Item # 3 Comment Seq # 1 UPC , Air Admittance Valves SUBMITTER: Jack Beuschel Studor, Inc

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1 Item # 3 Comment Seq # 1 UPC , Air Admittance Valves SUBMITTER: Jack Beuschel Studor, Inc Add new text as follows: Air Admittance Valves - One-way valves designed to allow air to enter the plumbing drainage system when negative pressures develop in the piping system. The device shall close by gravity and seal the vent terminal at zero differential pressure (no flow conditions) and under positive internal pressures. The purpose of an air admittance valve is to provide a method of allowing air to enter the plumbing drainage system to prevent siphonage of plumbing fixture traps. In plumbing installations it has been necessary to extend vent pipes to the atmosphere. This has resulted in problems relating to extensive vent piping, roof penetrations requiring vent pipe flashings that eventually leak, floor penetrations requiring fire-stopping devices, weakening of building frames, and frost closures as well as pollution of the environment and indoor air by sewer gas. Air admittance valves (AAVs) can resolve problems since they permit a relatively easier solution than venting to the atmosphere. Since there are less open pipes, the possibility of water entering the building through vent pipe roof flashings is substantially reduced. The AAV opens under negative pressure conditions allowing air to enter the DWV system preventing siphonage of the water trap. The valve closes by gravity under neutral and positive pressure, preventing the escape of sewer gas. It operates by means of a pressure/gravity-activated sealing assembly that acts as a one-way valve. Positive pressure will find relief through the open pipe relief vent required on the building drain when AAVs are installed. Systems in which AAVs are installed in conjunction with a minimum of one open vent pipe protect fixture traps against siphonage and backpressure, and air circulation is ensured throughout all parts of the system in compliance with the intent of Section of the UPC. Studies have proven that by installing AAVs in the DWV system both positive and negative pressure transients are reduced and better controlled than in an open pipe system. Installation of AAVs has no adverse effect on the operation of the system and provides benefits in terms of trap seal protection under all conditions. AAVs have been installed in Europe since 1972 and in the USA since The valves have been field tested and have proven to be a safe alternative to open pipe vents. The performance standards for AAVs are ASSE 1050 and 1051 and NSF 14. COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Appendix L 9.1 Definition Air Admittance Valves - One-way valves designed to allow air to enter the plumbing drainage system when negative pressures develop in the piping system. The device shall close by gravity and seal the vent terminal at zero differential pressure (no flow conditions) and under positive internal pressures. The purpose of an air admittance valve is to provide a method of allowing air to enter the plumbing drainage system to prevent siphonage of plumbing fixture traps. COMMITTEE STATEMENT: To correlate with committee action taken on Item 239 and the modification moves the definition to Appendix L. 1

2 A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1 (Assembly Action): Submitters: Sarah Aguilar, Southland Industries Bob Adler, City of San Jose Request to reject the code change proposal by this public comment. SUBSTANTIATION (Sarah Aguilar): Listing AAVs in Appendix L does not alleviate duty to ensure that AAVs do not pass a potential health hazard. The State of Minnesota recently commissioned several field studies and reports that demonstrated even properly working AAVs may allow dangerous amounts of sewer gas to enter the living area due to pressure caused by bathroom vent fans. These studies also found that AAVs have an unacceptable failure rate of at least 1.7% and that when they fail sewer gas can escape into the living spaces or work areas. The Technical Committee did not have access to these reports at their April hearing. The AAV Task Group recommended that Technical Committee take the following actions prior to approving AAVs: Demonstrate that air circulation is assured throughout all parts of the venting system equivalent to that required in Section 901 of the Uniform Plumbing Code. Require a review of the effects of backpressure on the sanitary system. Demonstrate that the level of seat fouling in AAVs is sufficiently low to prevent AAV failure as compared to that normally found in a conventional venting system by compiling research data on existing AAV installations. Require that where AAVs are installed the system shall have a pressure test of 1-inch water column by capping the sewer and vent to check for leaks (must hold against positive pressure) and that this test is repeated in 5 year increments. The Technical Committee failed to comply with any of these Task Group Recommendations. SUBSTANTIATION (Bob Adler, City of San Jose): AAVs present numerous problems that may make them inappropriate and unsafe for use. In particular, AAVs are mechanical devices that will eventually wear out and that can and do fail lodged in an open position, which may allow dangerous sewer gases, bugs, and vermin to enter the living area. AAVs also don t relieve positive pressure, allowing sewer gases to enter the living area during positive pressures that can result from sewer gas fluctuations, garbage disposals, washing machines and other sources. This is an unacceptable risk that does not exist with standard vent pipes. The State of Minnesota recently commissioned several field studies and reports that affirmed that even properly functioning AAVs can allow sewer gas to lean into the loving area as the result of positive pressures. These studies also found that AAVs have an unacceptable failure rate of at least 1.7% and that when they fail sewer gas can escape into the living spaces or working areas. As a result, the State of Minnesota has prohibited the installation of AAVs. The Technical Committee did not have access to these reports at their

3 hearing. Technical Committee also did not follow recommendation of AAV Task Group to make specified findings prior to approval of AAVs. For a copy of supporting documentation please contact: Mr. Bob Adler, 200 East Santa Clara, Rm 200, San Jose, CA 95113, Phone (408) PUBLIC COMMENT 2: Submitter: Jack Beuschel, Studor Inc. Request to accept code change proposal as submitted by this public comment. I disagree with the Committee s action to deny Studor s original proposals made in Items 3, 134 and 139 based on the Committee s action on Item 239, which is to include air admittance valves (AAVs) in Appendix L. This action does not constitute a technical reason to deny Studor s original proposals to include AAVs in the body of the UPC. With regard to the explanation of the negatives I would like to comment as follows: AAVs have been installed in Europe since early 1970 and in the USA since There are millions of valves installed; they have been field tested and found to equivalent to open pipe venting systems. The recent study prepared by Dr. Michael Gormley and Prof. John Swaffield titled Building Drainage Waste and Vent Systems: Options for Efficient Pressure Control shows that systems in which AAVs are installed are equivalent to open pipe vented systems in low-rise buildings in terms of trap seal retention and are superior to open pipe systems in high-rise buildings. This study is referenced in Items 134 and 139. During the last 37 years millions of valves have been installed worldwide without any documented evidence that they have created a health hazard or health risk. AAVs are not mechanical since they are not operated by a mechanism (such as a spring or lever). The valves open under negative pressure and close by gravity (both natural forces, not mechanical). DWV systems in which AAVs are installed always have a minimum of one open vent pipe that will relieve any positive pressure that might develop in the system. The states of Wisconsin and Colorado were referenced. It is interesting to note that AAVs were approved in both states in Since then thousands of valves have been installed in those states and they have successfully protected the health of the public. Item # 4 Comment Seq # 2 UPC (New) SUBMITTER: Steven Nastruz Public Health, Seattle and King Co Add new text as follows: Bathroom, Half - A room equipped with a water closet and lavatory. The use of the term half-bathroom is part of Table 5-1 without defining a half-bathroom. Providing the definition in Chapter 2 will provide clarity for Table

4 COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Michael Cudahy, Plastic Pipe and Fitting Association (PPFA) Request to accept the code change proposal as modified by this public comment Bathroom, Half - A room equipped with only a water closet and lavatory. The definition as written includes all bathrooms as Half-Bathrooms. The current UPC definition of bathroom is, A room equipped with a shower or bathtub. Adding only helps restrict the classification. Item # 5 Comment Seq # 3 UPC , Definitions SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Add new text as follows: Chemical Waste - Includes industrial liquid waste, process waste, diluted acid waste, undiluted acid waste, corrosive and non-corrosive chemical liquid waste. There is a need for a clear definition of chemical waste in the code in order for appropriate materials to be used in these types of systems. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The definition is not a true inclusive definition. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting Request to accept the code change proposal as submitted by this public comment. 4

5 There is a need for a clear definition of chemical waste in the code in order for appropriate materials to be used in these types of systems. There is currently no definition of chemical waste in the UPC. The Technical Committee s reason for rejection states that the proposed definition is not inclusive enough. We would respond that this proposed definition uses terms currently used in various sections of the UPC with respect to chemical waste and places them in a relevant definition. We are not opposed to adding wording that is appropriate if the committee could agree on that wording. However, this current proposal is not in conflict with other sections of the UPC and should be added at this time to put together items sometimes referred to as special waste, indirect waste and chemical waste. Item # 7 Comment Seq # 4 UPC Excess Flow Valve SUBMITTER: Bryan Popp Dormont Manufacturing Company Delete text without substitution: Excess Flow Valve A valve designed to close when the fuel gas passing through exceeds a prescribed flow rate. The definition and reference to Excess Flow Valves should be removed from this code until a consensus standard is developed and accepted within the industry. The existing definition is inaccurate, misleading and insufficient to adequately describe the devices and concepts associated excess flow valves. If a definition of excess flow valves is required to be included in this code, then the following language may be more appropriate. EXCESS FLOW VALVE, (EFV): A device installed in a fuel gas piping system to automatically trip when the rate of passage of fuel gas through the device exceeds a predetermined level. EXCESS FLOW VALVE BYPASS, (EFVB): A valve designed to limit the flow of fuel gas after trip of the excess flow valve to a predetermined level and to reset automatically after he pressure is equalized across the valve. EXCESS FLOW VALVE NON-BYPASS, (EFVNB): A valve designed to stop the flow of fuel gas after trip of the excess flow valve and to be reset manually. These definitions match the current draft of ANSI Z21.93 standard that is being developed. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Excess flow valves are used and definition is needed in the code. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Ted Lemoff, NFPA 5

6 Request to accept the code change proposal as modified by this public comment Excess Flow Valve (EFV) A valve designed to close activate when the fuel gas passing through it exceeds a prescribed flow rate. This comment proposes a revision consistent with NFPA The definition is revised to recognize that excess flow valves, of the type used for gas piping systems, do not close completely. They allow a small bypass flow, which is used to reopen the valve. PUBLIC COMMENT 2: Submitter: Bryan Popp, Dormont Manufacturing Company Request to accept the code change proposal as modified by this public comment Excess Flow Valve A valve designed to close when the fuel gas passing through exceeds a prescribed flow rate. EXCESS FLOW VALVE (EFV) A device installed in a fuel gas piping system to automatically trip when the rate of passage of fuel gas through the device exceeds a predetermined level. EXCESS FLOW VALVE BYPASS (EFVB) An excess flow valve bypass is designed to limit the flow of fuel gas after trip of the excess flow valve to a predetermined level and to reset automatically after the pressure is equalized across the valve. EXCESS FLOW VALVE NON-BYPASS (EFVNB) An excess flow valve non-bypass is designed to stop the flow of fuel gas after trip of the excess flow valve and to be reset manually. The committee stated that a definition is needed, however they did not address concerns about the definition being inaccurate, misleading and insufficient to adequately describe the devices and concepts associated with excess flow valves. This comment improves the language of the standard. These definitions match the current draft of ANSI Z21.93 standard that is being developed. Item # 11 Comment Seq # 5 UPC Chapter 2, 218.0, SUBMITTER: Gary Klein California Energy Commission Revise text as follows: 6

7 218.0 Plumbing System Includes all potable water, building supply, and distribution pipes (hot and cold); all plumbing fixtures and traps; all drainage and vent pipes; and all building drains and building sewers, including their respective joints and connections, devices, receptors, and appurtenances within the property lines of the premises and shall include potable water piping, potable water treating or using equipment, medical gas and medical vacuum systems, liquid and fuel gas piping, and water heaters and vents for same Water Supply System The building supply pipe, the hot and cold water-distributing pipes, and the necessary connecting pipes, fittings, control valves, backflow prevention devices, and all appurtenances carrying or supplying potable water in or adjacent to the building or premises. The hot water distribution system is that portion of the water supply system between a water heating device and the hot water consuming plumbing fixtures. Statement of Problem: The purpose of this proposal is to define hot water distribution systems as a subset of potable water distribution systems to facilitate the evaluation of energy consumption and water waste as well as flow and pressure characteristics in their design. There is no intent to define hot water, only that portion of the piping system that distributes it. The California Energy Commission, its supporting research organizations and other collaborators have been investigating the impact of the hot water distribution system s design on the overall energy and water performance of a building s hot water system. While our research and investigations are likely to lead to modifications in the Building Energy Efficiency Standards portion of California s Building Standards Code (Title 24), a number of potential ways to enhance the performance of these systems is influenced or governed by the requirements of plumbing codes including the Uniform Plumbing Code (UPC). Based on our research, the key factor in determining the performance of hot water distribution systems is to design and build them to have the smallest volume of water within that portion of the system between the plumbing fixture and the source of hot water. The length and the internal diameter of the pipe(s) determine the volume of water contained within the distribution system. Systems with the least internal volume waste the least amount of energy and water. They also typically provide hot water to the plumbing fixture with the shortest waiting period typically the most important consideration to the hot water user. Unfortunately, the current plumbing codes do not differentiate between hot and cold potable water piping in the design and installation of a distribution system. Without this differentiation, current hot water distribution systems typically become over-sized while following the guidance provided by plumbing codes. Excessive pipe size has little or no negative water or energy conservation impact on cold water systems but it is a big factor in reducing the performance of hot water distribution systems. Substantiation for Proposal: It is necessary to separately define hot and cold water distribution systems in order to improve the performance of the hot water distribution system. Improvements come in the flow and pressure characteristics of the plumbing, and by the corresponding reductions in water and energy waste. Hot water use represents percent of the total residential energy consumption. The low end of the range is found in colder climate zones and the higher end of the range is found in temperate climates. In many parts of the country, and as overall building energy performance is improved, hot water is the 1st or 2nd largest residential energy use. It also represents a large fraction of the energy consumption in 7

8 commercial food service, which uses almost half of the water heating used in all commercial buildings. Hot water distribution systems characteristics dictated by the UPC directly impact the amount of energy consumed. Therefore it is necessary to distinguish between hot and cold distribution systems so that appropriate hot water systems characteristics can be defined in the UPC. To do this, it is first necessary to provide a definition of a hot water distribution system. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Revisions to definitions are not needed and the current definitions are adequate as hot water is already addressed. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Gary Klein, Affiliated International Management, LLC Request to accept the code change proposal as modified by this public comment Plumbing System Includes all potable water, building supply, and distribution pipes (hot and cold); all plumbing fixtures and traps; all drainage and vent pipes; and all building drains and building sewers, including their respective joints and connections, devices, receptors, and appurtenances within the property lines of the premises and shall include potable water piping, potable water treating or using equipment, medical gas and medical vacuum systems, liquid and fuel gas piping, and water heaters and vents for same Water Supply System The building supply pipe, the water-distributing pipes, and the necessary connecting pipes, fittings, control valves, backflow prevention devices, and all appurtenances carrying or supplying potable water in or adjacent to the building or premises. The hot water distribution system is that portion of the potable water distribution system between a water heating device and the hot water consuming plumbing fixtures. Statement of Problem: The purpose of this proposal is to define hot water distribution systems as a subset of potable water distribution systems to facilitate the evaluation of energy consumption and water waste as well as flow and pressure characteristics in their design. There is no intent to define hot water, only that portion of the piping system that distributes it. The California Energy Commission, its supporting research organizations and other collaborators have been investigating the impact of the hot water distribution system s design on the overall energy and water performance of a building s hot water system. While our research and investigations are likely to lead to modifications in the Building Energy Efficiency Standards portion of California s Building Standards Code (Title 24), a number of potential ways to enhance the performance of these systems is influenced or governed by the requirements of plumbing codes including the Uniform Plumbing Code (UPC). Based on our research, the key factor in determining the performance of hot water distribution systems is to design and build them to have the smallest volume of water within that portion of the system between the plumbing fixture and the source of hot water. The length and the internal diameter of the pipe(s) 8

9 determine the volume of water contained within the distribution system. Systems with the least internal volume waste the least amount of energy and water. They also typically provide hot water to the plumbing fixture with the shortest waiting period typically the most important consideration to the hot water user. Unfortunately, the current plumbing codes do not differentiate between hot and cold potable water piping in the design and installation of a distribution system. Without this differentiation, current hot water distribution systems typically become over-sized while following the guidance provided by plumbing codes. Excessive pipe size has little or no negative water or energy conservation impact on cold water systems but it is a big factor in reducing the performance of hot water distribution systems. Substantiation for Proposal: The Committee rejected this proposal. There were two dissenting opinions which agreed with the value of separately recognizing the hot and cold portions of the potable water distribution system. The reasoning stated in the original proposal remain valid. Additionally, pipe sizing is more critical for the hot water portion of the distribution system since getting it wrong can result in significant waste of water and energy. It is necessary to separately define hot and cold water distribution systems in order to improve the performance of the hot water distribution system. Improvements come in the flow and pressure characteristics of the plumbing, and by the corresponding reductions in water and energy waste. Hot water use represents percent of the total residential energy consumption. The low end of the range is found in colder climate zones and the higher end of the range is found in temperate climates. In many parts of the country, and as overall building energy performance is improved, hot water is the 1st or 2nd largest residential energy use. It also represents a large fraction of the energy consumption in commercial food service, which uses almost half of the water heating used in all commercial buildings. Hot water distribution systems characteristics dictated by the UPC directly impact the amount of energy consumed. Therefore it is necessary to distinguish between hot and cold distribution systems so that appropriate hot water systems characteristics can be defined in the UPC. To do this, it is first necessary to provide a definition of a hot water distribution system. Item # 12 Comment Seq # 6 UPC SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #12). Add new text as follows: Quick-acting Valve. A valve that closes quickly or abruptly when manually released or electrically actuated. Section requires water supply systems in which quick-acting valve are installed shall be provided with devices to absorb the hammer caused by high pressure resulting from the quick closing of these valves. These valves must be approved mechanical devices however, we do not define what a quick acting valve is to determine whether or not they must be installed. In defining the valves, the user should know when they are required. 9

10 COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Shawn Martin, Plumbing Manufacturers Institute Request to reject the code change proposal by this public comment. The phrase closes quickly or abruptly, used to describe the action of the valve, is extremely subjective and vague. Since requires that systems with quick-acting valves be equipped with a device to absorb water hammer, this will lead to misapplication and inconsistent enforcement. Any definition should include a numerical value for the closing time, which leads to damaging hydraulic shock. Item # 13 Comment Seq # 7 UPC SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #13). Revise text as follows: Water hammer arrester- A device to absorb hydraulic shock, either of the air chamber or mechanical device design. A device designed to provide protection against excessive surge pressure (hydraulic shock) in the building water supply system when water is abruptly stopped. This definition should correlate with the provision of Section that prohibits the use of air chambers and references water hammer arrestors. This definition clarifies the definition of water hammer arresters and where such devices must be installed. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Shawn Martin, Plumbing Manufacturers Institute Request to accept the code change proposal as modified by this public comment. 10

