did the state’s Technical Advisory Committee adopt?
Wilson: For years, some contractors leaned on vague wording in the code to justify installation methods that didn’t meet ASTM standards. These methods were promoted as acceptable alternatives, even though they were never tested, engineered or approved as safe for consumers or plumbing infrastructures.
The Technical Advisory Committee clarified that CIPP installations must be continuous through the full length of the pipe, including past fittings, with proper reinstatements, in reference with ASTM F1216 and F1743. This removed interpretation and replaced it with clear, enforceable direction. That distinction matters enormously in the field for inspectors, property owners and Florida residents.
PHCPPros: What practical change will inspectors and AHJs see during final inspections?
Wilson: Inspectors now have clear authority to reject gapped installations during final video inspections. In the past, they were put in a difficult position—forced to interpret technical details without clear code backing.
Now it’s straightforward. Inspectors can simply ask:
Is the liner continuous through the full length of the pipe?
Is it structurally compliant?
Are the fittings properly reinstated?
Is the installation free from obstructions, abnormalities, bumps, ledges and lifts that can impede flow?
If the answer is no, it fails. That consistency is a major win for enforcement and public safety.
PHCPPros: What did the ICC-ES gapping issue reveal about third-party evaluations?
Wilson: The August ICC-ES report that briefly endorsed gapping, before being retracted, showed how risky incomplete or misinterpreted evaluations can be. Third-party reports carry significant weight with inspectors and property owners, so when one appears to contradict ASTM standards or code intent, confusion spreads quickly.
The takeaway is simple: third-party evaluations must align with code, safety, standards, and tested for engineered performance and not marketing narratives. By retracting and revising the document, ICC-ES confirmed that gapping uses CIPP products in ways they were never engineered or approved for.
PHCPPros: What failures are being documented, especially with SB 4-D reserve studies underway?
Wilson: We’re seeing very predictable failures: debris catching on liner edges, liners separating from the host pipe, wastewater getting behind the liner, corrosion continuing at exposed fittings, backups, accelerated deterioration and early system failures.
With SB 4-D reserve studies requiring deeper inspections, these problems are now documented—not just suspected. Many condo associations are finding systems sold as “50-year solutions” failing in under 10 years, leading to warranty disputes and legal exposure.
PHCPPros: What arguments were made to defend gapping, and why do they fall short?
Wilson: The main arguments were lower cost and “field practicality.” But those claims don’t hold up long-term. Saving money upfront means nothing if the system fails early.
From a safety, durability, warranty and lifecycle standpoint, gapping doesn’t perform as a structural rehabilitation method. It doesn’t meet code or ASTM standards, and the data now clearly shows that.
PHCPPros: How will Florida’s decision influence national standards?
Wilson: Florida often sets the tone for the rest of the country. The ICC’s revised language is already influencing the 2026–2027 national code cycles. Other states, especially those with aging infrastructure and large multi-family buildings, are paying close attention.
This decision reinforces that CIPP is an engineered system, not a shortcut or a jerry-rigged system, and it must be treated that way nationwide.
PHCPPros: What will contractors need to change to comply going forward?
Wilson: This moment is similar to when the industry moved away from lead solder. Contractors will need the right CIPP equipment, approved materials, proper training in continuous liner design and a better understanding of hydraulics and structural performance.
This isn’t about doing more work. It’s about doing the work correctly and protecting the structural “bones” of the building. Contractors who invest in training and equipment will succeed.
PHCPPros: How does epoxy spin-casting factor into this discussion?
Wilson: Epoxy spin-casting raises many of the same concerns. There are no ASTM standards that define it as a structural pipe rehabilitation method and no accepted third-party approvals for using it as a standalone structural solution.
Like gapping, it’s often marketed as equivalent to CIPP when it isn’t, and it has been linked to failures and system damage. We expect further code clarification on this issue, and property owners should proceed cautiously while taking the time to become informed through reliable, code-aligned resources and understand their options.
PHCPPros: What services are in greatest demand now, and how will education evolve?
Wilson: Right now, owners are looking for clarity.
That demand has created a strong need for independent, code-aligned guidance and education. In this environment, knowledge is protection. The more owners and boards understand, the better prepared they are and the less likely they are to face costly missteps. They need to know what is considered compliant versus non-compliant, recognize common tactics used to sell improper methods, understand what a proper CIPP bid should include, and know what a code-compliant installation must look like. Just as important, they need to know the right questions to ask contractors and engineers, and to expect their property managers and Common Area Maintenance fees to be informed and aligned as well.
As well, owners and boards are asking what to do next and in what order. They’re asking critical questions:
Is my system compliant?
Do I have warranty exposure?
What are my options?
Services that are critical to helping them with these questions are independent video review, deficiency reporting, documentation analysis, contractor vetting, and clear code-compliant remediation planning. Owners want facts and direction, not sales pitches.
Boards, engineers, inspectors, building officials, property managers, owners and contractors all benefit from sharing the same baseline understanding of what compliant CIPP looks like. The next few years will be about educating through transparency, consistency, accessibility and standards-based material.






