Water heater permits and inspections, Part 1

Due to the length of this article, it will be published in two parts. Part one will cover why we need permits. Next month, part two will cover the actual inspection process for water heaters.

Why do we need permits for the installation or replacement of a water heater? I have been asked this question on many occasions. The simple answer is the permit is required so that an inspection can be done to make sure the water heater is installed properly, and that it does not create a hazard to the building occupants. A water heater is one of the most dangerous appliances in a building, and there are many things that can go wrong if a water heater is replaced and there is an error in the installation. This article will cover what things can go wrong and why permits and inspections are important.

The question is always asked, “Do you need a permit for an inspection if you replace an existing water heater?”

The answer is most likely, “Yes, a permit is required.”

Licensed and qualified persons

Over the past 36 years, I have crossed paths with a lot of people in building maintenance positions that were not trained or qualified for their jobs. It’s sad, because there are lots of qualified people out there. I’m guessing pay scale may have something to do with why properly trained and licensed people are not hired. Following are a couple of examples of unlicensed and unqualified people I have met. The names are left out of these stories, but the circumstances are similar in many instances.

Some time ago, I was inspecting the mechanical systems in a building where someone was scalded and I noticed a recent manufacturing date on the water heater that was located in an older building. I asked the maintenance guy that was showing us around if they had recently replaced the water heaters in the building. He then took a step back, his eyes got big and he looked at the shiny new water heater then looked back at me and said, “Yeah, it's new.”

I noticed it was an atmospheric combustion water heater and the flue was directly connected to the top of the water heater. The shiny new flue sloped down a couple of inches where it tied into the old flue vent connection. Apparently, the old water heater was shorter, so they got rid of that pesky draft hood. It was still a couple of inches higher than the old flue connection, so they sloped the flue downward to the connection. The discharge pipe from the temperature and pressure relief valve went up to the ceiling and across to the outside wall. Through the outside wall, there were no dielectric unions and no thermal expansion tank, and there was about 20 feet of 3/8 inch soft copper tubing coiled around a few times in a loop for the gas supply connection, which had no dirt leg.

The list of installation issues went on and on. I asked if he knew if there was a permit for the installation of the water heater. The maintenance guy seemed a little agitated with my questions, and he said, “Dude, it’s just a hot water tank. It ain’t rocket science. A permit is just a way for the city to get your money.”

I was immediately reminded of the “MythBusters” episode where co-hosts Adam and Jamie intentionally plugged off the relief valve and caused a water heater to explode. Of course, the water heater took off and shot 600 feet up in the air when the bottom blew out. So, I thought to myself, "Yeah, it is kind of like rocket science.”

I decided that I did not want to push the issue any further with this guy, because I had come to realize that it is people like him that the permitting and inspection process is protecting all of us from. It was becoming obvious that maybe he had installed this water heater himself, and I had already noticed several serious issues with the installation. I decided to just communicate, take notes and put it in my report, rather than get into a futile discussion about why he should have followed the laws and codes. I did notify the building owner of the hazards associated with hot water before I left. It turned out that the maintenance man was a handyman, and he had, in fact, been pretty handy with lots of plumbing and electrical work that he was apparently not licensed or trained to do. I couldn't help but think every dollar the owner saved by not hiring a licensed and properly trained contractor, was probably going to be spent in litigation after one of the many installation flaws caused an accident. I thought, somberly, that perhaps a child would be scalded and would have to deal with her injuries for the rest of her life.

Promotions

On several occasions, I have found that property owners promote people to positions and do not provide proper training for them in their new positions. There was a case where a hospital had promoted a janitor to the position of maintaining the mechanical systems. That didn’t end well for the mechanical systems, which were ruined by lack of proper maintenance.

There was another case where the attorneys were deposing a man who was the director of facilities engineering for a large complex that included multiple buildings and many millions of square feet, with about 10 high rise buildings. It also had a power plant with chillers, boilers, cooling towers, cogeneration facilities and lots of other specialty and heat recovery systems. It was a very sophisticated residential/commercial/retail/entertainment complex. They had a problem at the facility that caused many people to become sick, and there was a multi-million dollar lawsuit in process.

During the deposition, the director of facilities engineering was asked about his education and training. They asked questions about where he went to college, and if he was a graduate engineer. Was he a professional engineer? Was he certified to operate facilities or a power plant? Did he have any certifications or training at all related to facilities operation? Any college degrees at all? His answer to all of the questions was, “No.”