11 225.0 Water hammer arrester-a device designed to provide protection against excessive surge pressure (hydraulic shock) in the building water supply system when water is abruptly stopped. The phrases excessive surge pressure and abruptly stopped used to describe the case of hydraulic shock where an arrestor is needed, are extremely subjective and vague. Since requires that systems with quick-acting valves be equipped with a device to absorb water hammer, this will lead to misapplication and inconsistent enforcement. Ideally, any revision to the definition should include a threshold level for the surge pressure over which damage to the system would result, and a water hammer arrester is necessary. This, however, would be difficult to assess in the field. As a result a change to the definition indicating the intent to protect the plumbing system from damaging hydraulic is proposed. This definition parallels that commonly used in technical literature. Item # 15 Comment Seq # 8 UPC SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #15). Revise text as follows: Approvals. All pipe, pipe fittings, traps, fixtures, material, and devices used in a plumbing system shall be listed or labeled (third -party certified) by a listing agency (accredited conformity assessment body) and shall conform to approved applicable recognized standards referenced in this code, and shall be free from defects. Plastic pipe, fittings and components shall meet the requirements of NSF 14 as referenced in Table Unless otherwise provided for in this code, all materials, fixtures, or devices used or entering into the construction of plumbing systems, or parts thereof, shall be submitted to the Authority Having Jurisdiction for approval. Section does not specify that all plastic pipe, fittings and components shall meet the requirements of NSF 14 as referenced in Table We do require that all potable water pipe shall meet the requirements of NSF 61. It makes sense to recommend the addition of NSF 14 to bring together the performance requirements for plastics. The standard as referenced incorporates plastic pipe, plastic fittings and components. This would include all plastics that are permitted for water service and distribution piping, dwv piping, and components. This requirement would not include components with plastic parts. COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Approvals. All pipe, pipe fittings, traps, fixtures, material, and devices used in a plumbing system shall be listed or labeled (third -party certified) by a listing agency (accredited conformity assessment body) and shall conform to approved applicable recognized standards referenced in this code, and shall be free from defects. Plastic piping and fittings and components other than those used 11

12 for gas, shall meet the requirements of NSF 14 as referenced in Table Unless otherwise provided for in this code, all materials, fixtures, or devices used or entering into the construction of plumbing systems, or parts thereof, shall be submitted to the Authority Having Jurisdiction for approval. COMMITTEE STATEMENT: The modification removes language or reference to components as this requirement would not include components with plastic parts and should only reference plastic piping and fittings. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Bob Adler, City of San Jose Request to reject the code change proposal by this public comment. Upon further consideration, I believe this will make another document (NSF 14) become defacto code language. Since this is proprietary language, our code should refer to a listed item, rather than call out the item in the code body itself. Item # 19 Comment Seq # 9 UPC SUBMITTER: Martin Cooper Central California Chapter IAPMO Revise text as follows: Alternate Materials and Methods of Construction Equivalency. Nothing in this code is intended to prevent the use of alternate materials, systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this code that meet the requirements of this section. Any alternate material, system, method, or device approved for use shall comply with the intent of this code and shall provide an equivalent or superior level of quality, strength, effectiveness, fire resistance, durability and safety to that prescribed by this code. Technical Documentation shall be submitted to the Authority Having Jurisdiction to demonstrate equivalency. The Authority Having Jurisdiction shall approve the system, method, or device when determined to be equivalent or superior. Any approval of an alternate material, system, method, or device shall be at the discretion of the Authority Having Jurisdiction. However, tthe exercise of this discretionary approval by the Authority Having Jurisdiction shall have no effect beyond the jurisdictional boundaries of said Authority Having Jurisdiction. Any alternate material or method of construction so approved shall not be considered as conforming to the requirements and/or intent of this code for any purpose other than that granted by the Authority Having Jurisdiction when the submitted data does not prove equivalency. Revisions to the alternate material and alternative engineered design provisions to clarify that approval is discretionary, to clarify the requirement to comply with the intent of the code, to remove vague and ambiguous language, and to ensure consistency between UPC and UMC code language. 12

13 Current code language is unclear as to whether approval of alternate materials and methods of construction is discretionary. It also conflicts with the alternate material provisions contained in the UMC. This ambiguity undermines the ability of local authorities to rely on a uniform state code. It also takes away the discretion of local authorities to avoid taking on the time, expense and responsibility of evaluating new, unproven materials, methods and devices. The discretion of local jurisdictions not to approve alternate materials or methods that have not been reviewed and accepted for use through the consensus ANSI process should be clarified. Current codelanguage may be interpreted to require local authorities to allow their jurisdictions to be testing grounds for new materials and methods. Local jurisdictions should be allowed to determine for themselves if they want to be beta testers for new products. Current code-language may also be interpreted to shift the burden of proof to the local jurisdictions to rebut claims of equivalency even for unknown products that have not been field-tested anywhere. Where a building official lacks expertise in a particular material s chemical or mechanical make-up, diagnosis of potential issues and design of appropriate tests would be difficult and haphazard. Moreover, this may lead to lawsuits over whether local jurisdictions have met their burden to rebut claims of equivalency. Officials who may have doubts as to a proposal s equivalency, but don t have the resources or expertise to fully evaluate the proposal or to design an appropriate test may feel compelled to err toward approval rather than disapproval. The current mandatory code language also improperly restricts the AHJ s authority to disapprove alternatives based upon other governmental policy reasons such as energy efficiency, water efficiency or access issues. This oversteps the role of model codes. The proposed language is consistent with the alternate approval language contained in the UMC and the language recommended by the UPC Non-Specific Code Language Task Group in Current Code language is also unclear as to whether alternate materials and methods of construction must comply with the intent of the code. The 2006 UPC inadvertently removed the express requirement that alternate materials and methods must comply with the intent of the code. However, a reference to this requirement remains in the last sentence of section The requirement to comply with the intent of the code is also contained in the Alternative Engineered Design provisions of UPC section The proposed amendment clarifies this issue and creates consistency in the code. The proposed changes also remove repetitive and unnecessary language and clarify vague or confusing language. For example, in the last sentence of UPC section 301.2, the clause when the submitted data does not prove equivalency is unnecessary, vague, and confusing. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Current text provides for alternative methods and approval. In addition, the proposed language is too subjective. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Martin Cooper, Central California Chapter IAPMO Request to accept the code change proposal as submitted by this public comment. 13

14 The 2006 UPC included several significant changes to the provisions for approving alternate materials in Section These changes inadvertently: 1) Made approval of alternate materials mandatory upon the submission of any claim of equivalency, unless proved by the authority having jurisdiction ( AHJ ) not to be equivalent or superior. 2) Resulted in confusing and ambiguous language. 3) The discretion of the Authority Having Jurisdiction ( AHJ ) not to approve alternate materials or methods that have not been reviewed and accepted for use in the UPC should be clarified as proposed in ROP Item 19. 4) The proposed discretionary language in ROP Item 19 is consistent with the alternate approval language previously contained in the 2003 UPC and currently contained in the 2006 UMC. 5) The proposed discretionary language in ROP Item 19 is also consistent with the recommendations of the UPC nonspecific Code Language Task Group for the 2006 UPC. The TC recommended amendment of ROP Item 20 which fails to clarify that alternate material approvals are discretionary and fails to clarify the confusing last sentence of Section Accordingly, we move to Reject Item 20. The current mandatory code language requires local jurisdictions to be testing grounds for new materials and methods. This undermines the entire Uniform Code concept. Local jurisdictions should be allowed to determine for themselves if they want to be beta testers for new products. The current mandatory code language shifts the burden of proof to the AHJ to rebut claims of equivalency even for unknown products that have not been field-tested anywhere. This may lead to lawsuits over whether local jurisdictions have met their burden to rebut claims of equivalency. AHJs who may have doubts as to a proposal s equivalency, but don t have the resources or expertise to fully evaluate the proposal or to design an appropriate test may feel compelled to err toward approval rather than disapproval. The current mandatory code language oversteps the role of model codes by improperly restricting the AHJ s authority to disapprove alternatives based upon other governmental policy reasons such as energy efficiency, water efficiency or access issues. Item # 20 Comment Seq # 10 UPC SUBMITTER: Leonard Ramociotti LAR Consultants Revise text as follows: Alternate Materials and Methods of Construction Equivalency. Nothing in this code is intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this code. Technical documentation shall be submitted to the Authority Having Jurisdiction to demonstrate equivalency. The Authority Having Jurisdiction shall have the authority to approve or disapprove the system, method or device for the intended purpose. when determined to be equivalent or superior. (Remainder of text remains unchanged) When the code change for the 2003 passed to get rid of all the permissive language of may to shall the language took away the Authority Having Jurisdiction s ability to not disapprove various methods, materials, or devices. The way it is worded now the Authority Having Jurisdiction SHALL accept any of the above if it is listed by any recognized testing agency. This wording will correlate with Section of the Uniform Mechanical Code. 14

15 COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Alternate Materials and Methods of Construction Equivalency. Nothing in this code is intended to prevent the use of alternate materials, systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this code. Technical documentation shall be submitted to the Authority Having Jurisdiction to demonstrate equivalency. The Authority Having Jurisdiction shall have the authority to approve or disapprove the system, method or device for the intended purpose when determined by the Authority Having Jurisdiction to be equivalent or superior. (Remainder of text remains unchanged) COMMITTEE STATEMENT: The proposed text clarifies the intent of this section as to the Authority Having Jurisdiction and the modification provides additional language for alternate materials and specifically addresses such authority. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Leonard Ramociotti, LAR Consultants Request to accept the code change proposal as submitted by this public comment. The 2006 UPC included several significant changes to the provisions for approving alternate materials in Section These changes inadvertently: Made approval of alternate materials mandatory upon the submission of any claim of equivalency, unless proved by the authority having jurisdiction ( AHJ ) not to be equivalent or superior that resulted in confusing and ambiguous language The discretion of the authority having jurisdiction ( AHJ ) not to approve alternate materials or methods that have not been reviewed and accepted for use in the UPC should be clarified as proposed in ROP Item 19. The proposed discretionary language in ROP Item 19 is consistent with the alternate approval language previously contained in the 2003 UPC and currently contained in the 2006 UMC. The proposed discretionary language in ROP Item 19 is also consistent with the recommendations of the UPC nonspecific Code Language Task Group for the 2006 UPC. The TC recommended amendment of ROP Item 20 fails to clarify that alternate material approvals are discretionary and fails to clarify the confusing last sentence of Section Accordingly, we move to Approve a originally submitted proposal for Item 20. The current mandatory code language requires local jurisdictions to be testing grounds for new materials and methods. This undermines the entire Uniform Code concept. Local jurisdictions should be allowed to determine for themselves if they want to be beta testers for new products. The current mandatory code language shifts the burden of proof to the AHJ to rebut claims of equivalency even for unknown products that have not been field-tested anywhere. This may lead to lawsuits over whether local jurisdictions have met their burden to rebut claims of equivalency. AHJs who 15

16 may have doubts as to a proposal s equivalency, but don t have the resources or expertise to fully evaluate the proposal or to design an appropriate test may feel compelled to err toward approval rather than disapproval. The current mandatory code language oversteps the role of model codes by improperly restricting the AHJ s authority to disapprove alternatives based upon other governmental policy reasons such as energy efficiency, water efficiency or access issues. Item # 21 Comment Seq # 11 UPC SUBMITTER: Michael Cudahy Plastic Pipe and Fitting Association (PPFA) Revise text as follows: Testing. The Authority Having Jurisdiction shall have the authority to require tests, as proof of equivalency Tests shall be made in accordance with approved applicable standards, by an approved testing agency at the expense of the applicant. In the absence of such standards, the Authority Having Jurisdiction shall have the authority to specify the test procedure. Applicable is a better choice of code language. IAPMO is not expected to approve standards for use in testing alternate materials and methods. Inclusion of to is made in order to correct the grammar. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed text does not clarify this section and the Authority Having Jurisdiction determines the acceptable referenced standard. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Michael Cudahy, Plastic Pipe and Fitting Association (PPFA) Request to accept the code change proposal as modified by this public comment Tests shall be made in accordance with approved or applicable standards, by an approved testing agency at the expense of the applicant. In the absence of such standards, the Authority Having Jurisdiction shall have the authority to specify the test procedure. Applicable should be used here as this is the alternative materials section of the code. There will not be approved standards in all cases. The use of approved would imply that the product, method of construction, etc. is covered by an approved standard, which would not necessarily be the case. This modification to my original proposal would insert or applicable into the section to clearly indicate that approved or applicable standards could be used. 16

17 Item # 22 Comment Seq # 12 UPC SUBMITTER: Martin Cooper Central California Chapter IAPMO Revise text as follows: Alternative Engineered Design Design Criteria. An alternative engineered design shall conform to the intent of the provisions of this code and shall provide an equivalent level of quality, strength, effectiveness, fire resistance, durability, and safety. Material, equipment, or components shall be designed and installed in accordance with the manufacturer s installation instructions Permit Application. The registered professional engineer shall indicate on the design documents that the plumbing system, or parts thereof, is an alternative engineered design so that it is noted on the construction permit application. The permit and permanent permit records shall indicate that an alternative engineered design was part of the approved installation Technical Data. The registered professional engineer shall submit sufficient technical data to substantiate the proposed alternative engineered design and to prove that the performance meets the intent of this code Design Documents. The registered professional engineer shall provide two (2) complete sets of signed and sealed design documents for the alternative engineered design for submittal to the Authority Having Jurisdiction. The design documents shall include floor plans and a riser diagram of the work. Where appropriate, the design documents shall indicate the direction of flow, all pipe sizes, grade of horizontal piping, loading, and location of fixtures and appliances Design Approval. Where the Authority Having Jurisdiction determines that the alternative engineered design conforms to the intent of this code, the plumbing system shall be approved. If the alternative engineered design is not approved, the Authority Having Jurisdiction shall notify the registered professional engineer in writing, stating the reasons therefore. Any approval of an alternative engineered design shall be at the discretion of the Authority Having Jurisdiction. The exercise of this discretionary approval by the Authority Having Jurisdiction shall have no effect beyond the jurisdictional boundaries of said Authority Having Jurisdiction. Any alternative engineered design so approved shall not be considered as conforming to the requirements and/or intent of this code for any purpose other than that granted by the Authority Having Jurisdiction Design Review. The Authority Having Jurisdiction shall have the authority to require testing of the alternative engineered design in accordance to Section , including the authority to require an independent review of the design documents by a registered professional engineer selected by the Authority Having Jurisdiction and at the expense of the applicant Inspection and Testing. The alternative engineered design shall be tested and inspected in accordance with the submitted testing and inspection plan and the requirements of this code. Revisions to the alternate material and alternative engineered design provisions to clarify that approval is discretionary, to clarify the requirement to comply with the intent of the code, to remove vague and ambiguous language, and to ensure consistency between UPC and UMC code language. Current code language lacks consistency with the code language found in the alternate approval provisions of UPC Section and UMC Section 105. The current code language also lacks a mechanism for requiring independent tests or review at the applicant s expense. It is also vague as to a 17

18 local jurisdiction s discretion to reject unproven new technologies and designs. The proposed amendment resolves these issues and creates consistency in the codes by harmonizing the alternate approval provisions found in the UPC and the UMC. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed text is already covered under alternative methods and materials. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Don Wadsworth, City of San Jose Requests to accept the code change proposal as submitted by this public comment. Current code language lacks consistency with the code language found in the alternate material approval provisions of UPC Section and UMC Section 105. As currently written this language lacks a mechanism for requiring independent tests or peer review at the applicant s expense; and is vague as to a local jurisdiction s discretion to reject unproven or controversial new technologies and designs. Lastly, current code language does not provide guidance where there is disagreement among engineers or other experts. The proposed amendment resolves these issues and creates consistency in the codes by harmonizing this section with the alternate approval provisions found in the UPC and the UMC. Item # 25 Comment Seq # 13 UPC SUBMITTER: Michael Wynne UA Local 290 Training Center Add new text as follows: The use of venting methods, fittings and devices which do not protect a trap seal from both siphonage and back-pressure shall be prohibited in all plumbing systems regulated by this code. The ability of a plumbing system to maintain trap seals is the backbone of modern plumbing design. The venting methods allowed by a code must protect the trap seal from both siphonage and back-pressure. Yet we see claims of new methods and devices, which do not perform these functions as somehow being beneficial to public health and safety. Venting methods, fittings and devices which do not protect the trap seal from both siphonage and back-pressure must be prohibited. 18

19 COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Already covered in Section for vents required. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Michael Wynne, UA Local 290 Training Center Request to accept the code change proposal as submitted by this public comment. The ability of a plumbing system to maintain trap seals is the backbone of modern plumbing design. The venting methods allowed by a code must protect the trap seal from both siphonage and back-pressure. Yet we see claims of new methods and devices, which do not perform these functions as somehow being beneficial to public health and safety. Venting methods fittings and devices which do not protect the trap seal from both siphonage and back-pressure must be prohibited. Item # 27 Comment Seq # 14 UPC , 313.7, , , SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #27). Revise text as follows: All piping penetrations of fire-resistance rated walls, partitions, floors, floor/ceiling assemblies, roof/ceiling assemblies or shaft enclosures shall be protected in accordance with the requirements of the Building Code, IAPMO installation Standards applicable standards referenced in Table 14-1 and Chapter 15, Firestop Protection Solvent Cement Plastic Pipe Joints. Plastic pipe and fittings designed to be joined by solvent cementing shall comply with appropriate applicable standards referenced in Table IAPMO Installation Standards. ABS pipe and fittings shall be cleaned and then joined with solvent cement(s). CPVC pipe and fittings shall be cleaned and then joined with listed primer(s) and solvent cement(s) Exception: Listed solvent cements that do not require the use of primer shall be permitted for use with CPVC pipe and fittings, manufactured in accordance with ASTM D 2846, ½ inch through 2 inches in diameter. 19

