Update on Code Standard Activities
A recap of recent changes and announcements in the world of codes.
All of the hearings are completed for the International Codes published by the International Code Council (ICC), with the final administrative process now taking place in order to publish the 2018 codes sometime in 2017. The schedule for the publication was developed to allow municipalities to receive copies of the codes in 2017 with time for state and local code committees to review before adopting them in state statutes or local ordinances that have the effect of giving codes the force of law.
The International Codes are a family of many codes that are designed to reference each other and work together in harmony to provide a safe built environment. As the number of codes increased, the hearings grew in length to well over two weeks, with multiple tracks taking place simultaneously. A few years ago, an effort was made to streamline the process. A committee suggested splitting the codes into three different groups in order to hold separate hearings each year for groups in the three-year code change process. The three groups were titled Group A, Group B and Group C.
I talked with many people at the recent ASHRAE meetings in Las Vegas, and many from the plumbing industry were not happy with what was happening in the 189.1 standard. I asked what their concerns were, and they relayed that the people in the 189.1 meetings were trying to make extreme water and energy conservation mandatory instead of voluntary.
Extreme water conservation is not needed in all parts of the country. One person said that there is a more of a focus on water and energy conservation and less of a focus on health and safety concerns. Several people told me they were worried that water flows will be so low that they will almost guarantee stagnant water and higher bacteria counts in the potable water supply. They worry about the dissipation of water treatment chemicals over time caused by conservation efforts and water reuse efforts.
In addition, there were concerns about drain line transport of solids associated with water use reductions. Others reminded us of extreme water shortages in some areas of the country. The two sides of an emotionally-charged discussion reminded me of some of the recent political discussion debates. I think it would be a good idea to restrict further development in areas that have development that exceeds the water resources for the area.
Each side has a passion for what it is doing. It seems many energy and water conservation folks do not understand plumbing system design principles and the hydraulics, flow velocities, cross connection and health and safety issues associated with the energy saving “water conservation limbo” they are playing. At some point the bar will be too low for anyone to pass under. In other words, the plumbing systems will not work.
One friend said jokingly, “But think of all the water we are saving.” He then described some of the proposals for saving water that were promoted by some energy and water conservation proponents in the 189.1 standard. I told him I have heard the same or similar proposals at the model code hearings, and there are three things we need to be cautious of when dealing with water conservation beyond the current water conservation limits. They are:
1. Poor drain line transport of solids (you need enough water in the river to float the boats).
2. Poor water quality. As water flows are reduced and alternate water sources are used for flushing, the flows in water mains that must remain large for fire flow purposes are being reduced to the point where the water is flowing so slow, the treatment chemicals dissipate to levels that are ineffective at fighting bacteria like Legionella and organic pathogens in the building water supply, and, moreso in the building water distribution piping. This is called water age, aging water or stagnant water. The longer the water resides in the water main from the treatment plant, the chemicals dissipate.
One possible solution would be for water utilities to look at installing chemical treatment monitoring stations and chemical injection pumps in locations where booster pumps are located throughout water utility distribution systems.
NOTE: We in the U.S. should also look at the need for mandating water treatment chemical monitoring and chemical treatment/injection pumps at all building service entrances for critical facilities like public buildings, hospitals, nursing homes, hotels and any other facility with an at risk population. The state of Wisconsin did this recently, and I think it is a good idea considering the significantly reduced water flows at fixtures.
3. The risk of scalding. Scalding risk increases with reduced water flows to showerheads in systems with older non-compensating type fixture supply fittings or in systems with hard water. Pressure disturbances in water systems will cause drastic changes in temperatures in fixtures with flow-restrictor showerheads and two-handle shower valves.
Normally, changes to the IgCC would have been considered as Group C code changes and would not start until the third year of the ICC code development cycle, which would have been in 2017. However, due to the merger, a comparison between IgCC and ASHRAE 189.1 has already been made, and proposed changes to ASHRAE 189.1 based upon existing provisions of the 2015 IgCC have been submitted. These proposed changes are currently under consideration by the ASHRAE 189.1 committee. These activities will continue through 2016 and 2017.
The feedback to the code development process will be compiled into a report, which will be posted soon. The final results should be published on the ICC website at www.iccsafe.org.
ASME to drop plumbing standards — ASME A112 Standards Committee on Plumbing Materials Equipment Project team meetings and Main committee meetings January 2017
ASME and CSA had a joint meeting to go over harmonized standards as part of a continuing harmonization effort. At the beginning of the meetings ASME staff announced that ASME Board of Directors had evaluated all of their market sectors and decided to focus on the high-tech industry, robotics and nanotechnology, and in doing so they decided not to continue supporting the A112 Plumbing Materials and Equipment Committee.