They asked if any of his people were licensed plumbers or licensed electricians. He did not know if any were or not. During the line of questioning, they asked him to describe his work history. He started with how his first job was as a golf caddy at a country club. At some point, he moved over to the grounds maintenance crew at the country club. While performing grounds maintenance at the country club, he met a person that was in management and part owner of a large corporation that owned lots of buildings. He was invited to come work for the large corporation in the grounds maintenance department. He took the job and worked with a staff of dozens of grounds maintenance and landscape workers. After a few years working in the grounds maintenance department for the large complex, he was promoted to head of the grounds maintenance department and he worked alongside the director of facilities maintenance and engineering. He would attend in-house management meetings with the owners, other managers and the director of facilities engineering. A few years later the director of facilities engineering retired and they asked him if he wanted to move over to take over the position of director of facility maintenance. When the attorneys inquired why they asked him to take that position, it was apparently because the owners knew him, and they were used to seeing him in the management meetings. And, they played golf together.

Shortly after assuming his new position, the large corporation decided to build a newer, larger entertainment complex, and he was asked to participate in the meetings for the planning and design of the complex. When the complex was completed, he became thedirector of facilities engineering. This former golf caddy was now in charge of a new complex of buildings with sophisticated engineered systems, and worth billions of dollars. He seemed to rely heavily on what the sales representatives that called on him would tell him needed to be done in the facility. He seemed to have inherited a job that he was not trained or equipped to deal with. The man did not seem to understand how a chiller or boiler or cogeneration plant worked, but he and his staff were now in charge of operating, maintaining and controlling them. He had an army of hundreds of facilities and maintenance workers under him, and many were certified to deal with the systems that needed certifications (boiler operators, etc.). But no one on his staff was an engineer, and no one was a licensed plumber or electrician.

This situation makes me think about the Russian comedian, Yakov Smirnoff, who used to say, “What a country!”

Everything is possible here.

Many people associated with this case wondered how this could have happened, but it did. Sometimes it seems like it is who you know, not what you know. It did not look good for the owners of the building when it came out that their director of facilities was not properly trained or qualified for the job he had, and his lack of knowledge of the systems he was responsible for maintaining likely contributed to the illnesses that had occurred to so many people.

Maintenance

It seems everyone wants to build something grand, but no one wants to spend the money to maintain it the way it should be maintained. Maintenance is an important part of the life cycle costs of a building. If you do not maintain a building and its systems, the cost to repair the systems when they break can be significantly more. In addition, there can be damages to the building and contents if the manager waits for something to break and leak before trying to repair it. This management style can lead to injuries and property damage, and is often called “management by crisis.” What we should strive for is “preventative maintenance,” where equipment is maintained on a planned schedule. This includes replacing filters, blowing down boilers, water heaters, strainers, oiling bearings, and checking, recording and maintaining temperatures.

Permits

The reason why there should be a permit required for the installation or replacement of a water heater is that there are many things that can go wrong with a water heater installation. The dangers can include: scalding, legionella bacteria growth, fuel gas leaks, ignition sources, fires, explosions, water leak damage/mold, structural stability and carbon monoxide asphyxiation. If someone who is not properly trained and licensed installs a water heater, there is a chance of making a mistake that can create a dangerous or hazardous condition. Without a permit and inspection, it is easy to overlook something, and people could be injured or killed.

Most codes or ordinances allow a homeowner to install their own water heater, and some jurisdictions allow unlicensed individuals to install water heaters, but they still must pull a permit and have it inspected for safety. Other than a homeowner and a few exceptions in a few jurisdictions, whoever installs a water heater is required to be a licensed master plumber, a licensed mechanical contractor or licensed gas fitter. Typically, all of these trades are cross-trained in most of the safety issues associated with fuel gas fired water heaters.

The permit is actually an application for an inspection that allows a plumbing inspector to look at the installation to make sure it was installed properly. It helps ensure that the homeowner or installer has not inadvertently created a bomb by doing something like putting a plug in the water heater tank opening for the temperature and pressure relief valve, or creating a fire hazard by incorrectly connecting the gas piping. For a refresher, please see the "MythBusters episode" I mentioned earlier.