20 PVC pipe and fittings shall be cleaned and joined with primer(s) and solvent cement(s). A solvent cement transition joint between ABS and PVC building drain or and building sewer shall be made using a listed transition solvent cement ABS and PVC DWV piping installations shall be installed in accordance with IS 5, IS 9 that are IAPMO installation standards. applicable standards referenced in Table 14-1 and Chapter 15 Firestop Protection. Except for individual single-family dwelling units, materials exposed within ducts of plenums shall have a flame-spread index of not more than 25 and a smoke-developed index of not more than 50, when tested in accordance with the Test for Surface-Burning Characteristics of the Building Materials. (See the Building Code standards based on ASTM E-84 and ANSI/UL 723) Elastomeric Gasketed and Rubber-Ring Joints. Elastomeric gasketed and rubber-ring joints shall comply with applicable standards referenced in Table 14-1 Installation standards listed in Appendix I Hubless Cast-Iron Pipe Joints. Joints for hubless cast-iron soil pipe and fittings shall conform to appropriate applicable standards referenced in Table 14-1 installation standards listed in Appendix I and shall not be considered slip joints. Section indicates that All IAPMO Installation Standards are included in Appendix I for the users of this code. They are not considered as a part of this code unless formally adopted as such by the Authority Having Jurisdiction. Using the terms IAPMO Installation Standards as a requirement in the code does not correlate and contradicts Section COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Tony Crimi, A.C. Consulting Solutions Inc. Request to accept the code change proposal as modified by this public comment All piping penetrations of fire-resistance rated walls, partitions, floors, floor/ceiling assemblies, roof/ceiling assemblies or shaft enclosures shall be protected in accordance with the requirements of the Building Code, IAPMO installation Standards applicable standards referenced in Table 14-1 and Chapter 15, Firestop Protection Remain unchanged ABS and PVC DWV piping installations shall be installed in accordance with applicable standards referenced in Table and Chapter 15 Firestop Protection. Except for individual singlefamily dwelling units, materials exposed within ducts of plenums shall have a flame-spread index of not more than 25 and a smoke-developed index of not more than 50, when tested in accordance with the Test for Surface-Burning Characteristics of the Building Materials. (See the Building Code standards based on ASTM E-84 and ANSI/UL 723) Remain unchanged Remain unchanged 20

21 The proposal from the Correlation Task group goes well beyond merely providing consistency with section Firstly, the existing approach where IAPMO Installation Standards are in Appendix I for the users of this code, without making them mandatory parts of the Code provides a useful resource. Alternatively, if the concern is with having material in Appendix I that is not contained in any mandatory references in the body of the Code, then a more appropriate solution is to remove the material and reference documents from Appendix I altogether. The IFC has particular concerns with respect to the mandatory use ASME A , Standard for Qualification of Installers of Firestop Systems and Devices for Piping Systems. One currently existing means that a user has of ensuring that the installer is knowledgeable in fire stop installation is by requiring that the installer meet a minimum qualification standard. The FM Global Standard for Approval of Firestop Contractors and the UL Qualified Firestop Contractor Program were developed to provide users with a benchmark that firestopping installers must meet in order to be approved or registered. Such contractors must pass examinations based on the accepted industry reference materials, codes and standards, the FCIA Manual of Practice, and must undertake continuing education to maintain their standing. Re-examination is required every three years. Under the UL Qualified Contractor Program, candidates are offered a U.S. or Canadian examination based on US or Canadian code requirements. Installers, qualified to the standards, can be found throughout North America. Users can determine that the work has been performed by qualified installers by seeking the FM Global or UL/ULC mark on the completed fire stops in the field and by inquiring about certification from the installer. In addition, trade associations and others may offer detailed training for installation personnel. A mandatory reference to ASME A as proposed here would prohibit these qualified firms and programs from complying with the UPC based solely on the fact that the individuals performing the function may not have 4 years of plumbing experience. Consequently, this proposed Code change would prohibit experienced, qualified, even certified contractors and individuals from installing firestopping around piping. In addition, having participated in the development of the ASME A Standard for Qualification of Installers of Firestop Systems and Devices for Piping Systems, it is our view that the ASME A standard contains some serious flaws. The objective of any Standard should be to provide a potential user with the information needed to correctly perform a task, in a consistent manner, and to be able to know when the task has been done correctly. As currently written, this Standard does not fulfill this objective. There are no specified performance levels, no evaluation criteria, and no numerical pass/fail criteria. Further, it contains a requirement that a firestop installer should have 4 years of plumbing experience, and yet does not require any experience with installing firestopping. It does not specify how many firestop installations they need to conduct during that period, nor whether any specific supervision, evaluation, or training, other than the 32 hour classroom training, is required over that period. The lack of any requirements for practical field installation experience in the installation of firestopping, coupled with the mandatory requirement for 4 years of potentially unrelated plumbing experience, can be a recipe for faulty installations, potentially resulting in a life safety hazard. While we do not have any specific objections to the revisions to Sections , , or , we still believe that the principle of providing IAPMO Installation Standards in Appendix I for the users of this code, without making them mandatory parts of the Code is valid and valuable. If the Committee feels this is inappropriate, we would recommend deleting from Appendix I and Table 14-1 all of those Standards for which there are not any mandatory requirements in the body of the Code. PUBLIC COMMENT 2: Submitter: Bill McHugh, Firestop Contractors International Association Request to reject the code change proposal by this public comment. 21

22 FCIA comments that the reference to ASME A be rejected completely. The Firestop Contractors International Association comments that this standard is not applicable, as it requires that all firestopping be installed by journeyworkers who have passed a 4 year apprenticeship in plumbing. Item # 28 Comment Seq # 15 UPC SUBMITTER: Michael Cudahy Plastic Pipe and Fitting Association (PPFA) Revise text as follows: All piping penetrations of fire-resistance-rated walls, partitions, floors, floor/ceiling assemblies, roof/ceiling assemblies, or shaft enclosures shall be protected in accordance with the requirements of the Building Code, IAPMO Installation Standards, and Chapter 15, Firestop Protection. Striking IAPMO Installation Standards (IS), which are non-mandatory, and may or may not be adopted, corrects this section. There are also not IS available for all materials, and this also corrects an inconsistency in Chapter 15, which does not mention the IS. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The committee action taken on Item 27 already addresses this issue. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Tony Crimi, A.C. Consulting Solutions Inc. Request to accept the code change proposal as submitted by this public comment. The proposal from the Correlation Task (Item #27) group goes well beyond merely providing consistency with Section If the concern is with having material in Appendix I that is not contained in any mandatory references in the body of the Code, then a more appropriate solution is to remove the material and reference documents from Appendix I altogether. Alternatively, this proposal does resolve the conflict within the body of the Code. While we still believe that the principle of providing IAPMO Installation Standards in Appendix I for the users of this code, without making them mandatory parts of the Code is valid and valuable. If the Committee feels this is inappropriate, we would recommend deleting from Appendix I and Table 14-1 all of those Standards for which there are not any mandatory requirements in the body of the Code. 22

23 The IFC has particular concerns with respect to the mandatory use ASME A , Standard for Qualification of Installers of Firestop Systems and Devices for Piping Systems. By requiring that the installer meet a minimum qualification stand ensures that the installer is knowledgeable in firestop installation. The FM Global Standard for Approval of Firestop Contractors and the UL Qualified Firestop Contractor Program were developed to provide users with a benchmark that firestopping installers must meet in order to be approved or registered. Such contractors must pass examinations based on the accepted industry reference materials, codes and standards, the FCIA Manual of Practice, and must undertake continuing education to maintain their standing. Re-examination is required every three years. Under the UL Qualified Contractor Program, candidates are offered a U.S. or Canadian examination based on US or Canadian code requirements. Installers, qualified to the standards, can be found throughout North America. Users can determine that the work has been performed by qualified installers by seeking the FM Global or UL/ULC mark on the completed fire stops in the field and by inquiring about certification from the installer. In addition, trade associations and others may offer detailed training for installation personnel. A mandatory reference to ASME A as proposed here would prohibit these qualified firms and programs from complying with the UPC based solely on the fact that the individuals performing the function may not have 4 years of plumbing experience. Consequently, this proposed Code change would prohibit experienced, qualified, even certified contractors and individuals from installing firestopping around piping. Item # 29 Comment Seq # 16 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revise text as follows: Solvent Cement Plastic Pipe Joints. Plastic pipe and fittings designed to be joined by solvent cementing shall comply with appropriate IAPMO Installations Standards. When primers are required or necessary, they shall be traceable either by color or UV frequency lighting. ABS Pipe and fittings shall be cleaned and then joined with solvent cement(s). CPVC pipe and fittings shall be cleaned and then joined with listed primer(s) and solvent cement(s). Exception: Listed solvent cements that do not require the use of primer shall be permitted for use with CPVC pipe and fittings, manufactured in accordance with ASTM D2846, 1/2 inch through 2 inches in diameter. PVC pipe and fittings shall be cleaned and joined with primer(s) and solvent cement(s). A solvent cement transition joint between ABS and PVC building drain or and building sewer shall be made using a listed transition solvent cement. Many times because of material, temperature or size, it is critical to the long term performance of solvent cement joints that a primer is used and that the regulatory inspector can determine that it was in fact applied. A new technology primer has been developed that can be identified with a UV frequency light which gives an option to the use of color primers. COMMITTEE ACTION: Reject 23

24 COMMITTEE STATEMENT: Current referenced standard for primers does not cover this product or proposed text. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting Request to accept the code change proposal as submitted by this public comment. The Technical Committee s reason for rejection was that the consensus standard does not cover the product or proposed text. We have taken out a project at ASTM to revise F 656 to include reference to and requirements for detectable clear primers. This revision is expected sometime in This proposal is simply another safe guard in protecting piping systems and the public with regard to primers. This proposal encourages the use of primers and gives an alternative to the use of mandatory colored primers which are sometimes not used because of staining and discoloration of finish materials. Item # 30 Comment Seq # 17 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revise text as follows: Solvent Cement Plastic Pipe Joints. Plastic pipe and fittings designed to be joined by solvent cementing shall comply with appropriate IAPMO Installations Standards. When primers are required, they shall be purple or clear when visible under UV or visible light source (black light). ABS Pipe and fittings shall be cleaned and then joined with solvent cement(s). CPVC pipe and fittings shall be cleaned and then joined with listed primer(s) and solvent cement(s). Exception: Listed solvent cements that do not require the use of primer shall be permitted for use with CPVC pipe and fittings, manufactured in accordance with ASTM D2846, 1/2 inch through 2 inches in diameter. PVC pipe and fittings shall be cleaned and joined with primer(s) and solvent cement(s). A solvent cement transition joint between ABS and PVC building drain or and building sewer shall be made using a listed transition solvent cement. Many times because of material, temperature or size, it is critical to the long term performance of solvent cement joints that a primer is used and that the regulatory inspector can determine that it was in fact applied. A new technology primer has been developed that can be identified with a UV frequency light which gives an option to the use of color primers. 24

25 COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on committee action taken on Item 29 and current referenced standard for primers does not cover this product or proposed text. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting Request to accept the code change proposal as submitted by this public comment. The Technical Committee s reason for rejection was that the consensus standard does not cover the product or proposed text. We have taken out a project at ASTM to revise F 656 to include reference to and requirements for detectable clear primers. This revision is expected sometime in Item 30 is simply another suggested wording and will achieve the same effect and goal as Item 29. This proposal is simply another safe guard in protecting piping systems and the public with regard to primers. This proposal encourages the use of primers and gives an alternative to the use of mandatory colored primers which are sometimes not used because of staining and discoloration of finished materials. Item # 33 Comment Seq # 18 UPC (New) SUBMITTER: James Paschal Bodycote Add new text as follows: Heat Fusion Weld Joints. This type of joint is used in Polypropylene (PP) systems to connect pipe to fittings or pipe lengths directly to one another (butt fusion). This method of joining pipe to fittings includes socket-fusion, electrofusion, and saddle-fusion. This method of welding involves the application of heat and pressure to the polypropylene components, allowing the PP to fuse together forming a bond between the pipe and fitting. This proposal provides for an alternate plumbing material. These Polypropylene (PP) piping systems are manufactured, tested and listed in accordance with ASTM F 2389, and have been accepted in other model codes in the U.S. and Canada (IPC, NSPC, NPC). COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Ted Lemoff, NFPA 25

26 Request to accept the code change proposal as modified by this public comment Heat Fusion Weld Joints. This type of joint is used in Polyethylene (PE), Polypropylene (PP), and similar systems to connect pipe to fittings or pipe lengths directly to one another (butt fusion). This method of joining pipe to fittings includes socket-fusion, electrofusion, and saddle-fusion. This method of welding involves the application of heat and pressure to the polypropylene the plastic components, allowing the PP plastic component to fuse together forming a bond between the pipe and fitting. The definition as proposed would limit heat fusion weld joints to polypropylene. As polyethylene pipe, which is allowed for gas piping (outdoors, underground, only), is also joined using heat fusion welds the definition should be expanded to cover other materials. The recommended revisions also would allow similar materials so as not to be restrictive. Other materials can be used, i.e. polyamide for gas piping (but at present it tends to be at an economic disadvantage). PUBLIC COMMENT 2: Submitter: Michael Cudahy, Plastic Pipe and Fitting Association (PPFA) Request to accept the code change proposal as modified by this public comment Heat Fusion Weld Joints. This type of joint is used in Polypropylene (PP) some thermoplastic systems to connect pipe to fittings or pipe lengths directly to one another (butt fusion). This method of joining pipe to fittings includes socket-fusion, electrofusion, and saddle-fusion. This method of welding involves the application of heat and pressure to the polypropylene components, allowing them PP to fuse together forming a bond between the pipes and/or fitting. This section is the Joints and Connections of the general regulations chapter. Heat Fusion Weld Joints can be done with several thermoplastic pipes. This definition would be better if it referred to some thermoplastics instead of just Polypropylene (PP). Item # 34 Comment Seq # 19 UPC (New) SUBMITTER: Rand Ackroyd Rand Engineering Add new text as follows: Push-fit Fitting. This is a mechanical connection for joining copper, pex and cpvc tubing. The connection is hand assembled by pushing the tubing into the fitting. The connection seals with an O ring. This type of fitting is now covered by the new Standard ASSE COMMITTEE ACTION: Accept as Submitted 26

27 A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Michael Cudahy, Plastic Pipe and Fittings Association Request to accept the code change proposal as modified by this public comment Push-fit Fitting. This is a mechanical connection fitting for joining copper, pex and cpvc tubing. The connection is hand assembled by pushing the tubing into the fitting. The connection seals with an O ring. The definition could be simplified and included in the code without the current listing of materials. Most of the PEX industry opposes using this fitting, manufactured to ASSE 1061, at this time because of the lack of proper materials and sizing requirements. It is, however, also likely that push-fit fittings could be adaptable to other materials and pipes than the ones listed. Item # 37 Comment Seq # 20 UPC and Table 14-1 SUBMITTER: Daniel Gleiberman Falcon Waterfree Technologies Add new text as follows: Nonwater Urinals. When nonwater urinals are installed they shall be listed and comply with the appropriate standards referenced in Table Nonwater urinals shall have a barrier liquid sealant to maintain a trap seal. Nonwater urinals shall permit the uninhibited flow of waste through the urinal to the sanitary drainage system. Nonwater urinals shall be cleaned and maintained in accordance with the manufacturer s instructions after installation. When nonwater urinals are installed they shall have a water distribution line rough-in to the urinal location to allow for the installation of an approved backflow prevention device in the event of a retrofit. MANDATORY REFERENCED STANDARDS TABLE 14-1 Standards for Materials, Equipment, Joints, and Connections Where more than one standard has been listed for the same material or method, the relevant portions of all such standards shall apply. Standard Number Standard Title Application ASME A Vitreous China Nonwater Urinals Fixtures This change provides for the inclusion in the code of an American National consensus standard. The new code section provides additional language that mandates requirements for the installation of nonwater urinals which will help protect the public health and safety when nonwater urinals are installed. If in the future a retrofit of the restroom happens the requirement for a rough-in distribution line allows for changes without unreasonable expense and delays for the property owner. * Note: A copy of the referenced Standard was provided. 27

28 COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: John Halliwill, Halliwill and Associates Request to accept the code change proposal as modified by this public comment Nonwater Urinals. When nonwater urinals are installed they shall be listed and comply with the appropriate standards referenced in Table Nonwater urinals shall have a barrier liquid sealant to maintain a trap seal. Nonwater urinals shall permit the uninhibited flow of liquid waste through the urinal to the sanitary drainage system. Nonwater urinals shall be cleaned and maintained in accordance with the manufacturer s instructions after installation. When nonwater urinals are installed they shall have a water distribution line rough-in to the urinal location to allow for the installation of an approved backflow prevention device in the event of a retrofit. MANDATORY REFERENCED STANDARDS TABLE 14-1 Standards for Materials, Equipment, Joints, and Connections Where more than one standard has been listed for the same material or method, the relevant portions of all such standards shall apply. Standard Number Standard Title Application ASME A Vitreous China Nonwater Urinals Fixtures I am recommending that the wording Nonwater urinals shall have a barrier liquid sealant to maintain a trap seal be deleted for the following reasons: 1. Adding the new wording will introduce additional wording to the Code that is not needed. 2. This new wording would establish two requirements in the code as Section already has requirements for a liquid seal in all fixture traps that adequately protects the public health and safety. 3. The inclusion of this additional prescriptive wording would not allow for future technologies as they are developed and would not allow for these new products to be installed even though they may provide better performance. I have no comment for the inclusion of ASME A into Table Item # 38 Comment Seq # 21 UPC SUBMITTER: Gary Klein California Energy Commission Add new text as follows: Water-Conserving Fixtures and Fittings Shower heads. Any fixture, device or combination of devices plumbed to emit and spray hot or warm water and discharging to a floor drain or tub drain. For the purposes of this definition, shower 28

