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This year the International Code Council (ICC) held its committee action hearings in Columbus, Ohio on April 15 – 23. The committee heard more than 150 proposed code changes dealing with the international plumbing code, a few correlated proposed changes to the international residential plumbing code, and proposed changes to the international private sewage disposal code. This was the first of two rounds of code hearings for the 2021 International Plumbing Code.
The comments to the proposed 2021 International Code changes are due by July 16, 2018. The commentary hearings will be in Richmond, Virginia, Oct. 24 – 31, at the Greater Richmond Convention Center.
The following is a discussion on a few of the notable code changes that were approved as submitted or approved as modified and there are a few of the code changes that were disapproved, but worthy of mention here because they were thought provoking.
The International Property Maintenance Code (IPMC) is adopted by jurisdictions that want to provide a level of safety for rental properties so that when a tenant leaves, and before the apartment is leased to a new tenant (if greater than 6 months between rentals), the property must be inspected for various safety issues.
The IPMC covers all existing residential and non-residential structures and all existing premises. It constitutes the minimum requirements and standards for premises, structures, equipment and facilities for light, ventilation, heating, sanitation, protection from elements, a reasonable level of safety from fire and other hazards, and a reasonable level of sanitary maintenance. It also covers the responsibility of owners, an owner’s authorized agent, operators, and occupants; and the occupancy of existing structures or premises, and for administration, enforcement and penalties. The intent is to ensure public health, safety and welfare for occupants in rental properties.
In an effort to do that, a code change was submitted to add scalding to the definition of a “hazard” in the IPMC.
Jennifer McKeown, a mother whose child was scalded to death in a bathtub in a rental property, testified that the water flowing from the bathtub spout in her apartment exceeded 160 F while her two daughters were playing in the bathroom. She said that her younger daughter was suddenly scalded in the bathtub and when she heard her scream, she was there within seconds to remove her from danger. Her daughter received 3rd degree burns and died a few days later.
McKeown, and many others, testified that extremely hot water should be part of the inspection for the turn-over of a rental property to assure that it was not so hot that it could cause a scalding hazard. The addition of “hot water” to the definition, along with other hazards such as slip or fall hazards, seemed logical to include for inspection.
Those in favor of the code change were frustrated to see property owners, building managers, homebuilders associations, and other lobbyists testifying against the change because it would add cost to operating their businesses. In most cases the cost of making the correction is less than one month rent, yet the deadly hazard was allowed to persist, while other hazards like uneven sidewalks or slippery surfaces were included as necessary inspections.
This made me wonder about the code change submittal form. It has a requirement to identify whether the code change will “add to the cost of construction,” and if it does, justification language must be provided related to the cost of construction or the code change will not be considered. There is no requirement in the code change forms to identify whether or not a change addresses a health and safety issue. I think the cost justification should be removed, or a health and safety reference should be added. A friend of mine, who was a general in the army as well as a civil engineer, used to always say, “Health and safety is more important than cost.”
During the Plumbing Code Hearings, a couple of days later, the Copper Development Association (CDA) submitted a bunch of code changes dealing with copper alloy definitions. During the last code change cycle, it submitted to change the term “brass” to “copper alloy” anywhere it was mentioned in the codes. There were lots of places where the term brass was used, so it added dozens of changes with little or no benefit. For this code change cycle, the association added a proposed change for a definition for the term “copper alloy.” The CDA submitted a definition as follows:
“Copper alloy — a homogeneous mixture of not more than two metals were not less than 50 percent of the finished metal is copper.”
The key words are, “not more than two metals.” This definition is now trying to enforce requirements for the make-up of metals. Historically, codes have stayed away from adding code requirements in definitions. There was an underlying reason for the change that was not covered in the reason statement. There has been a dezincification issue related to cheap yellow brass imported valves and fittings that were cast in foundries in foreign countries without any quality control with respect to the metals used in the alloy. In some of these countries, whatever scrap metals they have laying around including zinc, magnesium, aluminum, lead and tin get thrown into the furnace and melted down into an alloy they sold as brass. Soon after these fittings and valves were installed, they began to corrode and in one instance, they had failed miserably at a school.