When a water heater explodes in a house, the explosion can be equivalent to many sticks of dynamite, and it will usually reduce an entire house to a pile of rubble. A violent steam explosion like this can cause significant damage to adjacent buildings in the area due to the shock wave and blast. This is one reason among many that an inspector needs to protect everyone from improperly installed water heaters.

Inspections

Because of all of the dangers listed above, water heaters are a considerable safety risk, and they need to be inspected to assure all of the above issues are addressed by the installer of the water heater. The way we protect the public is through model codes and/or local ordinances, which require a permit for an inspection. Jurisdictions that do not require licensing, permits or inspections should consider the safety of the public and consider mandating these things.

Water heater life expectancy

The average water heater should last anywhere from 11 to 15 years. There are water heaters that will last a long time, because they are installed in good water quality areas, and are maintained regularly with the replacement of anode rods. Then there are water heaters installed in areas with hard water that are lucky to survive three to five years without a water softener to remove the minerals from the hard water. Hard water can lead to a buildup of scale and minerals on heating surfaces, similar to food sticking to the bottom of a pan on the stove.

This buildup of scale and minerals insulates the water from the heating surface, and it will lead to stress in the structure of the water heater from longer burner cycles and higher temperatures on the heat exchanger surfaces. It also shows up as higher temperatures in the flue gasses. One water heater company used to sell an efficiency indicator temperature gauge in the outlet flue of a water heater. As the heater scaled up, the efficiency of the heater went down, as the combustion gasses went up the flue instead of into the water. This condition can lead to melted or cracked plastic flue pipes.

Replacement water heaters

I investigate many scald incidents every year, and I find a significant number of them seem to have a recurring theme. Many of the scald incidents occur shortly after a water heater has been replaced or the hot water system temperature has been adjusted because of a call associated with no hot water. In many of these cases, the thermostat on the water heater is set to a higher temperature than the water heater that it replaced. I hear lots of discussion about turning down the thermostat on the water heater to prevent scalding. Using the thermostat on the water heater to control the final hot water temperature is not allowed by most codes because the thermostat on the water heater cannot accurately control the outlet temperature of a water heater.

In most scald incidents, the water flowing from the fixture involved in the scald incident is higher than 120°F. It is not uncommon to see hot water temperatures well in excess of 160°F in some scald cases. Water temperatures over 120°F should be considered a scalding hazard. As for existing buildings with non-code compliant fixtures, we as a society need to place more emphasis on safety with respect to scalding. We have the technology to completely prevent scalding, yet we still allow systems to exist where people are at risk of being injured or killed by scalding hot water. An education effort is needed to deal with this issue. Engineers should design and write commissioning specifications for installations with this in mind. Contractors and plumbers should check to make sure the hot water temperatures are not dangerously hot. Inspectors should check, or at least spot check, a few fixtures to assure all fixtures have the limit stops or thermostatic mixing valves adjusted to limit the hot water to 120°F or less.

Familiarity with the controls

In many scald cases, I find the injured party is unfamiliar with the controls, or they are a child, an elderly person or a person who is in some way handicapped. Children, the elderly and handicapped persons are most at risk for being scalded. This is because they are groups of people that can easily be confused. They may not be able to figure out how to readjust the controls or they may have difficulty getting out of harm’s way if the water suddenly gets hot.

Often, when investigating a scald incident, I find the manufacturing date on the water heater is rather recent and the shower or bathtub/shower controls are not pressure compensating, temperature compensating or combination pressure and temperature compensating controls with adjustable maximum temperature limit stops. In other words, they are not code compliant. There should be a permit for water heater installation, which triggers an inspection by the authorities having jurisdiction. If there is an inspection of a replacement water heater, the inspector and the installer should wait until the water heater burner cycles off and check the hot water temperatures flowing from various fixtures to assure that temperatures do not exceed the limits mentioned in the codes. After a scald incident, I often find that the local jurisdiction has no records of permits/inspections for a new water heater installation.

The reason why there should be a permit for the installation or replacement of a water heater is that an inspection should be required to make sure the water heater is installed correctly and that the dangers associated with scalding, legionella bacteria growth, fuel gas leaks, ignition sources, fires, explosions, water leak damage/mold, structural stability and carbon monoxide asphyxiation can be addressed. In part 2, we will cover how to properly inspect a water heater. The inspection could also be part of a commissioning process. 

Ron George, CPD, is president of Plumb-Tech Design & Consulting Services LLC. Visit www.Plumb-TechLLC.com.

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