29 heads shall be broadly defined to include shower heads, spa sprays, rain simulators, water spray emitters, handhelds, showering enclosures or other similar devices. Each shower head shall have separate controls Shower compartment. A shower compartment, stall, enclosure or tub/shower combination Water consumption. The water consumption of an individual shower head shall not exceed 2.5 gallons per minute (9.5 L/min) at 80 psi. In addition, when multiple shower heads are installed in a shower compartment with a floor area up to two thousand five hundred (2,500) square inches (1.61 m 2 ), the total water consumption shall not exceed 2.5 gallons per minute (9.5 L/min) when all or any combination of shower heads are operating. Where the floor area of the shower compartment exceeds two thousand five hundred (2,500) square inches (1.61 m 2 ), the total maximum water output shall not exceed 2.5 gallons per minute, per two thousand (2,000) square inches of additional floor area Water supply branch pipe for showers. There shall only be one water supply branch pipe for each shower head or combination of shower heads in a shower compartment with a floor area up to two thousand five hundred (2,500) square inches (1.61 m 2 ). One additional water supply branch pipe is permitted per two thousand (2,000) square inches of additional floor area. The water supply branch pipe shall be sized in accordance with the dimension in Table 6-5. Where additional water supply branch pipes are allowed, they shall be separated by at least thirty six (36) inches (0.92 m). (Renumber remaining sections) Statement of Problem: With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct mandated a maximum 2.5 gallon/minute flow rate for showerheads, limited toilet water use to 1.6 gallons/flush and established reduced flow standards for household faucets. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven effective, without undue burden on the consumer or manufacturers. The U.S. Environmental Protection Agency estimates that by 2020, residential and commercial savings from these efficient plumbing fixtures will be 6 billion-9 billion gallons per day. Water, energy and wastewater agencies throughout the United States are relying on these savings to meet the current and future demand for water and energy. Conservation is no longer just a public service program; it is an integral and vital part of the management of our resources. The energy and water savings from EPAct must be maintained and protected by plumbing codes, including the UPC. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers have installed multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the allowable flow rate. Violations of the federal law are growing, as reported in various trade publications: Bathrooms on Long Island are beginning to feel more like spas. Showers with multiple body sprays are combining to make the bathroom a cozy place that s as comfortable as any room in the house.ceiling mounted showerheads, up to 12 inches in diameter, can make it rain on you while you are soaking. By Bernadette Starzee, HousingZone.Com newsletter, November 23, 2005, Homeowners are making their bathrooms into more comfortable, cozy spaces One of the strongest trends in luxury bath design of interest to the plumbing contractor is the large walkin shower. Not only do these oversized units dwarf conventional showers, consumers want them installed with an array of feature options from seating to multiple showerheads, to elaborate controls for the heads and/or jets as well as temperature. By Allison Deer, Reeves Journal, June 2005, Steam Heat 29

30 The latest trend is the new all-in-one shower panel with shower head, hand shower, and body sprays (showers that spray horizontally). All of this has become very popular because of its ease of installation. Rain showers are being used more and more today. These shower heads keep getting larger and larger. By Fred Fedewa, Grohe Reeves Journal, June 2005, Shower Heads, They re not all the same. The walk-in shower in the master bathroom, for example, has two adjoined bays, with six nozzles each, that can be used simultaneously. It s like a car wash, Joe Varagoon quips. The shower built for their daughter s bathroom has 10 body jets. The guest bathroom has a setup that simulates rainfall We have water going everywhere. By Brett Oppegaard HousingZone.Com newsletter, June 8, 2005, Clean living; Luxury showers raise the ante on feeling fresh with a variety of sprays, fixtures and sheer size Danze now offers a custom shower system that enables homeowners to design their own shower experience The Danze unit is equipped with ½-inch inlets and outlets and will deliver in excess of four gallons per minute at 45 psi. Supply House Times, October 2005 Multiple spray showers require lots of water flow. Some multi-spray showers have six or eight heads and consume 12 or more gpm. The valve has to be rated to flow at least the sum of all the heads in a shower. Plumbing & Heating Contractor News, July/August 2001 All-in-one shower panels with up to four body sprays are a growing, mass-market trend, assert manufacturers surveyed, because they make for an easy retrofit into existing applications. Kitchen & Bath Design News, September 2005, Product Trend Report Full Steam Ahead. There is no doubt the spirit and intent of EPAct was to eliminate the waste of excessive water use during showering. The law addresses the performance characteristics of shower heads; not the requirements of installations. EPAct did not specify installation requirements; for this is the role of plumbing codes. IAPMO has not yet included provisions in the Uniform Plumbing Code to address and support the shower requirements of the federal law. Unless IAPMO acts quickly to fill this void in the UPC; states, counties and municipalities will be forced to enact their own laws to meet this need. These various laws will likely result in regional variations of the requirements; causing confusion amongst contractors, manufacturers and plumbing inspectors. Substantiation for Proposal: The proposal supports EPAct and eliminates water waste by eliminating the various means of exceeding the flow rate requirements of the federal law. The proposal is no more restrictive than the clear intent of EPAct. The only products affected are products used to exceed the flow rate requirements of the federal law. The water use of showers remains at 2.5 gallons per minute for each person showering. The standard tub-shower combination (6 x 2.5 ) includes approximately 2,160 square inches of floor area. The UPC mandates a minimum of 1,024 square inches of floor area (equal to a 32 x 32 square). The area of most shower stalls, compartments and enclosures falls within this range. Additional shower heads, or combinations of showering devices are allowed to accommodate multi-person gang showers at the rate of one shower per every 2,000 square inches (approximately 45 x 45 ) above the initial one shower head per 2,500 square inches. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: It is arbitrary to tie flow rate to square footage as the proposed text suggests and such language does not address gang showers. The proposed text includes definitions located in code text and a shower head is not considered a fixture. In addition, there may be possible conflicts with ADA regulations along with various concerns addressed by the technical committee. 30

31 A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION PUBLIC COMMENT(s): Submitter: Douglas Bennett, Southern Nevada Water Authority Mary Ann Dickinson, Alliance for Water Efficiency Al Dietemann, Seattle Public Utilities Jeanne Deaver, Santa Fe Irrigation District Miles Ferris, City of Santa Rosa Utilities Department Lynne Florey, Sonoma County Water Agency Sharon Fraser, El Dorado Irrigation District (EID) Rodd Greene, Yucaipa Valley Water District Andy Hul, Metropolitan Water District of Southern California Joone Lopez, Central Basin Water District Jose Martinez, Walnut Valley Water District Kristina Ortez, Natural Resources Defense Council (NRDC) Thomas E. Pape, Alliance for Water Efficiency Paul Piazza, Town of Windsor Stacy L. Rodriguez, Eastern Municipal Water District John Schommer, Watermiser Greg Milleman, Valencia Water Company Request to accept the code change proposal as modified by this public comment Water-Conserving Fixtures and Fittings Showerhead Water Consumption. The water consumption of an individual showerhead shall not exceed 2.5 gallons per minute (9.5 L/min) at 80 psi. In addition, when multiple showerheads are installed in a shower compartment with a floor area up to two thousand five hundred (2,500) square inches (1.61 m 2 ), the total water consumption shall not exceed 2.5 gallons per minute (9.5 L/min) when all or any combination of showerheads are operating. Where the floor area of the shower compartment exceeds two thousand five hundred (2,500) square inches (1.61 m 2 ), the total maximum water output shall not exceed 2.5 gallons per minute, per two thousand (2,000) square inches of additional floor area Water supply branch pipe for showers. There shall only be one water supply branch pipe for each showerhead or combination of showerheads in a shower compartment with a floor area up to two thousand five hundred (2,500) square inches (1.61 m 2 ). One additional water supply branch pipe is permitted per two thousand (2,000) square inches of additional floor area. The water supply branch pipe shall be sized in accordance with the dimension in Table 6 5. Where additional water supply branch pipes are allowed, they shall be separated by at least thirty-six (36) inches (0.92 m). Each showerhead shall have separate controls or mixing valve. (renumber remaining sections) SUBSTANTIATION (Douglas Bennett): Efficient showerheads have long been one of the major tools for reducing urban water demand. The 1992 Energy Policy Act (EPAct) mandated a maximum flow rate of 2.5 gpm for showerheads. At the time EPAct was approved, the prospect of multiple showerheads in a single stall was not discussed or considered. It is conspicuous by EPAct s core purpose that the wording of the policy was not intended to allow multiple showerheads to be used simultaneously in a single shower compartment. Regrettable, this has been the functional interpretation and these multiple showerhead applications are negatively impacting the energy and water benefits of the legislation. 31

32 Technology has vastly improved the quality of showerheads since 1992 and appropriate policy will further drive innovation in performance. In Las Vegas, tens of thousands of luxury hotel guest rooms have been retrofitted with high-quality showerheads that are up to 40 percent below the federal flow limit of 2.5 gpm. The availability of these fixtures and the fact that they meet the high customer satisfaction requirements of resort hotels indicates that there will be no significant user satisfaction consequences of the proposed limitation. These successful high-efficiency installations further demonstrate the potential for manufacturers to develop multi-outlet devices that are still compliant with the combined 2.5 gpm standard. It seems absolutely appropriate for though UPC to address this issue. Without national leadership, it is highly likely that various agencies and programs will adopt local, state and regional requirements that may create havoc and confusion among manufacturers, installers, retailers and policymakers. The SNWA currently operates the nation s largest water-efficiency program for new homes, the Water Smart Home. The Water Smart Home program has established a criterion for single showerheads in facilities with a pan area of less than 2,500 square inches. If multiple showerheads or nozzles are used, the combined flow may not exceed 2.5 gpm. More than 6,000 new homes have been built to this standard in the Las Vegas, NV region. The SNWA finds that the proposed amendment adequately addresses the need for multiple showerheads in multiple user facilities and that the standards for such installations are appropriately defined on the basis of shower stall area. SUBSTANTIATION (Mary Ann Dickinson): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. The Alliance for Water Efficiency understands and concurs with IAPMO s role in protecting the health and safety of the public. Ours is a similar mission. We are particularly concerned that the codes promote efficient and sustainable water use, vital to ensuring that the water supplies are able to meet the growing demand. Thus, the efficient use of water must be an important emphasis for the code in the protection of the health and safety of the public. 32

33 The Alliance for Water Efficiency is a stakeholder-based 501(c)3 non-profit organization dedicated to the efficient and sustainable use of water. Located in Chicago, the Alliance serves as a North American advocate for water efficient products and programs, and provides information and assistance on water conservation efforts. Our membership includes water utility wholesalers and retailers, manufacturers of water plumbing fixtures and appliances, governmental agencies, research organizations, energy and environmental organizations, and other water use and conservation experts. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 3,100 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Al Dietemann): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. Seattle Public Utilities understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 20 years the regional Saving Water Partnership has spent forty million dollars to improve water efficiency. We have replaced more that 400,000 showerheads to more efficient models. Our efforts are undermined by the lack of plumbing code provisions to deter the installing multiple showerheads in increasing numbers. A recent survey indicated that 7% of households now have more than one showerhead in each stall. This number has grown from 2% in just five years. The water wasting implications of this growth rate is very troublesome. The lack of a good definition for what is a showerhead and how many can be installed, is creating a loop hole in national and local plumbing codes to allow massive water waste. 33

34 We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Jeanne Deaver): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Santa Fe Irrigation District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. We participate in and fund conservation programs offered by the San Diego County Water Authority and the Metropolitan Water District, including a large scale distribution of water efficient showerheads. Our efforts are potentially undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,100 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Miles Ferris): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute 34

35 maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at City of Santa Rosa Utilities Department understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 20 years, the City of Santa Rosa Utilities Department has spent more than $14.5 million to improve water efficiency and perform and repair transmission system leaks. We have replaced 87% of the showerheads in Single Family Residences and 76% of the showerheads in Multi Family Residences with efficient models. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. SUBSTANTIATION (Lynne Florey): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 35

36 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Sonoma County Water Agency understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 10 years, the Sonoma County Water Agency as its water contractors have spent more than $82,000,000 dollars to improve water efficiency, expand the use of local water resources and develop recycled water to offset potable demand. The Sonoma County Water Agency also spends more than $53,000 each year to detect and repair leaks in our water distribution system. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 3,000 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Sharon Fraser): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. 36

37 The El Dorado Irrigation District (EID) understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In 2006 alone, EID spent more than $600,000 to improve water efficiency, including replacing many high-flow showerheads to more efficient models. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. Water resources are limited in EID s service area, and this wasteful practice is unacceptable. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Rodd Greene): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Yucaipa Valley Water District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. The Yucaipa Valley Water District strongly supports efforts to improve water efficiency. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for 37

38 one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Andy Hul): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. Unfortunately, EPAct did not anticipate all the means in which the law would be circumvented. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a non-substantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Yucaipa Valley Water District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. The Yucaipa Valley Water District strongly supports efforts to improve water efficiency. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. The mission of the Metropolitan Water District is to provide its service area with adequate and reliable supplies of high quality water to meet present and future needs in an environmentally and economically responsible way. Metropolitan has spent more that $200 million to improve water efficiency in the past 18 years. Metropolitan has replaced more than 1.7 million showerheads in its service area with more efficient models. These efforts would be supported through the proposed amendment regarding multiple showerheads. We urge IAPMO to adopt provisions to deter the circumvention of the Federal water efficiency for showerheads. If IAPMO does not act, Metropolitan and other water providers may propose ordinances and legislation at the local and state level to stop this water waste. Local regulation of this issue would result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Joone Lopez): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute 38

39 maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Central Basin understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 14 years, Central Basin has spent more than $5 million dollars to improve water efficiency. We have replaced more than 300,000 showerheads to more efficient models. We also spend more than $2.7 million each year on education and outreach to inform the community of the various issues we face with water reliability. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Jose Martinez): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain 39

40 machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Walnut Valley Water District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 10 years, Walnut Valley Water District spent more than $750,000 to improve water efficiency. We have replaced more than 1,000 showerheads over the past few years to more efficient models. We also spend an estimated $250,000 each year to detect and repair leaks in our water distribution system. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,100 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Kristina Ortez): The Natural Resources Defense Council (NRDC) represents over 1.2 million members and e-activists. We have been involved in water use efficiency for decades, and have advocated for legislation and regulating related to water conservation. NRDC supports efforts that contribute to sustainable water use and water management strategies, including improve industry standards that provide for water supply reliability for communities, agricultural and environmental purposes. NRDC urges the IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. Congress signed the Energy Policy Act (EPAct) into law 1992, mandating 2.5-gallon/minute maximum flow rates for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven costeffective, and have provided water savings, without undue burden on the consumer or manufacturers. At this point, these vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidl6y, as reported in various plumbing trade publications including Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. 40

41 The proposed amendment is not arbitrary in its limitations, and the proposal accommodates group showers. The typical home shower stall, appropriate for one users at a time is approximately 1,800 square inches. The UPC already sets the minimum shower area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-tobody contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each users is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is not limit to the size of a shower stall, or accessibility to showerhead or controls. As a non-substantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. SUBSTANTIATION (Thomas E. Pape): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. The Alliance for Water Efficiency understands IAPMO s role in protecting the health and safety of the public. Ours is a similar mission. We are particularly concerned that the codes promote efficient and sustainable water use is vital to assure water supplies meet the growing demand. Thus, the efficient use of water must be an important emphasis for the code in the protection of the health and safety of the public. The Alliance for Water Efficiency is a stakeholder-based 501(c)3 non-profit organization dedicated to the efficient and sustainable use of water. Located in Chicago, the Alliance serves as a North American advocate for water efficient products and programs, and provides information and assistance on water conservation efforts. Our membership includes water utility wholesalers and retailer, manufacturers of water plumbing fixtures and appliances, governmental agencies, research organizations, energy and environmental organizations, and other water use and conservations experts. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and 41

42 legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 3,100 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Paul Piazza): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Town of Windsor understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. A reliable source of water is paramount to all or our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past five years, the Town of Windsor has spent more than $300k to improve water efficiency. We have replaced more than 1,200 showerheads to more efficient models. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Stacy L. Rodriguez): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. 42

43 These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the Municipal Water District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. Eastern has spent millions of dollars over the past years in order to improve water efficiency. Also, Eastern has provided and distributed thousands of efficient showerheads since Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (John Schommer): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct included a mandate of 2.5 gallon/minute maximum flow rate for showerheads. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven cost effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers install multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the legal flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the legally allowable shower flow rate. Violations of the federal law are growing rapidly, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating Contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. 43

44 The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches. While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact. This proposed provision assures sanitary conditions by allowing multiple users in a gang shower without body-to-body contact; each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a nonsubstantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. We at the (Watermiser) understand IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 17 years, Watermiser has spent more than 2 million dollars to improve water efficiency. We have installed thousands of Watermiser Flow control devices on Showerheads and faucets to make them more efficient. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Greg Milleman): With the goal of improving water and energy efficiency, Congress, in 1992, signed the Energy Policy Act (EPAct) into law. Taking effect in 1994, EPAct mandated a maximum 2.5 gallon/minute flow rate for showerheads, limited toilet water use to 1.6 gallons/flush and established reduced flow standards for household faucets. These requirements were deemed necessary to assure the security and reliability of potable water supplies in America. These efficiency standards have proven effective, without undue burden on the consumer or manufacturers. These vital water and energy efficiencies are in serious jeopardy by those who wish to subvert the flow rates dictated by the law in order to develop a market. Unfortunately, EPAct did not anticipate all the means in which the law would be violated. Plumbers have installed multiple shower risers in single shower compartments, thereby exceeding the flow rate. Plumbing fixture manufacturers now offer products to adapt shower arms to accommodate multiple showerheads, which also exceed the flow rate. Products violating the EPAct requirements are now marketed as body spas, shower trees, rain machines, etc.; as attempts to exceed the allowable flow rate. Violations of the federal law are growing, as reported in various plumbing trade publications, including: Reeves Journal, HousingZone.com newsletter, Supply House Times, Plumbing & Heating contractor News, and Kitchen & Bath Design News. Many of these trade journals claim the multiple showerhead systems are the fastest growing trend in the home building industry. The proposed amendment is not arbitrary in its limitations, and the proposal accommodates gang showers. The typical home shower stall, appropriate for one user at a time, is approximately 1,800 square inches. The UPC already sets the minimum shower stall area at 1,024 square inches, While 1,024 square inches is reasonable for a single user alone in the shower stall, it is not reasonable to expect two users could simultaneously shower in a space less than 2,500 square inches without repeated body-to-body contact each user is assured of at least 2,000 square inches of personal space in the shower stall. ADA requirements are not affected by this proposal, for there is no limit to the size of a shower stall, or accessibility to showerhead or controls. As a non-substantive edit, we request the definitions in the proposed language be deleted as unnecessary, or moved to Chapter 2 Definitions as appropriate. 44