They announced this would be the last meeting of the ASME A112 committee sponsored by ASME. It is their goal to transfer the ASME A112 Plumbing Standards to another standards developer, and then ASME staff will be reassigned to new market sector areas.
They are currently working with two standards development organizations with their attorneys looking at the issues with transferring these standards. CSA has labs, and ICC has a strong presence in the codes, and they have a standards development branch.
The new standards will likely have an acronym of ANSI-ICC/CSA A112 xxxx or ANSI-CSA/ICC A112 xxxx.
This will require a code change to be submitted to accept a change of updated standard numbers in the model codes when this process is complete, which might able to be done on one large administrative code change.
After the announcement, several people spoke up and stated they were not happy with the way the ASME handled the dropping of A112 standards, and that no prior discussions were held with the committee or potential standards developers currently on the committee. Others said there should at least have been a request for proposal put out to current standards developers to bid on taking over the ASME standards. The attorneys are working out the details, and the committee will continue operating as it has been with the exception that the standards designation will change.
Hot water at the ASHRAE meeting
I attended the ASHRAE meeting Jan. 27-Feb. 1 in Las Vegas and participated in the ASHRAE TC 6.6 Technical Committee on Service Water Heating, the ASHRAE 188 Standard meeting for Legionellosis: Risk Management for Building Water Systems, The ASHRAE Guideline 12 committee meeting Control of Legionella in Building Water Systems and the TC 3.6 meeting on Water Treatment. TC 3.6, TC 6.6 and ASHRAE 188 committees will all be supporting a research request to study hot water temperatures to prevent Legionella bacteria growth and scalding.
I mentioned to these committees that this research project was not to perform actual laboratory research, but that is was using existing research to cherry pick reports and information. I said we already know the temperatures that hot water systems should be stored at from a white paper and prior research, which was done by ASPE Research Foundation in 1988, recommending storing hot water between 135 F to 140 F to control Legionella Bacteria growth and delivering the hot water at no more than 120 F to prevent scalding. There was also ASPE Research Foundation funded research done at the University of Wisconsin studying hot water usage temperatures and hot water temperatures to control Legionella and scalding. My concern is some people may cherry pick the available data to achieve results that are favorable to their argument to increase allowable cold water temperatures and decrease allowable hot water temperatures for Legionella bacteria growth and also increase the recommended hot water temperature flowing from fixtures up to higher temperatures.
One of the proponents of the new research project has indicated he wanted to raise the hot water temperature allowed at showers and bathtubs to 130 F so he could set the water heater temperature at 130 F and meet both Legionella control and scalding provisions without using mixing valves. He also submitted code change proposals with 130 F limits for showers and bathtubs that were turned down unanimously at last year’s code hearings. The proponent said, “mixing valves fail because no one maintains them” so he does not want to use them. The problem with this thinking is some types of storage water heaters can see drastic temperature swings, and temperature control in the system would not be possible for both Legionella and scald prevention. Hot water distribution systems commonly see temperature losses greater than 20 F across the supply and return system, and there is no magical one temperature that will work throughout the entire system.
I say tires on your car will fail if you don’t rotate them regularly and buy new ones when the manufacturer recommends replacement. The same will happen with the motor, if the radiator runs low on water, it will eventually fail if you never check or add water, or if you never change or fill the oil, oil filter or air filter. Maintenance is required for any mechanical system to function properly.
Mixing valves must be inspected annually or as required by the manufacturers maintenance instructions and as dictated by the water quality of the installations. During the inspection, if the valve is calcified it should have the thermal motor or cartridge removed and placed in a bowl of warm vinegar water to dissolve the scale and mineral build-up. If the thermal motor is defective or too scaled up, then it should be replaced.
If you don’t want to change the tires, or the oil on your car, then you can always just drive it until the tires or the motor blows up. We should promote proactive preventative maintenance instead of reactive maintenance in a crisis situation.
Developing a report based on existing data and changing the results will not reduce the number of scald or Legionella incidents, it will just muddy the waters. If research is to be done, the research should be to determine what happens to Legionella bacteria at different temperatures and what happens in scald burn incidents at different temperatures. Anything else is just cherry picking the results of past research.
Ron George, CPD, is president of Plumb-Tech Design & Consulting Services LLC. Visit www.plumb-techllc.com.