Investigations have revealed at least six different metals in the cast brass PEX fittings or valves. The metallurgy lab inspecting the make-up of the metal reported there was less than 50 percent copper in the casting and they had six different metals present. Historically, red brass has been at least 85 percent copper and 15 percent other filler metals. Yellow brass is when there is less than 85 percent copper in the casting. Brass historically had lead included in the casting to make it easier to machine. The efforts to reduce lead in brass over the last few decades have resulted in lead-free brass, which is more expensive to manufacture and harder to machine and forge. This fuels the temptation for importers and supply houses to import shipments of these cheap yellow brass valves and fittings for use in plumbing systems. Over the last decade or two, yellow brass valves and fittings have been sold to supply houses as a cheap imported brass option, usually in smaller pipe and valve sizes.
When the CDA chose to eliminate the term “brass” from the plumbing codes and replace it with “copper alloy,” it seemed to have created more confusion than it solved because the definition calls for more than 50 percent copper. This definition seems to imply to casual readers of the code that copper alloy only needs to be more than 50 percent copper. When the filler metals exceed 15 percent and the copper content is below 85 percent in brass or a copper alloy, the filler metals that are less noble on the electromotive series of metals will corrode away leaving a metal that looks something like a sponge under a microscope.
When the filler metals oxidize or corrode they will leave a white or green chalky substance on the surface of the brass or copper alloy. This corrosion of the less noble metals in the brass or copper alloy is known as dezincification. When the filler metals corrode away, the remaining metal becomes brittle and is often the source of a leak or break in a fitting or valve. This has been the subject of many litigation cases over the years related to dezincification of brass or copper alloy fittings with high percentages of filler metals imported from overseas. Valves and fittings for use with copper or PEX piping should have at least 85 percent copper to be corrosion resistant for plumbing systems. Design professionals should specify copper alloy valves and fittings with at least 85 percent copper.
Another code change dealt with the definitions of “public” and “private” plumbing fixtures. The definitions were simplified as part of an effort to allow cold water only for some lavatories. The companion changes to eliminate hot water at public lavatories were successful as long as the cold water is above 60 F. This particular code change may face some opposition at the commentary hearings in Virginia this fall if someone submits a comment.
There was another code change that added an exception under section 403.1.1 fixture calculations, exception #2 states:
“Where multi-user facilities are designed to serve all genders, the minimum fixture count shall be calculated 100 percent, based on total occupant load. In such multi-user user facilities, each fixture type shall be in accordance with ICC A117.1 and each urinal that is provided shall be located in a stall.”
One of the code changes that was unsuccessful was in section 411.2 waste connections for emergency fixtures. There was a change proposed to eliminate the text that read “waste connections shall not be required” and language was proposed to require floor drains of an adequate size and capacity for emergency showers and eyewashes and eye/face washes. There was also an exception that allowed the elimination of the waste connections or floor drain if the code official determines that the flushing fluid will not cause structural damage and that there will be no spread of chemicals or contaminants in runoff. This is typically done by installing a curb around the chemical storage and use areas. With the current code language not requiring drains for emergency fixtures, it makes performing maintenance and doing the weekly flushing that is required by the standards very difficult and expensive. When emergency fixtures are not flushed on a weekly basis, the water becomes stagnant and it loses its water treatment chemicals that fight bacteria. In addition, many emergency fixtures are made of galvanized pipe, and water sitting in galvanized pipes for long periods of time oxidizes and turns a rusty orange color. This is not a good situation if a factory worker or chemical plant worker is injured on the job and rushes to an emergency fixture and stagnant bacteria laden rusty water is flushed onto their injuries or in their eyes.
A code change to Section 501.2 was approved; it requires a heat exchanger to separate the heating hot water from the domestic hot water in combined systems. This was approved because the heating hot water circuit can sit idle in a combined system for eight or nine months of the year in southern climates. This condition causes water to become stagnant when the thermostat does not call for heat on that circuit. When the thermostat finally calls for heat, the stagnant water in the piping and coil, which does not contain corrosion inhibitors or biocides, will dose the hot water tank with elevated levels of bacteria and stagnant water. This has led to many incidents of Legionella outbreaks and scald incidents associated with these types of combined systems with potable water in the heating coils. There have also been many incidents of scald injuries associated with these types of systems. Combined systems operate at different temperatures and are very difficult to set up and maintain without causing scalding hazards or Legionella growth hazards.