45 We at Valencia Water Company understand IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past five years, Valencia Water Company has spent more than $400, dollars to improve water efficiency, with $200, being spent in 2007 alone. Valencia Water Company substantially stepped up its water efficiency measures in 2006/2007 and we plan to continue this into the future. Our conservation budget for is approximately $250,000.00, but will grow as opportunities for water efficiency present themselves. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one shower head per 2,300 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. Item # 39 Comment Seq # 22 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revise text as follows: Prohibited Urinals. Floor-type and wall-hung type trough urinals shall be prohibited. Urinals that have an invisible seal a mechanical trap of any type, or that have an unventilated space or wall that is not thoroughly washed at each discharge shall be prohibited. This clarification is necessary to protect the public health and safety. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed language is addressed in Section for prohibited traps. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting Request to accept the code change proposal as submitted by this public comment. The Technical Committee s reason for rejection was that this requirement is covered in Section This action was taken before the committee and accepted with amendment for Item 142. While their 45

46 action does clarify that bladders, check valves and other types of devices with moveable parts are not traps and thus prohibited from use as traps in general, it still needs to be emphasized in Section as there are IAPMO listed urinals that utilize these types of devices due to a misunderstanding of what a mechanical trap is. Reinforcement is good when necessary to protect health and safety. Item # 50 Comment Seq # 23 UPC SUBMITTER: John Halliwill Halliwill and Associates Revise text as follows: Fixture requirements for Special Occupancies Additional fixtures may be required when unusual environmental conditions or special activities are encountered. (1) For Sanitation - Nonsewered Waste-Disposal Systems - Minimum Requirements shall conform to the standards listed in Table (2) For Sanitation - In Fields and Temporary Labor Camps - Minimum Requirements shall conform to the standards listed in Table This change is needed and the standards referenced so that the AHJ has guidance on how to install these types of installations. The ANSI Z4.3 standard gives additional guidance in addition to those requirements contained in ANSI Z4.1. Additionally ANSI Z4.4 give guidance to an issue that is not currently covered in the UPC. The current requirements in Appendix E do not give any guidance on how to make these installations and only gives guidance for Manufactured/MH Parks and RV Parks. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Arnie Rodio, Pace Setter Plumbing Corp. Request to reject the code change proposal by this public comment. I disagree with the committee decision to approve. This standard has nice titles but is actually very far reaching in its impact. Almost every provision is outside the realm of a plumbing contractor. For example, Section requires drinking water every 200. Does this mean he plumbing contractor has to ensure water stations every 200 on a larger project? Are plumbers now responsible for the porta-potties? Under Section 3.2 expectorating are plumbers now on split patrol. This standard while worthwhile does not belong in the plumbing code. Read it. 46

47 Item # 52 Comment Seq # 24 UPC SUBMITTER: John Halliwill Halliwill and Associates Revise text as follows: Toilet Facilities for Workers. Suitable toilet facilities shall be provided and maintained in a sanitary condition for the use of workers during construction. These facilities shall conform to the standards listed in Table 14-1 or other requirements as established by the Authority Having Jurisdiction. The existing ANSI Z For Sanitation - In Places of Employment - Minimum Requirements and the proposed ANSI Z For Sanitation - Nonsewered Waste Disposal Systems - Minimum Requirements along with ANSI Z For Sanitation - In Fields and Temporary Labor - Minimum Requirements contain methods and installations that can be used to meet the requirements of this section. This revision will give guidance to the AHJ on how to comply with this code section. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Arnie Rodio, Pace Setter Plumbing Corp. Request to reject the code change proposal by this public comment. I disagree with the committee decision to approve. This standard has nice titles but is actually very far reaching in its impact. Almost every provision is outside the realm of a plumbing contractor. For example, Section requires drinking water every 200. Does this mean he plumbing contractor has to ensure water stations every 200 on a larger project? Are plumbers now responsible for the porta-potties? Under Section 3.2 expectorating are plumbers now on split patrol. This standard while worthwhile does not belong in the plumbing code. Read it. Item # 54 Comment Seq # 25 UPC SUBMITTER: William Chapin Cash Acme Revise text as follows: Limitation of Hot Water Temperature for Public Lavatories. Hot water delivered from public-use lavatories shall be limited to a maximum temperature of 120 F by a device that conforms to ASSE The water heater thermostat shall not be considered a control for meeting this provision. 47

48 This wording is consistent with what has been adopted for Showers in Section Historically, past Technical Committees have wished that the Code keep standards referenced as part of Chapter 14; however it is a matter of public safety to specify the correct standard in the proposed text. There are several ASSE Standards for temperature control referenced in Chapter 14 and there is no guidance in that chapter for the installer to differentiate between a water distribution device and a device designed to limit temperature at the point of use. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Shawn Martin, Plumbing Manufacturers Institute Request to accept the code change proposal as modified by this public comment Limitation of Hot Water Temperature for Public Lavatories. Hot water delivered from public-use lavatories shall be limited to a maximum temperature of 120 F by a device that conforms to ASSE 1070 or CSA B The water heater thermostat shall not be considered a control for meeting this provision. CSA B125.3 is an equivalent standard, and should therefore be included. Including CSA B125.3 would provide harmonization with the requirements of the International Plumbing Code. Item # 56 Comment Seq # 26 UPC SUBMITTER: William Chapin Cash Acme Revise text as follows: Limitation of Hot Water in Bathtubs and Whirlpool Bathtubs. The maximum hot water temperature discharging from the bathtub and whirlpool bathtub filler shall be limited to 120 F by a device that conforms to ASSE The water heater thermostat shall not be considered a control for meeting this provision. This wording is consistent with what has been adopted for Showers in Section Historically, past Technical Committees have wished that the Code keep standards reference as part of Chapter 14; however it is a matter of public safety to specify the correct standard in the proposed text. There are several ASSE Standards for temperature control referenced in Chapter 14 and there is no guidance in that chapter for the installer to differentiate between a water distribution device and a device designed to limit temperature at the point of use. COMMITTEE ACTION: Accept as Submitted 48

49 A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Shawn Martin, Plumbing Manufacturers Institute Request to accept the code change proposal as modified by this public comment Limitation of Hot Water in Bathtubs and Whirlpool Bathtubs. The maximum hot water temperature discharging from the bathtub and whirlpool bathtub filler shall be limited to 120 F by a device that conforms to ASSE 1070 or CSA B The water heater thermostat shall not be considered a control for meeting this provision. CSA B125.3 is an equivalent standard, and should therefore be included. Including CSA B125.3 would provide harmonization with the requirements of the International Plumbing Code. Item # 57 Comment Seq # 27 UPC SUBMITTER: William Chapin Cash Acme Add new text as follows: Limitation of Water Temperature in Bidets. The maximum hot water temperature discharging from a bidet shall be limited to 110 o F (43 o C) by a device that conforms to ASSE The water heater thermostat shall not be considered a control for meeting this provision. Scald injuries do occur in bidets, and the reaction from an unexpected blast of hot water can lead to serious injury to the user. Over the last several years an ASSE working group has been developing a more comprehensive suite of standards for water temperature control devices. One of the resulting standards, ASSE 1070, is specifically intended for this type of application. This wording is consistent with what has been adopted for Bathtubs, Whirlpools and Showers. Historically, past Technical Committees have wished that the Code keep standards referenced as part of Chapter 14; however it is a matter of public safety to specify the correct standard in the proposed text. There are several ASSE Standards for temperature control referenced in Chapter 14 and there is no guidance in that chapter for the installer to differentiate between a water distribution device and a device designed to limit temperature at the point of use. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Shawn Martin, Plumbing Manufacturers Institute 49

50 Request to accept the code change proposal as modified by this public comment Limitation of Water Temperature in Bidets. The maximum hot water temperature discharging from a bidet shall be limited to 110 o F (43 o C) by a device that conforms to ASSE 1070 or CSA B The water heater thermostat shall not be considered a control for meeting this provision. CSA B125.3 is an equivalent standard, and should therefore be included. Including CSA B125.3 would provide harmonization with the requirements of the International Plumbing Code. Item # 61 Comment Seq # 28 UPC 2009 Table 4-1, Footnotes, Table A SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #61). Item 1 Delete text without substitution: Table 4-1 Minimum Plumbing Facilities 1 Type of Building Or Occupancy 2 Restaurants, pubs, and Offices 14, 15, A unisex facility (one water closet and one lavatory) may be used when the customer occupant load for the dining area, including outdoor seating area, is 10 or less and the total number of employees for the space is 4 or less. (Renumber remaining footnotes) Item 2 Revise text as follows: Table 4-1 Minimum Plumbing Facilities 1 Each building shall be provided with sanitary facilities, including provisions for persons with disabilities as prescribed by the Department Having Jurisdiction. For requirements for persons with disabilities, ICC/ANSI A117.1, Accessible and Usable Buildings and Facilities, may be used. The total occupant load shall be determined by minimum exiting requirements. The minimum number of fixtures shall be calculated at fifty (50) percent male and fifty (50) percent female based on the total occupant load. 50

51 The occupant load and use of the building or space under consideration shall first be established using the Occupant Load Factor Table A. Once the occupant load and uses are determined, the requirements of Section and Table 4-1 shall be applied to determine the minimum number of plumbing fixtures required. This table applies to new buildings, additions to a building, changes of occupancy or type in an existing building resulting in increased occupant load (example: change an assembly room from fixed seating to open seating). Exception: New cafeterias for employee use are the only use exempted from this requirement. Item 3 Delete Table A without substitution: Table A. Occupant Load Factor: Occupancy*, ** Occupant Load Factor (square feet) (CBC 2001, Table A-29A) Group A 1. Auditoriums, convention halls, dance floors, 15 lodge rooms, stadiums, and casinos (where no fixed seating is provided) (use 1/2 one-half the number of fixed seating) 2. Conference rooms, dining rooms, drinking establishments, exhibit rooms, gymnasiums, 30 lounges, stages, and similar uses, including restaurants classified as Group B occupancies 3. Worship places; principal assembly area, educational and activity unit 30 (use 1/2 one-half the number of fixed seating) (where no fixed seating is provided) Group B Office or public buildings (area accessible to 200 the public) Group E Schools for daycare, elementary, secondary 50 Educational Facilities Other than Group E Colleges, universities, adult centers, etc. 50 Group F Workshops, foundries and similar establishments 2,000 Group H Hazardous materials fabrication and storage 2,000 Group I Hospital general use area, health care facilities 200 Group M Retail or Wholesale stores 200 Group R Congregate residence, Group R Group S Warehouse 5,000 * Any uses not specifically listed shall be based on similar uses listed in this table. ** For building or space with mixed occupancies, use appropriate occupancy group for each area (for example, a school may have an A occupancy for the gymnasium, a B occupancy for the office, an E occupancy for the classrooms, etc.) Accessory areas may be excluded (for example: hallway, restroom, stair enclosure) 51

52 Substantiation for Item 1 Table 4-1 footnote 16 indicates that a unisex facility (one water closet and one lavatory) may be used when the customer occupant load for the dining area, including outdoor seating area, is 10 or less and the total number of employees for the space is 4 or less. This footnote appears in the entry for Restaurants, pubs and lounges. Section indicates that an exception for separate facilities for occupancies serving 10 or fewer people, one toilet facility designed for both sexes may be used. This would include all occupancies including restaurants, pubs and lounges. A conflict exists between Section and Footnote 16 of Table 4-1. Recommend the deletion of footnote 16 and use Section the exception for separate facilities for all occupancies. Substantiation for Item 2 Table 4-1 Minimum Plumbing Facilities- Additional language was added to the 2006 UPC under the heading for Table 4-1 Minimum Plumbing Facilities, which states in the third paragraph the occupant load and the use of the building or space under consideration shall be first established using the Occupant Load Factor Table A. This conflicts with the second paragraph that the total occupant load shall be determined by minimum exiting requirements. Recommend using the language that the Building Code determines the occupant load. Substantiation for Item 3 Table A Occupant Load Factor references the occupant load factor based on the (CBC 2001, Table A- 29A) and this conflicts with the intent that the code references the building code without specifying any particular building code. In addition, this table conflicts with the building code that uses occupant load factors as a means of exiting requirements. The building code determines occupant load factors on means of egress and exiting components. These factors are used to estimate the maximum number of occupants that are likely to use the building at the same time and expressed in floor area in square feet. Plumbing codes determine the minimum number of plumbing fixtures required based on the occupant load. Trying to mix and match egress requirements with minimum number of plumbing fixtures creates conflicts with the building code. Rather than using egress requirements or occupant load factors the minimum number of plumbing fixtures should be revised to take into account that a far greater number will be calculated using the egress components as the actual number of occupants. Many plumbing codes have been revised to take into account that exiting requirements produce a higher occupant load and revise plumbing fixtures accordingly or reduce the occupant load by 2/3 and apply the table. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Larry Brown, National Association of Home Builders Request to accept the code change proposal as modified by this public comment. Item 1 (Remains unchanged) Item 2 Table 4-1 Minimum Plumbing Facilities 1 Each building shall be provided with sanitary facilities, including provisions for persons with disabilities as prescribed by the Department Having Jurisdiction. For requirements for persons with disabilities, ICC/ANSI A117.1, Accessible and Usable Buildings and Facilities, may be used. 52

53 (Moved up in order of reading) This Table 4-1 applies to new buildings, additions to a building, and changes of occupancy or use type in an existing building resulting in increased occupant load (example: change an assembly room from fixed seating to open seating). Exception: New cafeterias used only by for employees use are the only use exempted from this requirement. The total occupant load shall be determined in accordance with the Building Code by minimum exiting requirements. The type of building or occupancy shall be determined based on the actual use of the various spaces within the building. Building categories not shown in Table 4-1 shall be considered separately by the Authority Having Jurisdiction. The minimum number of fixtures shall be calculated at fifty (50) percent male and fifty (50) percent female based on the total occupant load. Once the occupant load and uses are determined, the requirements of Section and Table 4-1 shall be applied to determine the minimum number of plumbing fixtures required. Item 3 (Remains unchanged) (1) The second sentence in the first paragraph is stricken, as the A117.1 Standard does not dictate how many fixtures to install, it provides the installation requirement on how to install the required number of fixtures. Section 201 of A states: 201 General. This standard provides technical criteria for making sites, facilities, buildings, and elements accessible. The administrative authority shall provide scoping provisions to specify the extent to which these technical criteria apply. These scoping provisions shall address the application of this standard to: each building and occupancy type; new construction, alterations, temporary facilities, and existing buildings; specific site and building elements; and to multiple elements or spaces provided within a site or building. (2) The second paragraph and Exception (as shown above) are moved from being the last paragraph of the Section as this reading order is more logical to the application of the text. (3) The Exception is modified to provide more direct, enforceable language. The example text is stricken is it is commentary and not enforceable. (4) The third paragraph is modified to correlate with the actual minimum occupancy that would be required by the Building Code. In fact, the exit capacity does not dictate the minimum number of occupants allowed by the Building Code, it is provisions in the IBC itself that first sets the occupancy based on occupancy Group Type, and square footage. Once the occupancy load has been determined, the elements of egress (the number of exits, the width of stairs, doors, etc.) are then design to accommodate the occupant load. Item # Comment Seq # 29 UPC (1) SUBMITTER: UPC Technical Committee Proposal Revise text as follows: Location (1) Fuel-burning water heaters may be installed in a closet located in the bedroom or bathroom provided the closet is equipped with a listed, gasketed door assembly and a listed self-closing device. The self- 53

54 closing door assembly shall meet the requirements of Section The door assembly shall be installed with a threshold and bottom door seal and shall meet the requirements of Section All combustion air for such installations shall be obtained from the outdoors in accordance with Section The closet shall be for the exclusive use of the water heater. (1) Water heaters shall be installed in a closet equipped with a weather-stripped door with no openings, and with a self-closing device. All combustion air shall be obtained from the outdoors in accordance with Section (Remainder of text unchanged) This revision is proposed to harmonize the requirements of NFPA 54 and the UPC on the subject by extracting the updated requirements in NFPA 54. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Martin Cooper, Central California Chapter IAPMO Request to reject the code change proposal by this public comment. Current code language is preferred. As written, current language directs the user to specific sections of the code. The current language protects the public, if a water heater is to be installed in a bedroom closet or bathroom closet. Item # 66 Comment Seq # 30 UPC SUBMITTER: Ted Lemoff, NFPA Revise text as follows: Location. Water heater installations in bedrooms and bathrooms shall comply with one of the following [NFPA 54: ]: (1) Fuel-burning water heaters may be installed in a closet located in the bedroom or bathroom provided the closet is equipped with a listed, gasketed door assembly and a listed self-closing device. The selfclosing door assembly shall meet the requirements of Section The door assembly shall be installed with a threshold and bottom door seal and shall meet the requirements of Section All combustion air for such installations shall be obtained from the outdoors in accordance with Section The closet shall be for the exclusive use of the water heater. (2) Water heater shall be of the direct vent type. [NFPA 54: ] (For informational purposes) Self-Closing Doors. Self-closing doors shall swing easily and freely and shall be equipped with a self-closing device to cause the door to close and latch each time it is opened. The closing mechanism shall not have a hold open feature. [NFPA 80: ] 54

55 Self-closing doors shall swing easily and freely and shall be equipped with a closing device to cause the door to close and latch each time it is opened. The closing mechanism shall not have a hold-open feature.[nfpa 80: ] Gasketing. Gasketing on gasketed doors or frames shall be furnished only in accordance with the published listings of the doors, frame, or gasketing material manufacturer. Gasketing on fire doors or frames shall be furnished only in accordance with the published listings of the door, frame, or gasketing material manufacturer. [NFPA 220:6.4.8] Exception: Where acceptable to the Authority Having Jurisdiction, gasketing of noncombustible or limited-combustible material (see NFPA 220) Standard on Types of Building Construction) shall be permitted to be applied to the frame, provided closing and latching of the door are not inhibited. [NFPA 80:2-4.8] Text extracted from NFPA , paragraph is substituted for coverage of the same subject in the UPC to coordinate coverage of this subject. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Martin Cooper, Central California Chapter IAPMO Request to reject the code change proposal by this public comment. Current code language is preferred. The code change proposed by the Technical Committee would only apply to fire-rated assemblies. The current language is specific to listed gasketed, self closing assemblies in a bedroom or bathroom closet containing a water heater. Item # 71 Comment Seq # 31 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revise text as follows: Gas Equipment Physical Protection. Where it is necessary to locate gas utilization equipment close to a passageway traveled by vehicles or equipment, excess flow valves shall be installed in addition to guardrails or bumper plates shall be installed to protect the gas service and equipment from damage. [NFPA 54:9.1.13] This code change adds mandatory requirements for excess flow valves in dangerous and potential accident locations that will protect the health and safety of occupants should such incidents occur. 55

