Uniform Plumbing Code hearings take place in Denver, Colorado

By the time you read this, the Uniform Plumbing Code (UPC) Technical Committee meeting will be under way or just concluding in Denver, Colorado.  The code hearings are scheduled for May 2-6. You should still be able to go the IAPMO website to see the proposed UPC changes: http://codes.iapmo.org.

This year, there are 350 code change proposals to the UPC. The average code change proposal takes about eight to 10 minutes to hear. So, based on the large number of code changes for plumbing it will may take over three long days just to cover the plumbing code hearings. This year, the standards task group discussed adding various standards to the body of the code. The UPC, in the past, has listed all the standards in the back of the code. This proved to be cumbersome when trying to enforce the code because there could be several standards listed in the back of the code that could apply, and there was no guidance as to which one applied in a given application without specifically addressing it in the body of the code.  

For example, there were standards for ASSE 1016 shower valves, ASSE 1017 temperature actuated mixing valves for hot water distribution systems, ASSE 1070 temperature limiting valves, ASSE 1071 temperature limiting valves for emergency fixtures and ASSE temperature limiting valves for gang showers. In addition, ASSE had standards for ASSE 1066 pressure balancing devices and ASSE 1062 temperature activated flow reduction valves.

Without the standard listed in the body of the code with the applications where the products were intended to be used, it was difficult for contractors and inspectors to determine if the correct device was installed in a given location. The same went for approved piping materials; there were a lot of standards, but determining which one applies was difficult in the past. The standards task group has proposed many code changes to address these types of issues.  
There was a group of outspoken individuals at the code hearings that did not want to include standards in the body of the codes. Their reason was they did not want to have to learn the alphabet soup of standard numbers, letters and names, and they did not want to buy all those books. I can’t blame them for wanting to keep it simple. Following is a review of a few of the notable code change proposals on the UPC hearing agenda.

UPC item #004

One of the early code changes was to remove the word “plumbing” in many places where the code addresses “plumbing systems.” This is because the UPC covers many types of plumbing and piping systems including those piping systems for: plumbing (water supply and drainage), fuel gas, medical gas, vacuum, combustion flue vents, firestopping systems, firefighter breathing air replenishment systems, etc. The proposal intends to update the language so the plumbing code will address all of these systems, not just the items defined as “plumbing.”  

UPC item #011

There is a code change to eliminate the definition for hot water and replace it with nine different terms each representing a different temperature range of hot water. The proposed terms are: heated water temperature, cold water, disinfecting hot water, hot water, tempered hot water, tepid cold water, tepid water, very hot water and warm water. Each of these terms is proposed to have a specific defined temperature range.

This code change appears to be doomed from the beginning because it has so many conflicting terms and temperatures. Currently tepid water is defined in the emergency fixture standards as a different temperature range than the tepid water temperature in this proposal. The tepid cold water is hotter than warm water so that would further create confusion. It appears the proponent wants to mandate temperatures out of convenience by using a term to mean a temperature range for purposes of controlling Legionella bacteria growth. It would seem more appropriate to state a temperature range to avoid in order to prevent the growth of Legionella bacteria. I am going to go out on a pretty sturdy limb and predicting this code change will have a difficult uphill battle.

UPC item #021

In UPC section 301.3 Alternate Materials and Methods of Construction Equivalency a code change is being submitted to require the design professional to provide technical documentation to the code official prior to the installation to show equivalency for the quality, strength, fire resistance, effectiveness, durability and safety of the proposed alternate design over what is required in the plumbing code. 

This is already a requirement in the code. The code change is just requiring that the documentation be submitted prior to the installation. The code change has a pretty good chance of passing.

UPC item #022

UPC section 301.5.6 Inspection and Testing is proposed to be modified to add text as follows. The alternative engineered design shall be tested and inspected in accordance with the submitted testing and inspection plan and the requirements of this code. Prior to the final plumbing inspection, the registered design professional shall provide written certification to the Authority Having Jurisdiction that the system has been visually inspected by the registered design professional or the registered design professional’s designee, and the installation has been properly implemented according to the certified plans, calculations and specifications. This proposed addition is intended to make sure the design professional or designee inspects the installation.