A code change was submitted for paragraph 604.3.1 to add a section titled: “System design for building water safety.” It would have required the design of water distribution systems to comply with ASHRAE standard 188: Legionellosis: Risk Management for Building Water Systems.
There were several code changes during the international codes proposing to add the ASHRAE 188 standard. All of the code changes dealing with ASHRAE 188 were disapproved despite quite a bit of emotional testimony in support by many code officials who had attended a Legionella seminar put on by Dr. Janet Stout prior to the code hearings. In the end, the code change was disapproved with comments about the standard covering many areas where it would be difficult for the code official to enforce.
There were also the usual water conservation code change proposals that have been submitted during every code change cycle since the water conservation movement began. Most of these code change proposals were turned down with discussion about problems associated with drain line transport at current flow rates; aging water issues allowing bacteria to grow; difficulty controlling hot water temperatures at lower flow rates; and ongoing research by several universities studying the effects of water conservation and how lower flows are allowing water treatment chemicals to dissipate causing bacteria growth and water quality issues in utility water mains.
Another code change proposal was to eliminate all galvanized pipe and fittings from the tables for water distribution pipe and fittings. The code change was unsuccessful, but I’m sure it will be brought up in future proposals. There have been many new projects including hospitals where galvanized pipe was installed in pipe sizes as small as 2-1/2 inches including in the domestic hot water system as part of a “design-build” process where contractors try to squeeze as much money out of a project budget as they can.
Galvanized pipe and fittings are an approved material for water distribution piping and fittings in the code, yet I cannot think of a good reason why anyone would use galvanized piping in a potable water distribution system. Galvanized piping will begin to corrode soon after it is installed, and it will produce orange and brown water in a relatively new building. The many stories I have heard about galvanized piping working fine for long periods is because the galvanized pipe is coated with layers of calcium and scale that isolates the rust from the water. In new systems, there is no coating on the pipe. With the increased use of water treatment chemicals, galvanized piping has been corroding at alarming rates. Galvanized piping is still an acceptable material for other process and non-potable water systems.
To compound the situation, all hospitals and health care facilities have been required by the recent directive by the Center for Medicare and Medicaid Services (CMS), which has required all health care facilities receiving Medicare and Medicaid money to comply with ASHRAE 188 and have a water management plan or program for the facility. These water management plans often lead to the introduction of secondary water treatment chemicals at levels that can be very corrosive to the plumbing system, especially if emergency chemical disinfection is done after a positive test for Legionella bacteria.
In section 607.1, a code change that proposed to eliminate hot water at public hand washing facilities was successful. The proposal was “approved as modified.” The proposed change adds an exception that does not require hot water for public lavatories or handwashing facilities. The section is now tentatively approved as follows:
607.1 Where required. In residential and nonresidential occupancies, hot water or tempered water shall be supplied to plumbing fixtures and equipment utilized for bathing, washing, culinary purposes, cleansing, laundry or building maintenance.
Exception: Water having a temperature between 60 F (16 C) and 120 F (49 C) shall be supplied for hand washing to public toilet facilities.
The proponent stated he can now eliminate hot water in all public restrooms when the cold water is above 60 F. I find that the cold water drops below 60 F in many areas. I have done testing with 60 F water with my hands when trying to determine what the minimum temperature for an emergency shower and eye/facewash fixture should be. I can tell you from experience, that at 60 F the joints in your hands and fingers will be in pain. There’s not many locations in the U.S. where the cold water stays above 60 F in the winter months.
There were many similar changes to the Uniform Plumbing Codes (UPC). I will attempt to cover the proposed changes to the UPC in a future issue.
Ron George, CPD, is president of Plumb-Tech Design & Consulting Services LLC. Visit Plumb-TechLLC.com.