56 COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed text would not protect the equipment from damage in most cases. No substantiation is provided that any problem exists. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting Request to accept the code change proposal as submitted by this public comment. The Technical Committee s reason for rejection was that it does not protect the equipment. This proposal is to protect the gas service and any code change that adds added protection in a hazardous situation should be considered. Item # Comment Seq # 32 UPC SUBMITTER: UPC Technical Committee Proposal Revise text as follows: Well-Ventilated Spaces The operation of industrial appliances such that its flue gases are discharged directly into a large and well-ventilated space shall be permitted. Industrial Occupancies. Where appliances in industrial occupancies are located in ventilated areas such that the discharge of products of combustion does not present a health hazard, the appliance shall not be required to be vented. [54:12.3.4] The current text terms large and well-ventilated are not defined, nor is the term industrial appliance. This invites a broad range of interpretations. Current text would allow an industrial appliance (whatever that is) to be installed in any occupancy without venting it. Only the type of appliance, not the occupancy is addressed. The proposed text nails down the scope to industrial occupancies which is the intent and also spells out the intent regarding large and well-ventilated. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA 56

57 Request to reject the code change proposal by this public comment. This comment proposes a revision that was made in the 2008 edition of NFPA 54. The requirement was further revised as the revisions made in he proposal would have required the code official to determine if a health hazard exists, which is not reasonable. Item # Comment Seq # 33 UPC SUBMITTER: UPC Technical Committee Proposal Add new text as follows: Where vents, including those for direct-vent appliances, penetrate outside walls of buildings, the annular spaces around such penetrations shall be permanently sealed using approved materials to prevent entry of combustion products into the building. [NFPA 54:12.9.5] Experience has shown and common sense suggests that under conditions of heavy snowfall, sidewall vent terminals can become buried in snow and combustion gases can enter the building through gaps around the wall penetrations. The combustion gases can melt a cavity within the snowdrift, which might allow the appliance to continue operating instead of shutting down due to vent failure. The danger is even worse for direct vent appliances because the combustion products can be drawn into the outdoor intake and recycled through the appliance, thereby greatly increasing the concentration of CO. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment Where vents, including those for direct-vent appliances or combustion air intake pipes, penetrate outside walls of buildings, the annular spaces around such penetrations shall be permanently sealed using approved materials to prevent entry of combustion products into the building. [NFPA 54:12.9.5] This comment proposes a revision that was made in the 2008 edition of NFPA 54. The requirement was revised to make it applicable to air intake pipes as well as vents to ensure that all buildings penetrations are sealed. This is based on an incident where the space around an direct-vent combined intake/exhaust pipe resulted in high carbon monoxide levels in the building. 57

58 Item # Comment Seq # 34 UPC SUBMITTER: UPC Technical Committee Proposal Revise text as follows: Slope. A vent connector shall be installed without any dips or sags and shall slope upward toward the vent or chimney at least 1/4 in./ft. (20 mm/m). [NFPA 54: ] Exception: Vent connectors attached to a mechanical draft system installed in accordance with the draft system manufacturer s instructions. This change clarifies that the draft system manufacturer s instruction must be followed. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment Slope. A vent connector shall be installed without any dips or sags and shall slope upward toward the vent or chimney at least 1/4 in./ft. (20 mm/m). [NFPA 54: ] Exception: Vent connectors attached to a mechanical draft system installed in accordance with the appliance and draft system manufacturer s instructions. This comment proposes a revision that was made in the 2008 edition of NFPA 54. This revision recognizes that the appliance manufacturers instructions should be used, as well as the draft system s installation instructions. Item # Comment Seq # 35 UPC , SUBMITTER: UPC Technical Committee Proposal Revise text as follows: Elbows. Single-appliance venting configurations with zero (0) lateral lengths in Tables 5-8, 5-9, and 5-12 shall have no elbows in the venting system. For vent configurations Single-appliance venting with lateral lengths the venting tables include allowance for two 90-degree turns elbows. For each additional elbow up to and including 45 degrees, the maximum capacity listed in the venting tables shall 58

59 be reduced by 5 percent. For each additional elbow greater than 45 degrees up to and including 90 degrees, the maximum capacity listed in the venting tables shall be reduced by 10 percent. Where multiple offsets occur in a vent, the total lateral length of all offsets combined shall not exceed that specified in Tables 5-8 through [NFPA 54:13.1.3] Vent Offset. Where the common vertical vent is offset, the maximum capacity of the common vent shall be reduced in accordance with and the horizontal length of the common vent offset shall not exceed 18 in./in. (180 mm/mm) of common vent diameter. Where multiple offsets occur in a common vent, the total horizontal length of all offsets combined shall not exceed the total height of the vent. [NFPA 54:13.2.5] The code is currently silent on the maximum number of offsets, which can reduce vent performance. A new requirement is added based on performance requirements. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment Elbows. No change to text Vent Offset. Where the common vertical vent is offset, the maximum capacity of the common vent shall be reduced in accordance with and the horizontal length of the common vent offset shall not exceed 18 in./in. (180 mm/mm) of common vent diameter. Where multiple offsets occur in a common vent, the total horizontal length of all offsets combined shall not exceed the total height of the vent 18 in./in. (180 mm/mm) of common vent diameter. [NFPA 54:13.2.5] This comment proposes a revision that was made in the 2008 edition of NFPA 54. The revision corrects an error in this requirement, which limits the offset in a common vent based on the diameter, not the height, which is not correct. Item # 76 Comment Seq # 36 UPC SUBMITTER: Michael Cudahy Plastic Pipe and Fitting Association (PPFA) Revise text as follows: Identification of a Potable and Nonpotable Water Systems. In all buildings where potable water and nonpotable water systems are installed, each nonpotable system shall be clearly identified. Each system shall be identified with a colored pipe or band and coded as follows with paints, wraps and materials compatible with the piping. 59

60 Potable Water - Green background with white lettering Nonpotable Water - Yellow Purple (Pantone color #512) background with black uppercase lettering, with the words Caution: Nonpotable water, do not drink. CAUTION: NONPOTABLE WATER, DO NOT DRINK. Each system shall be identified with a colored band to designate the liquid being conveyed, and the direction of normal flow shall be clearly shown. The minimum size of the letters and length of the color field shall conform to Table 6-1. If used, aa colored identification band shall be indicated every twenty (20) feet (6,096 mm) but at least once per room, and shall be visible from the floor level. Marking is not required for concealed plastic or composite pipe manufactured with purple color integral to the pipe and marked with black uppercase lettering to read CAUTION: NONPOTABLE WATER, DO NOT DRINK in intervals not to exceed five (5) feet (1,524mm). Where vacuum breakers or backflow preventers are installed with fixtures listed in Table 14-1, identification of the discharge side may be omitted. Each outlet on the nonpotable water line that could be used for special purposes shall be posted with black uppercase lettering as follows: Caution: Nonpotable water, do not drink. CAUTION: NONPOTABLE WATER, DO NOT DRINK Reclaimed Water - Purple (Pantone color #512) background and shall be imprinted in nominal 1/2-inch (12.7 mm) high, with black uppercase letters lettering, with the words Caution: Reclaimed water, do not drink. CAUTION: NONPOTABLE WATER, DO NOT DRINK. The minimum size of the letters and length of the color field shall conform to Table 6-1. Where used, a colored identification band shall be indicated every twenty (20) feet (6,096 mm) not less than once per room, and shall be visible from the floor level. Marking is not required for enclosed plastic or composite pipe manufactured with purple color integral to the pipe and marked with black uppercase lettering to read CAUTION: RECLAIMED WATER, DO NOT DRINK in intervals not to exceed five (5) feet (1,524 mm). With an increasing focus, and implementation of green building plumbing such as rainwater collection, gray water, and reclaimed water systems, it is time to examine and simplify pipe marking requirements. Why mark the potable side at all? Why not simply use purple piping for all non-potable or reclaimed water? Plastic and composite pipes can and are being manufactured with color integral to the pipe. Marking requirements for piping systems in ASTM standards are set at 5 feet. CSA B Design and installation of non-potable water systems / Maintenance and field testing of non-potable water systems: has a simple requirement such as this for non-potable systems, which in some cases may even be combined - rainwater and gray water, for example. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Proposed items dealing with rainwater collection, gray water and reclaimed water is referred to a task group for further study because the technical committee will need additional information to make informed decisions in regards to the proposed text. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Dave Cantrell, Chair (UPC Gray Water and Reclaimed Water Task Group) 60

61 The following is recommended by the Gray Water and Reclaimed Water Task Group (see Gray Water and Reclaimed Water Task Group Report for Item #76). Request to accept the code change proposal as modified by this public comment Identification of a Potable and Nonpotable Water Systems. In all buildings where potable water and nonpotable water systems are installed, each nonpotable system shall be clearly identified in accordance with Sections through Each system shall be color coded as follows Potable Water - Green background with white lettering Color and Information - Each system shall be identified with a colored pipe or band and coded with paints, wraps and materials compatible with the piping Nonpotable Water Except as required in Sections and , Yellow background nonpotable water systems shall have a yellow background with black uppercase lettering, with the words Caution: Nonpotable water, do not drink. CAUTION: NONPOTABLE WATER, DO NOT DRINK. Each nonpotable system shall be identified with a colored band to designate the liquid being conveyed, and the direction of normal flow shall be clearly shown. The minimum size of the letters and length of the color field shall conform to Table 6 1. A colored identification band The background color and required information shall be indicated every twenty (20) feet (6,096 mm) but at least not less than once per room, and shall be visible from the floor level Fixtures - Where vacuum breakers or backflow preventers are installed with fixtures listed in Table 14 1, identification of the discharge side may shall be permitted to be omitted Outlets - Each outlet on the nonpotable water line that could be is used for special purposes shall be posted with black uppercase lettering as follows: Caution: Nonpotable water, do not drink. CAUTION: NONPOTABLE WATER, DO NOT DRINK Reclaimed Water Purple (pantone color #512) background and shall be imprinted in nominal ½-inch (12.7 mm) high, black uppercase letters, with the words Caution: Reclaimed water, do not drink. The Task Group agreed with the submitter s substantiation regarding the simplification of pipe marking systems. The Task Group is recommending further modifications to consolidate, harmonize and clarify gray water and reclaimed water pipe material, marking and information provisions of Chapter 6 and 16. In developing this recommendation, the Task Group also considered Items 217, 220, and 221. Item # 84 Comment Seq # 37 UPC , Table 6-4 SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #84). Item 1 Revise as follows: 61

62 604.1 All pipe, tube, and fittings carrying water used in potable water systems intended to supply drinking water shall meet the requirements of NSF 61 as found in Table All materials used in the water supply system, except valves and similar devices, shall be of a like material, except where otherwise approved by the Authority Having Jurisdiction. Materials for building water piping and building supply piping shall be in accordance with one of the referenced standards in Table 6-4. and the standards in Table 14-1 Item 2 Delete Table 6-4 and replace as follows: Material Water Distribution Pipe and Fittings Building Supply Pipe and Fittings Table 6-4 Referenced Standard(s) Pipe PEX-AL-PEX X X ASTM F 1281, CSA B , ASTM F 2262 PVC X 1 ASTM D 1785, ASTM D 2241, AWWA C For Building Supply or cold-water applications. Referenced Standard(s) Fittings Asbestos-Cement X ASTM C 296, AWWA C400 ASME B16.4, ASME B16.12 Brass X X ASTM B 43, ASTM B135 Copper X X ASTM B 42, ASTM B 75, ASTM B 88, ASTM B 251, ASTM B 302, ASME B 16.15, ASME B 16.18, ASME B 16.22, ASME B16.26 ASTM B 447 Cast-Iron X X AWWA C151 AWWA C 110, AWWA C153, ASME B16.4 CPVC X X ASTM D 2846, ASTM F ASTM D 2846, ASTM F , ASTM F 439 Malleable Iron X X ASME B 16.3 Galvanized Steel X X ASTM A 53 PE X 1 ASTM D 2239, ASTM D 2737, AWWA C901, ASTM D 2609, CSA B137.1 CSA B137.1 PE-AL-PE X X ASTM F 1282, CSA B137.9 ASTM F 1974, CSA B137.9 PEX X X ASTM F876, ASTM F 877, CSA B137.5 ASTM F 877, ASTM F 1807, ASTM F1960, ASTM F 1961, ASTM F 2080, ASTM F 2159, CSA B137.5 ASTM F 1974, ASTM F 2434, CSA B ASTM D2464, ASTM D 2466, ASTM D2467 This table was revised to correlate with Chapter 6 and the type of materials/standards referenced. All standards listed in this table are already located in Table Because of the misconception of the referenced standard required, the applicable standards were added to provide the necessary information and to assist the user. COMMITTEE ACTION: Accept as Submitted 62

63 A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION PUBLIC COMMENT 1: Submitter: Leon Manian, Ductile Iron Pipe Research Association Request to accept the code change proposal as modified by this public comment. Material Water Distribution Pipe and Fittings (Portions of Table not shown do not change) (Standard(s) was provided for review) Table 6-4 Building Supply Pipe and Fittings Referenced Standard(s) Pipe There is no cast-iron pipe manufactured in the U.S. only cast-iron fittings are manufactured. Referenced Standard(s) Fittings Cast-Iron Ductile Iron x x AWWA C151 AWWA C153, ASME B16.4, AWWA C110 PUBLIC COMMENT 2: Submitter: David Ash, Lubrizol Advanced Materials Request to accept the code change proposal as modified by this public comment. Material Building Supply Pipe and Fittings Table 6-4 Water Distribution Pipe and Fittings Referenced Standard(s) Pipe CPVC x x ASTM D 2846, ASTM F 441, ASTM F 442 Referenced Standard(s) Fittings ASTM D 2846, ASTM F 437, ASTM F 438, ASTM F 439, ASTM F 1970 (Portions of Table not shown do not change) (Standard(s) was provided for review) ASTM F 1970 Standard Specification for Special Engineered Fittings, Appurtenances or Valves for use in Poly (Vinyl Chloride) (PVC) or chlorinated Poly (Vinyl Chloride) (CPVC) Systems contains fittings for PVC and CPVC systems and is currently listed in Table It should be included in Table 6-4. ASTM F 438 Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 40 contains fittings for CPVC and is currently listed in Table It should be included in Table 6-4. ASTM F 442 Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe (SDR-PR), and is currently listed in Table It should be included in Table

64 The Building Supply pipe column should precede the Water Distribution pipe column. PUBLIC COMMENT 3: Submitter: Michael Cudahy, Plastic Pipe and Fittings Association (PPFA) Request to accept the code change proposal as modified by this public comment. Material Building Supply Pipe and Fittings Table 6-4 Water Distribution Pipe and Fittings Referenced Standard(s) Pipe CPVC X X ASTM D 2846, ASTM F 441, ASTM F 442 PE X 1 ASTM D 2239, ASTM D 2737, ASTM D 3035, AWWA C901, CSA B137.1 PE-AL-PE X X ASTM F 1282, CSA B137.9 PEX-AL-PEX X X ASTM F 1281, CSA B , ASTM F 2262 PVC X 1 ASTM D 1785, ASTM D 2241, AWWA C900 Referenced Standard(s) Fittings ASTM D 2846, ASTM F 437, ASTM F 438, ASTM F 439, ASTM F 1970 ASTM D 2609, ASTM D 2683, ASTM D 3261, ASTM F 1055, CSA B137.1 ASTM F 1282, ASTM 1974, CSA B137.9 ASTM F 1281, ASTM F 1974, ASTM F 2434, CSA B ASTM D 2464, ASTM D 2466, ASTM D 2467, ASTM F 1970 (Portions of Table not shown do not change) (Standard(s) was provided for review) ASTM D 3035 PE pipe and ASTM D 2683, ASTM D 3261, and ASTM F 1055 PE fittings should be included in the table. ASTM F 1970, F 438, F 1281, F 1282 and F 2262 should be included in the fittings column as they contain fittings information. ASTM D 3035 Standard Specification for Polyethylene (PE) Plastic Pipe (DR-PR) Based on Controlled Outside Diameter is pipe suitable for the application and is listed in Table ASTM D 2683 Standard Specification for Socket-Type Polyethylene Fittings for Outside Diameter- Controlled Polyethylene Pipe and Tubing contains fittings for D 3035 PE pipe. ASTM D 3261 Standard Specification for Butt Heat Fusion Polyethylene (PE) Plastic Fittings for Polyethylene (PE) Plastic Pipe and Tubing contains fittings for D 3035 PE pipe. ASTM F 1055 Standard Specification for Electrofusion Type Polyethylene Fittings for Outside Diameter Controlled Polyethylene Pipe and Tubing contains fittings for D 3035 PE pipe. 64

65 ASTM F 1970 Standard Specification for Special Engineered Fittings, Appurtenances or Valves for use in Poly (Vinyl Chloride) (PVC) or Chlorinated Poly (Vinyl Chloride) (CPVC) Systems contains fittings for PVC and CPVC systems and is listed in Table ASTM F 438 Standard Specification for Socket-Type Chlorinated Poly(Vinyl Chloride) (CPVC) Plastic Pipe Fittings, Schedule 40 contains fittings for CPVC and is listed in Table ASTM F 442 Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe (SDR-PR), and is listed in Table ASTM F 1281 Standard Specification for Crosslinked Polyethylene/Aluminum/Crosslinked Polyethylene (PEX-AL-PEX) Pressure Pipe contains fitting information and is listed in Table ASTM F 1282 Standard Specification for Polyethylene/ Aluminum/ Polyethylene (PE-AL-PE) Composite Pressure Pipe contains fitting information and is listed in Table Finally, the table would seem to make more logical sense if the supply pipe was moved before the distribution pipe column. Item # 85 Comment Seq # 38 UPC 2009 Table 6-4 SUBMITTER: James Paschal Bodycote Revise text as follows: TABLE 6-4 Material Water Distribution Pipe and Fittings Building Supply Pipe and Fittings Hot Cold Asbestos - Cement X Brass X X X Copper X X X Cast Iron X X X CPVC X X X Galvanized Malleable Iron X X X Galvanized Wrought Iron X X X Galvanized Steel X X X PE X X X PE-AL-PE X X X PEX X X X PEX-AL-PEX X X X PP X X X PVC X X X This proposal provides for an alternate plumbing material. These Polypropylene (PP) piping systems are manufactured, tested and listed in accordance with ASTM F 2389, and have been accepted in other model codes in the U.S. and Canada (IPC, NSPC, NPC). 65