There are numerous code changes by the IAPMO Standards Task Group where they are standardizing the language and references to standards and other documents in the UPC. The intent was to provide consistent language when referencing standards in the body of the code. I would like to see instructions for code change submittals to help future code change submittal proponents have consistent language in the code change proposals.

UPC item #035

The American Society of Plumbing Engineers (ASPE) Legislative Committee submitted a code change, through its representative Cyril Unger, to delete a code section addressing the quality of fixtures. The language is no longer needed with the proposed addition of standards to the body of the UPC.

UPC item #049

The Natural Resources Defense Council has proposed additional flow reductions for lavatories from 2.2 gallons per minute down to 1.5 gallons per minute. I applaud their efforts, but again I am not in favor of any water use reductions without technical support for what the effect will be on drain line transport and water quality.

 As water flows are reduced, chlorine dissipates down to levels that are ineffective at fighting Legionella bacteria. A recent study was commissioned by the EPA to study the effects of water conservation efforts on water quality in municipal water distribution systems. I say health and safety trumps water and energy conservation! I would rather have a moderate amount of good clean quality water than a trickle of stale, contaminated water full of bacteria and other organic pathogens. 

UPC item #054

There is a code change from a person wanting to eliminate the prohibition of using the thermostat on the water heater for controlling the hot water system temperature. The person has stated they are aware of a water heater manufacturer that can accurately control the outlet temperature of the water heater the prevent scalding. So, the person wants to eliminate this safety provision that is there to prevent scald injuries so a water heater manufacturer can install their water heater without any system temperature control limitations.  

There is an ASSE #1082 standard in development that will address water heater temperature controls to limit hot water temperatures. The details of the standard are yet to be developed, but the intent appears to be for tankless water heater manufacturers to be able to limit the hot water temperature with controls on the water heater and have an exception for this code provision. Some manufacturers have expressed a desire to have their units be equal to the temperature limits outlined in the ASSE 1070 temperature limiting valves standard. 

This code change is ahead of its time. The problem is, all water heaters cannot control the outlet temperature with the water heater thermostat because of stacking and thermal layering in uncirculated hot water tanks. This creates a serious scald hazard and this is why the language prohibiting the water heater thermostat to be used for complying with scald prevention provisions in the code is there. The ASSE Scald Awareness Committee has published a white paper covering the inability of water heater thermostats to control the outlet temperature of the water heater. For more info go to: www.asse-plumbing.org.

UPC item #054

This is another code change by the proponent that is a companion code change. The intent of this code change is to raise the allowable maximum temperature at showers, bathtubs and lavatories to 130 F from 120 F.  The reasoning behind this is to be able to set the water heater thermostat at 130 F and control Legionella bacteria growth. There have been numerous publications calling for storage of hot water at about 135-140 F to control Legionella bacteria and then use temperature control valves to reduce system temperatures for distribution at a lower temperature. The maximum temperature limit stops on code compliant shower valves can be set to deliver water at a safe temperature with water temperatures above 124 F delivered to the shower valve.  

The proponent has been promoting using the water heater thermostat to control system water temperatures. In their  experience, thermostatic mixing valves failed and never got maintained. The failure and maintenance issues were presented as reasons for not using them. Tires can go flat on a car, but I’m not going to throw away the tires and drive on the rims. You need to maintain mixing valves just like you would rotate your tires and replace them when they are worn. 

Many people and organizations have reviewed the burn studies performed by Dr. Moritz and Dr. Henrique at Harvard Medical School. Their research was done on soldiers and baby pigs with skin thicknesses similar to that of adult males in order to determine the time verses temperature relationships with respect to burn injuries. For example, at 120 F it takes five to eight minutes to receive a serious irreversible burn injury. At 130 F it takes about 25-30 seconds to receive a serious irreversible burn injury. Elderly, handicapped, and young persons would have difficulty getting out of harm’s way in time to prevent serious burn injuries. With a storage type water heater set at 130 F, the outlet temperature can easily reach 160 F with stacking and thermal layering.  

Approving this code change would cause thousands of additional scald burn injuries every year. The ASSE Scald Awareness Committee reviewed this code change, along with item #054 and item #01,1 at one of their conference calls and concluded these were not good code changes. 

Ron George, CPD, is president of Plumb-Tech Design & Consulting Services LLC. He can be reached at: office 734-322-0225; 755-1908; and website Plumb-TechLLC.com.

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