66 * Copy of standard provided COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Robert Calone, State Code Compliance Request to reject the code change proposal by this public comment. 1) Proposal lacks sufficient substantiation. 2) Mere reference to standard ASTM F 2389 and to listings in other model codes is no sufficient substantiation to list this product in the body of the code. 3) Lack of data exists regarding use of this product for long-term hot and cold potable water systems. 4) Relevant leaching, permeability, life expectancy and durability studies and data were not provided; therefore no scientific data has been submitted to substantiate proposal. 5) No data was provided showing conformance with NSF 61. 6) Resistance to degradation from exposure to hot water, chlorine or commonly encountered household substances must be disclosed. PUBLIC COMMENT 2: Submitter: Eduardo Piazza, Industrias Saladillos.A. Request to accept the code change proposal as modified by this public comment. TABLE 6-4 Material Water Distribution Pipe and Fittings Building Supply Pipe and Fititngs Hot Cold Asbestos - Cement X Brass X X X Copper X X X Cast Iron X X X CPVC X X X Galvanized Malleable Iron X X X Galvanized Wrought Iron X X X Galvanized Steel X X X PE X X X PE-AL-PE X X X PEX X X X PEX-AL-PEX X X X PP X X X PP-AL-PP X X X PVC X X X 66

67 This Proposal provides for an alternate plumbing material. These Polypropylene (PP) piping systems are manufactured, tested and listed in accordance with ASTM F 2389, and have been accepted in other model codes in the U.S. and Canada (IPC, NSPC, NPC). PP have been accepted worldwide as for example: in Germany in accordance with standard DIN 8077 (first edition in 1974) and standard DIN 8078 (first edition in 1980); in Italy in accordance with standard UNI 8318 (first edition in 1981) and standard UNI 8321 (first edition in 1982); there exist a lot of background justifying the use of PP for cold and hot water installations that could be impossible to be listed here. This Proposal provides an alternate plumbing material. These Polypropylene-Aluminum-Polypropylene (PP-AL-PP) piping systems are manufactured, tested and listed in accordance with IAPMO IGC , and have been accepted by international standards as ISO 21003, UNI (Italy - first edition in 2001) and UNI (Italy - first edition in 2005) and O Norm B5157(Austria - first edition in 1999). PP-AL-PP, or polypropylene-aluminum-polypropylene, as well as PP, polypropylene, are reliable materials for distribution of hot and cold water supply networks. In attached (sent for 2007 Technical Committee Meeting): Listings NSF/ANSI Std.14; NSF/ANSI Std. 61 PIPE & FITTING; Polypropylene RA 130E-8427 Borealis Statement on compliance to food contact regulations ; Polypropylene RA 130E Borealis Statement on compliance to regulations for drinking water pipes ; Polypropylene RA 130E-8427 Borealis Environmental Fact Sheet ; Polypropylene RA 130E-8427 Borealis Statement on compliance to food contact regulations ; Polypropylene RA 130E-8427 Borealis Data Sheet ; Polypropylene RA 130E-8427 Borealis Regression analysis according to ISO/TR 9080 ; Petroquimica Cuyo SAIC Polypropylene SP311 Toxicological and environmental product information ; Petroquimica Cuyo SAIC Polypropylene SP311 Data Sheet ; Petroquimica Cuyo SAIC Polypropylene SP311 Regression analysis according to ISO/TR 9080 ; Petroquimica Cuyo SAIC Polypropylene SP311 Hydrostatic pressure testing Test report ; ASTM F 2389 Standard Specification for Pressure-Rated Polypropylene (PP) Piping Systems. Item # 94 Comment Seq # 39 UPC (New) SUBMITTER: James Paschal Bodycote Add new text as follows: Polypropylene (PP). PP piping shall be marked with the appropriate standard designation(s) listed in Table 14-1 for which the piping has been approved. PP piping shall be installed in compliance with the provisions of this section Heat-fusion joints. Heat-fusion joints for polypropylene (PP) pipe and fitting joints shall be installed with socket type heat-fused polypropylene fittings, butt-fusion polypropylene fittings or pipe, or electrofusion polypropylene fittings. Joint surfaces shall be clean and free from moisture. The joint shall be undisturbed until cool. Joints shall be made in accordance with ASTM F Mechanical and compression sleeve joints. Mechanical and compression sleeve joints shall be installed in accordance with the manufacturer s instructions. (Renumber remaining sections) This proposal provides for an alternate plumbing material. These Polypropylene (PP) piping systems are manufactured, tested and listed in accordance with ASTM F 2389, and have been accepted in other model codes in the U.S. and Canada (IPC, NSPC, NPC). Note: Copy of standard provided 67

68 COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Robert Calone, State Code Compliance Request to reject the code change proposal by this public comment. 1) Proposal lacks sufficient substantiation. 2) Mere reference to standard ASTM F 2389 and to listings in other model codes is no sufficient substantiation to list this product in the body of the code. 3) Lack of data exists regarding use of this product for long-term hot and cold potable water systems. 4) Relevant leaching, permeability, life expectancy and durability studies and data were not provided; therefore no scientific data has been submitted to substantiate proposal. 5) No data was provided showing conformance with NSF 61. 6) Resistance to degradation from exposure to hot water, chlorine or commonly encountered household substances must be disclosed. Item # 95 Comment Seq # 40 UPC (New) SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Add new text as follows: CPVC-AL-CPVC. Chlorinated poly (vinyl chloride)-aluminum-chlorinated poly (vinyl chloride) shall be marked with the appropriate standards designations listed in Table 14-1 for which the piping has been listed and approved. CPVC-AL-CPVC shall be installed in compliance with the manufacturers instructions and requirements of this code. (Renumber remaining sections) This code change recognized a somewhat new technology that is currently being produced and used on a limited basis. It has a NSF specification and an ASTM standard is under development and should be finished in time to be included in the 2009 code. The piping uses the same fittings currently approved for use with CPVC in the UPC (ASTM F438 and ASTM F439). COMMITTEE ACTION: Reject 68

69 COMMITTEE STATEMENT The proposed referenced standard is not available, therefore the committee is unable to substantiate the proposed text. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting Request to accept the code change proposal as submitted by this public comment. The Technical Committee s reason for rejection was that this standard was not completed and thus could not be reviewed. There has been progress and the standard should be completed in 2008 as part of ASTM D 2846 or a separate standard. Item # 96 Comment Seq # 41 UPC , , SUBMITTER: Eduardo Piazza Industrias Saladillo S.A PP-AL-PP. Polypropylene-aluminum-polypropylene (PP-AL-PP) pipe shall be marked with the appropriate standard designation(s) listed in Table 14 1 for which the piping has been listed or approved. PP-AL-PP piping shall be installed in compliance with the provisions of this section PP-AL-PP. Fittings used with PP-AL-PP Piping shall be manufactured to and marked in accordance with the standard for the fittings in Table Water Heater Connections. PP-AL-PP tubing shall not be installed within the first eighteen inches (18) (457 mm) of piping connected to a water heater. PP-AL-PP, or polypropylene-aluminum-polypropylene as well as PP, or polypropylene, are reliable materials for distribution of hot and cold water supply networks. In attached Listings NSF/ANSI Std.14; NSF/ANSI Std.61 PIPE and FITTING; Polypropylene RA 130E-8427 Borealis Statement on compliance to food contact regulations ; Polypropylene RA 130E-8427 Borealis Statement on compliance to regulations for drinking water pipes ; Polypropylene RA 130E-8427 Borealis Data Sheet ; Polypropylene RA 130E-8427 Borealis Regression analysis according to ISO/TR 9080 ; Petroquímica Cuyo SAIC Polypropylene SP311 Toxicological and Environmental product information ; Petroquímica Cuyo SAIC Polypropylene SP311 Data Sheet ; Petroquímica Cuyo SAIC Polypropylene SP311 Regression analysis according to ISO/TR 9080 ; Petroquímica Cuyo SAIC Polypropylene SP311 Hydrostatic Pressure Testing- Test Report ; ASTM F2389 Standard Specification for Pressure-Rated Polypropylene (PP) Piping Systems. (Renumber remaining sections) 69

70 COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on committee action taken on Item 86 and the substantiation that was submitted is for a different material than the proposed text. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Eduardo Piazza Request to accept the code change proposal as submitted by this public comment. This Proposal provides for an alternate plumbing material. These Polypropylene-Aluminum- Polypropylene (PP-AL-PP) piping systems are manufactured, tested and listed in accordance with IAPMO IGC , and have been accepted by international standards as ISO , UNI y2 (Italy) and O Norm B5157 (Austria). Item # 101 Comment Seq # 42 UPC SUBMITTER: John Halliwill Halliwill and Associates Revise text as follows: Excessive Water Pressure Where static water pressure in the water supply piping is in excess of eighty (80) pounds per square inch (552 kpa), an approved-type pressure regulator preceded by an adequate strainer shall be installed and the static pressure reduced to eighty (80) pounds per square inch (552 kpa) or less. Such regulator(s) shall control the pressure to all water outlets in the building unless otherwise approved by the Authority Having Jurisdiction. Each such regulator and strainer shall be accessibly located aboveground or in a vault equipped with a properly sized and sloped bore-sighted drain to daylight, shall be protected from freezing, and shall have the strainer readily accessible for cleaning without removing the regulator or strainer body or disconnecting the supply piping. All pipe size determinations shall be based on eighty (80) percent of the reduced pressure when using Table Where a branch on the eighty (80) pounds per square inch (522 kpa) regulated system, serves a individual fixture, appliance or appurtenance that requires a lower pressure for its proper operation and to prevent damage or injury an additional accessible approved pressure regulator shall be installed preceding the fixture appliance or appliances. 70

71 Some manufacturers of fixtures, appurtenances and appliances recommend that their products not be used at 80 psi. They also recommend that a pressure regulator be installed to a different pressure such as 25 psi. Unfortunately, unless there are additional references in the code to remind the installer that there can be a potentially serious problems with these products working at a higher pressure and they forget the requirements in Section Installation Practices, there can be potential or real problems. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed text would allow products to be installed that are not rated higher than 80 psi and concern is raised in regards to the safety and listing of such products. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: John Halliwill, Halliwill and Associates Request to accept the code change proposal as submitted by this public comment. I am requesting that the Technical Committee reconsider their rejection of this proposal because I do not believe they understood why it was made. While serving as an inspector in the field I came across pieces of equipment that required less than 80 ponds per square inch for their proper operation. I have provided the following example of a piece of equipment that requires a maximum of 28 PSI and if it is above a pressure reducing valve is to be installed. Technical information for the Hobart SR 24 Dishware technical listed at specsheets/f-40028(1-06).pdf it has the following cautionary note WARNING: REQUIRED FLOWING PRESSURE TO THE DISHWASHER IS TO BE 25 PSI +/- 3 PSI. IF FLOW IS BELOW 22 PSI, THE SUPPLY LINE PRESSURE MUST BE INCREASED. IF FLOW PRESSURE IS ABOVE 28 PSI, A PRESSURE REDUCING VALVE (NOT SUPPLIED) MUST BE INSTALLED IN THE LINE. Additionally the Scottsman Ice Machine Company website at /products/md t2man.pdf for their model MDT2 machine indicates on page 4 the water pressure is to be Water pressure Min. 20 psi Max. 70 psi when using this machine. The reason from the TC indicated, The proposed text would allow products to be installed that are not rated higher than 80 psi and concern is raised in regards to the safety and listing of such products. The intent is to protect those products that are installed and used on a daily basis. This additional language also will reinforce the requirements of the existing UPC Section that is often overlooked by contractors and others involved with the installation of plumbing systems. It should further be noted that many pieces of equipment such as some dishwashers have a pressurereducing valve pre-installed at the water supply connection. This is needed on these installations for the proper distribution of water in the dishwasher as well as controlling the flow rate for those machines that have a heated tank as a part of their operation. 71

72 Item # 102 Comment Seq # 43 UPC SUBMITTER: James Paschal Bodycote Revise text as follows: Relief valves located inside a building shall be provided with a drain, not smaller than the relief valve outlet, of galvanized steel, hard-drawn copper piping and fittings, CPVC, PP, or listed relief valve drain tube with fittings that will not reduce the internal bore of the pipe or tubing (straight lengths as opposed to coils) and shall extend from the valve to the outside of the building, with the end of the pipe not more than two (2) feet (610 mm) nor less than six (6) inches (152 mm) above the ground or the flood level of the area receiving the discharge and pointing downward. Such drains may terminate at other approved locations. Relief valve drains shall not terminate in a building s crawl space. No part of such drain pipe shall be trapped or subject to freezing. The terminal end of the drain pipe shall not be threaded. This proposal provides for an alternate plumbing material. These Polypropylene (PP) piping systems are manufactured, tested and listed in accordance with ASTM F 2389, and have been accepted in other model codes in the U.S. and Canada (IPC, NSPC, NPC). COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Robert Calone, Request to reject the code change proposal by this public comment. 1) Proposal lack sufficient substantiation. 2) Mere reference to standard ASTM F 2389 and to listings in other model codes is no sufficient substantiation to list this product in the body of the code. 3) Lack of data exists regarding use of this product for long-term hot and cold potable water systems. 4) Relevant leaching, permeability, life expectancy and durability studies and data were not provided; therefore no scientific data has been submitted to substantiate proposal. 5) No data was provided showing conformance with NSF 61. 6) Resistance to degradation from exposure to hot water, chlorine or commonly encountered household substances must be disclosed. 72

73 Item # 105 Comment Seq # 44 UPC SUBMITTER: Gary Klein California Energy Commission Add new text as follows: All buried potable water piping shall be installed in a waterproof channel or conduit that allows for installation, removal and replacement. The internal cross-section area or diameter of the channel or conduit shall be large enough to allow for insulation of the potable hot water piping. Elbows shall be gradual, wide radius bends. Buried potable water piping can be subjected to damage during construction, and it is disruptive and relatively expensive to repair in the event of a pipe failure. Repairing a break can take a long time, during which period, the water supply is shut off, adversely impacting the health and safety of the occupants. When piping is accessible, it is relatively straightforward and inexpensive to repair or replace. It is well known that identifying and repairing leaks in under slab piping is expensive. It will get even more expensive if the trend toward post-tension construction for concrete slabs continues. Installing potable water piping in a conduit is reasonable given that historically, houses generally last longer than their plumbing systems. Electrical wiring that is buried within or under a slab floor is installed in a waterproof channel or conduit from which it can be removed, repaired and replaced if it becomes necessary to do so. The rationale is that the same should be done for potable water piping. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed addition of text is too broad, restrictive and cost prohibitive. Technical justification was not presented to warrant change and the definitions of fittings is inadequate. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Gary Klein, Affiliated International Management, LLC Request to accept the code change as modified by this public comment All buried potable water piping shall be installed in a waterproof channel or conduit that allows for installation, removal and replacement. When the buried pipe is part of the hot water distribution system, then the internal cross-section or diameter of the channel or conduit shall be large enough to allow for insulation of the hot water piping. 73

74 Statement of Problem: Buried potable water piping can be subjected to damage during construction, and it is disruptive and relatively expensive to repair in the event of a pipe failure (sometimes extremely expensive). Repairing a break can take a long time, during which period, the water supply is shut off, adversely impacting the health and safety of the occupants. Substantiation for Proposal: The Committee rejected this proposal as being too broad, restrictive and cost prohibitive. Additionally, technical justification was not provided to warrant the change and the definition of fittings was inadequate. First, this revised proposal removes the issue of fittings. Second, I have attempted to be more clear about the impact on the diameter of the conduit or channel when it contains hot water distribution piping that needs to be insulated. Third, I don t know how to respond to the concept that the original proposal was both too broad and restrictive. Fourth, during both the Committee meeting and the General Assembly, the question of cost was discussed and addressed. When piping is accessible, it is relatively straightforward and inexpensive to repair or replace. It is well known that identifying and repairing leaks in under slab piping is expensive. It will get even more expensive if the trend toward post-tension construction for concrete slabs continues. I agree that there is some additional cost to installing the potable water piping in as proposed. However, the cost of repair if the piping is not accessible far exceeds the marginal cost of this recommendation. Installing potable water piping in a conduit is reasonable given that historically houses generally last longer than their plumbing systems. One of the comments made during the discussion was that if it was too difficult or expensive to repair the piping under the slab, then the plumber would reroute the piping above the slab. My question, is why would this not make sense in the first place? There is a problem with fixtures or appliance installed in an island. There is no way to reroute the plumbing above the slab. For these situations, there really should be a way to remove the pipe and any needed insulation for repair when it becomes necessary. In addition, the energy consequences of installing uninsulated hot water piping under a slab are very large. According to research being conducted by the California Energy Commission, uninsulated hot water piping loses heat at 3-5 times the rate of uninsulated pipes in air at room temperature. This is for relatively dry soils. When the soils under the slab are wet, the heat loss rate is much larger. In addition, part of the idea of this proposal is to reduce the number of feet of pipe that is installed below the slab. The energy reasons for this on the hot water distribution piping are obvious. Finally, electrical wiring that is buried within or under a slab floor is installed in a waterproof channel or conduit from which it can be removed, repaired and replaced if it becomes necessary to do so. The rationale is that the same should be done for potable water piping. Item # 107 Comment Seq # 45 UPC SUBMITTER: Dave Kokosenski RCR Companies Revise text as follows: 74

75 610.0 Size of Potable Water Piping Whenever a water filter, water softener, backflow prevention device, tankless water heater, or similar device is installed in any water supply line, the pressure loss through such devices shall be included in the pressure loss calculations of the system, and the water supply pipe and meter shall be adequately sized to provide for any such pressure loss. No water filter, water softener, backflow prevention device, or similar device regulated by this code shall be installed in any potable water supply piping when the installation of such device produces an excessive pressure drop in any such water supply piping. In the absence of specific pressure drop information, the diameter of the inlet or outlet of any such device or its connecting piping shall not be less than the diameter of such water distribution piping to the fixtures served by the device. All such devices shall be of a type approved by the Authority Having Jurisdiction and shall be tested for flow rating and pressure loss by an approved laboratory or recognized testing agency to standards consistent with the intent of this chapter. The current code does not require us to include tankless water heaters in the pressure loss calculations of a system. These tankless water heaters do in fact produce a greater pressure drop when compared to a water meter, pressure reducing valve, filter, softener, backflow device, or elevation. By adding the words tankless water heater to this section the losses through a tankless water heater would be accounted for and velocities of 5 feet per second would not be exceeded. When sizing these heaters, typically they are only flowing 2 shower heads. When sizing our piping we must account for all losses within the system. When I requested an IAPMO interpretation regarding this, the response was the losses must be included and was covered with the words other similar devices, which could be misinterpreted. By adding these words it would be clear. Sections , and Installation Standard 3, Section of the California Plumbing Code limit the velocities in copper hot water piping to 5 feet per second. The Copper Development Association s The Copper Tube Handbook also limits the velocities in copper hot water piping to 5 feet per second. The 2003 Illustrated Training Manual mentions 4 feet per second on hot. These velocities will be exceeded when installing a single tankless water heater. See the attached below. 1-BATHTUB = 4 FIXTURE UNITS 1-CLOTHES WASHER = 4 FIXTURE UNITS 1-DISHWASHER = 1.5 FIXTURE UNITS 1-SHOWER HEAD = 2 FIXTURE UNITS 11.5 FIXTURE REDUCED 25% PER CODE IS FIXTURE UNITS = 8 GPM DEMAND TOTAL HOT DEMAND IN A TYPICAL HOME IS 10 TO 16 GPM WHAT IS THE TANKLESS LOSS AT THESE DEMANDS? 20 GRAIN WATER WOULD REQURE A WATER SOFTENER 75

76 76

77 COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Kevin Pirotin, Noritz American Corporation Request to accept the code change proposal as modified by this public comment Whenever a water filter, water softener, backflow prevention device, tankless water heater, or similar device is installed in any water supply line, the pressure loss through such devices shall be included in the pressure loss calculations of the system, and the water supply pipe and meter shall be adequately sized to provide for any such pressure loss. Other devices which can contribute significant pressure loss to the water supply piping shall also be included in the pressure loss calculations. No water filter, water softener, backflow prevention device, or similar device regulated by this code shall be installed in any potable water supply piping when the installation of such device produces an excessive pressure drop in any such water supply piping. In the absence of specific pressure drop information, the diameter of the inlet or outlet of any such device or its connecting piping shall not be less than the diameter of such water distribution piping to the fixtures served by the device. All such devices shall be of a type approved by the Authority Having Jurisdiction and shall be tested for flow rating and pressure loss by an approved laboratory or recognized testing agency to standards consistent with the intent of this chapter. The UPC does not currently provide sizing guidelines for tankless water heaters nor do standards exist which establish testing requirements for flow and pressure loss through water heaters in general. Such criteria is needed before the code can specifically mention tankless water heaters as a device which contributes significant pressure loss to the water supply line. An appropriately sized tankless water heater provides far less pressure loss than the figures submitted in the original recommendation by Mr. Kokosenski. The intent of the original recommendation is to identify devices, which can be a major contributor to pressure loss; this should include all devices, not just tankless water heaters. Therefore, Section should be modified to clarify the need to identify other significant sources of pressure loss with a statement similar to the above proposed modification. PUBLIC COMMENT 2: Submitter: Gary Klein, Affiliated International Management, LLC Request to accept the code change proposal as modified by this public comment Whenever a water filter, water softener, backflow prevention device, tankless water heater, or similar device is installed in any water supply line, the pressure loss through such devices shall be included in the pressure loss calculations of the system, and the water supply pipe and meter shall be adequately sized to provide for any such pressure loss. No water filter, water softener, backflow prevention device, or similar device regulated by this code shall be installed in any potable water supply piping when the installation of such device produces 77

78 an excessive pressure drop in any such water supply piping. In the absence of specific pressure drop information, the diameter of the inlet or outlet of any such device or its connecting piping shall not be less than the diameter of such water distribution piping to the fixtures served by the device. All such devices shall be of a type approved by the Authority Having Jurisdiction and shall be tested for flow rating and pressure loss by an approved laboratory or recognized testing agency to standards consistent with the intent of this chapter. My proposal deletes the word tankless from the original proposal so that the pressure drop due to any water heater must be considered when sizing the piping. There are a rather large variety of water heater types: storage water heaters, tankless water heaters (officially any water heater with a storage volume of less than 2 gallons), indirect heaters (boilers with external storage tanks), solar water heaters, heat pump water heaters, and some new water heaters with very small storage tanks and large burners (an example is a 4 gallon tank with a 180,000 Btu burner) and versions of many of these in gas, propane, oil and electric. The code needs to be inclusive of all of these types when calculating pressure drop and pipe sizing. PUBLIC COMMENT 3: Submitter: David Delaquila, Air Conditioning, Heating and Refrigeration Institute Request to reject the code change proposal by this public comment. The proposed change is unwarranted because: 1) the pressure drop through a tankless water heater is already accounted for in the current requirement; 2) no information indicates that pressure drops through water heaters are not being considered when this requirement is being applied in the field; 3) trying to list, or identify every potential component or piece of equipment in the system would be impractical, and 4) the rationale provided as justification for adopting this proposal is technically inaccurate. Item # 109 Comment Seq # 46 UPC ,610.5, Table 6-5, Appendix A, Table A-2 SUBMITTER: Gary Klein California Energy Commission Revise text as follows: The quantity of hot and cold water required to be supplied to every plumbing fixture shall be represented by fixture units, as shown in Table 6-5. Equivalent fixture values shown in Table 6-5 include both hot and cold water demand Except as provided in Section 610.4, the size of each the hot and cold water piping system shall be determined in accordance with the procedure set forth in Appendix A. For alternate methods of sizing water supply systems, see Appendix L. 78

79 TABLE 6-5 Water Supply Fixture Units (WSFU) and Minimum Fixture Branch Pipe Sizes 3 TABLE A-2 Water Supply Fixture Units (WSFU) and Minimum Fixture Branch Pipe Sizes Appliances, Appurtenances of Fixtures 2 1 Minimum Fixture Private Public Assembly 64 Branch Pipe Size 1,2,4 Cold Hot Cold Hot Cold Hot Cold Hot Bathtub or Combination Bath/Shower 1/2 1/ /4 Bathtub Fill Valve 3/4 3/ Bidet 3/8 3/ Clothes Washer 1/2 1/ Dental Unit, Cuspidor 1/2 1.0 Dishwasher, domestic, cold-water 3/ supply only 7. Dishwasher, domestic, hot-water 3/ supply only 8 Drinking fountain or Watercooler 1/ Hose Bibb 6 1/ Hose Bibb, each additional 86 1/ Lavatory 3/8 3/ Lawn Sprinkler, each head 53 1/ Mobile Home, each (minimum) 1/ Sinks Bar 3/8 3/ Clinic Faucet 1/2 1/ Clinic Flushometer Valve with or without faucet Kitchen, domestic 8 3/8 3/ Laundry 1/2 1/ Service or Mop Basin 1/2 1/ Washup, each set of faucets 1/2 1/ Shower, per head 3/8 3/ Urinal, 1.0 GPF Flushometer Valve 3/4 See Footnote 75 Urinal, greater than 1.0 GPF 3/4 See Footnote 75 Flushometer Valve Urinal, Flush Tank 1/ Washfountain, circular spray 3/4 4.0 Water Closet, 1.6 GPF Gravity Tank 1/ Water Closet, 1.6 GPF Flushometer 1/ Tank Water Closet, 1.6 GPF Flushometer 1 See Footnote 75 Valve Water Closet, greater than 1.6 GPF 1/ Gravity Tank Water Closet, greater than 1.6 GPF 1 See Footnote 75 Flushometer Valve 79

80 Notes: 1. Size of the cold branch pipe, or both the hot and cold branch pipes. 21. Appliances, Appurtenances of Fixtures not included in this Table may be sized by reference to fixtures having a similar flow rate and frequency of use. 3. The listed fixture unit values represent their load on their cold water service. The separate cold water and hot water fixture unit value for fixtures having both hot and cold water connections may each be taken as three-quarters (3/4) of the total value of the fixture. 42. The listed minimum supply branch pipe sizes for individual fixtures are the nominal (I.D.) pipe size. The sizes indicated in this table shall be used unless approved engineering calculations indicate that a smaller diameter is acceptable or that a larger diameter is required. 53. For fixture or supply connections likely to impose continuous flow demands, determine the required flow in gallons per minute (GPM) and add it separately to the demand (in GPM) for the distribution system or portions thereof. 64. Assembly {Public Use (See Table 4-1)]. 75. When sizing Flushometer systems see Section Reduced fixture unit loading for additional hose bibs as used is to be used only when sizing total building demand and for pipe sizing when more than one hose bibb is supplied by a segment of the water distribution pipe. The fixture branch to each hose bibb shall be sized on the basis of 2.5 fixture units. 7. Some dishwashers only use cold water. 8. The nominal pipe diameter shown is for the portion of the potable water distribution system line serving an individual domestic kitchen sink or domestic dishwasher and is to be used when the sink and dishwasher are not connected to a common branch line. When they are connected on a common branch line as is commonly found in many domestic kitchens, ½ inch nominal diameter piping may be used for both the branch line and for the individual lines serving the sink and the dishwasher. The purpose of this proposed change is to more easily enable the separate calculation of Water Supply Fixture Units (WFSU) and Minimum Fixture Branch Sizes for hot and cold water distribution systems for all occupancies. The ¾ value previously permitted in the footnote as the basis for all fixtures served by both hot and cold water has now been formally incorporated into the table. Tables 6-5 and A-2 were virtually identical. We propose that these tables become identical and both be changed as described above. The California Energy Commission, its supporting research organizations and other collaborators have been investigating the impact of the hot water distribution system s design on the overall energy and water performance of a building s hot water system. While our research and investigations are likely to lead to modifications in the Building Energy Efficiency Standards portion of California s Building Standards Code (Title 24), a number of potential ways to enhance the performance of these systems is influenced or governed by the requirements of plumbing codes including the Uniform Plumbing Code (UPC). Based on our research, the key factor in determining the performance of hot water distribution systems is to design and build them to have the smallest volume of water within that portion of the system between the plumbing fixture and the source of hot water. The length and the internal diameter of the pipe(s) determine the volume of water contained within the distribution system. Systems with the least internal volume waste the least amount of energy and water. They also typically provide hot water to the plumbing fixture with the shortest waiting period typically the most important consideration to the hot water user. 80

81 Unfortunately, the current plumbing codes do not differentiate between hot and cold potable water piping in the design and installation of a distribution system. Without this differentiation, current hot water distribution systems typically become over-sized while following the guidance provided by plumbing codes. Excessive pipe size has little or no negative water or energy conservation impact on cold water systems but it is a big factor in reducing the performance of hot water distribution systems. A review of the UPC identified several areas (listed in our various proposals) that could be changed in order to reduce water and energy wasted in hot water distribution as well as the waiting period for hot water to arrive at the fixture. We believe that the changes we have proposed improve energy and water performance while appropriately addressing the hydrodynamic factors of velocity (erosion, noise and water hammer) and friction losses (pressure drop and restrictions due to length and fittings). In addition, since our recommendations decrease the time it takes to get hot water from the source to the fixtures, hot water will be available more quickly when a faucet is opened. This is particularly important in food service and public restrooms, where these changes will support the health code s intent to have hot water readily available at all times during all operating hours. It is necessary to separately define hot and cold water distribution systems in order to improve the performance of the hot water distribution system. Improvements come in the flow and pressure characteristics of the plumbing, and by the corresponding reductions in water and energy waste. Hot water use represents percent of the total residential energy consumption. The low end of the range is found in colder climate zones and the higher end of the range is found in temperate climates. In many parts of the country, and as overall building energy performance is improved, hot water is the 1st or 2nd largest residential energy use. It also represents a large fraction of the energy consumption in commercial food service, which uses almost half of the water heating used in all commercial buildings. Hot water distribution systems characteristics dictated by the UPC directly impact the amount of energy consumed. Therefore it is necessary to distinguish between hot and cold distribution systems so that appropriate hot water systems characteristics can be defined in the UPC. The proposal revises the notes on the table to reflect the changes made to the table. In note 1 of the table it is our interpretation that the word branch as it is used in this table means that portion of the hot or cold water distribution system that serves only one fixture. (We have found it helpful to call this a twig to differentiate it from a branch which may serve more than one fixture and a trunk which serves many fixtures.) Since oversized hot water piping increases energy and water waste, it makes sense to stipulate that the size shown is to be used unless engineering calculations indicate that a smaller diameter is acceptable or that a larger diameter is required. The January/February 2007 issue of the Official Magazine contains an article that explains that excessive velocities will not occur in the revised pipe sizes (lavatory, single shower head, bidet) shown in the revised tables. Note 4 in current Table 6-5 and Table A-2 has been modified to reflect that no longer will the dimensions shown be considered as minimum. Note 3 in Table 6-5 (and Table A-2) currently allows for multiplying both the hot and cold WSFU by ¾ when a fixture is supplied with both hot and cold water. Since our proposal separately defines hot and cold water distribution systems, it is appropriate to apply this factor in the table. This factor, in our opinion, more accurately reflects reality and should be the basis of hot water distribution system sizing. Use of the factors in the revised Table 6-5 (and Table A-2) can be applied to all occupancies. Having the appropriate sizes in the table will make it easier to design, install and inspect. The changes to the other notes in the tables are primarily to renumber them. Note 7 identifies the fact that there are dishwashers that use only a cold water supply. COMMITTEE ACTION: Reject 81

82 COMMITTEE STATEMENT: The proposed tables lacks technical justification, inaccurate and does not address velocity issues. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Gary Klein, Affiliated International Management, LLC Request to accept the code change proposal as modified by this public comment. TABLE 6-5 Water Supply Fixture Units (WSFU) and Minimum Fixture Branch Pipe Sizes 3 (Tables remain unchanged) Notes: 4. The listed minimum supply branch pipe sizes for individual fixtures are the nominal (I.D.) pipe size. When the flow rate of an appliance, appurtenance, or fixture is less than or equal to 2 gallons per minute (gpm), the minimum supply branch size maybe reduced to 3/8 nominal (I.D.) pipe size. (Remainder of notes remain unchanged) TABLE A-2 Water Supply Fixture Units (WSFU) and Minimum Fixture Branch Pipe Sizes 3 (Tables remain unchanged) Notes: 4. The listed minimum supply branch pipe sizes for individual fixtures are the nominal (I.D.) pipe size. When the flow rate of an appliance, appurtenance, or fixture is less than or equal to 2 gallons per minute (gpm), the minimum supply branch size maybe reduced to 3/8 nominal (I.D.) pipe size. (Remainder of notes remain unchanged) Statement of Problem: The purpose of this proposed change is to more easily enable the separate calculation of Water Supply Fixture Units (WFSU) and Minimum Fixture Branch Sizes for hot and cold water distribution systems for all occupancies. The ¾ value previously permitted in the footnote as the basis for all fixtures served by both hot and cold water has now been formally incorporated into the table. Tables 6-5 and A-2 were virtually identical. We propose that these tables become identical and both be changed as described above. The California Energy Commission, its supporting research organizations and other collaborators have been investigating the impact of the hot water distribution system s design on the overall energy and water performance of a building s hot water system. While our research and investigations are likely to lead to modifications in the Building Energy Efficiency Standards portion of California s Building Standards Code (Title 24), a number of potential ways to enhance the performance of these systems is influenced or governed by the requirements of plumbing codes including the Uniform Plumbing Code (UPC). Based on our research, the key factor in determining the performance of hot water distribution systems is to design and build them to have the smallest volume of water within that portion of the system between the plumbing fixture and the source of hot water. The length and the internal diameter of the pipe(s) determine the volume of water contained within the distribution system. Systems with the least internal 82

83 volume waste the least amount of energy and water. They also typically provide hot water to the plumbing fixture with the shortest waiting period typically the most important consideration to the hot water user. Unfortunately, the current plumbing codes do not differentiate between hot and cold potable water piping in the design and installation of a distribution system. Without this differentiation, current hot water distribution systems typically become over-sized while following the guidance provided by plumbing codes. Excessive pipe size has little or no negative water or energy conservation impact on cold water systems but it is a big factor in reducing the performance of hot water distribution systems. A review of the UPC identified several areas (listed in our various proposals) that could be changed in order to reduce water and energy wasted in hot water distribution as well as the waiting period for hot water to arrive at the fixture. We believe that the changes we have proposed improve energy and water performance while appropriately addressing the hydrodynamic factors of velocity (erosion, noise and water hammer) and friction losses (pressure drop and restrictions due to length and fittings). In addition, since our recommendations decrease the time it takes to get hot water from the source to the fixtures, hot water will be available more quickly when a faucet is opened. This is particularly important in food service and public restrooms, where these changes will support the health code s intent to have hot water readily available at all times during all operating hours. Substantiation for Proposal: The Committee rejected this proposal stating it lacked technical justification, was inaccurate and did not address velocity issues. I have revised the proposal to address these concerns and based on the comments received from the Committee and the General Assembly. The major revision is that I have no longer proposed any changes to the table itself. The sole change is to the Footnote 4 and its purpose is to enable the use of 3/8 in nominal (I.D.) piping when the flow rate of an appliance, appurtenance or fixture is less than 2 gallons per minute (GPM). It is my understanding words supply branch pipe sizes for individual fixtures means that portion of the hot or cold water distribution system that serves only one fixture. (We have found it helpful to call this a twig to differentiate it from a branch which may serve more than one fixture and a trunk which serves many fixtures.) The reason for this proposal is that since oversized hot water piping increases energy and water waste, it makes sense to use the smallest diameter piping that meets all other hydraulic and safety considerations. The January/February 2007 issue of the Official Magazine contains an article that explains that excessive velocities will not occur in copper, CPVC or PEX when the flow rate is less than or equal to 2 GPM. For a copy of this article contact Gary Klein, 8471 Blue Maiden Court, Elk Grove, CA, l l Gklein@energy.state.ca.us The lower allowable flow rate for hot water in copper piping provides the reason why I have proposed that the flow rate be cut off at 2 gallons per minute. The allowable maximum velocity of 5 feet per second, is only exceeded, and just barely in Type K copper at this flow rate. See Table 2 for copper, Table 3 for CPVC and Table 4 for PEX. Another consideration is pressure drop in this piping over its length. Table 1 shows the friction loss for PEX, which was selected for the article because for a given nominal pipe diameter, PEX has the smallest actual inside diameter of the three types of pipe, and therefore the greatest friction loss per foot at a specified flow rate. Looking at the 3/8 inch column shows that at 2 gallons per minute the velocity is 6.67 feet per second and the friction loss over 100 feet is 25.4 psi. One would not want this much pressure drop for supply branch piping serving an individual fixture. Therefore, good practice would limit the length of the smaller diameter piping. Cutting the length to 25 feet would reduce the pressure drop by a factor of 4 to 6.35 psi. Cutting it to 20 feet would reduce it by a factor of 5 to 5.1 psi. The article also addresses water hammer, erosion and noise, which should not be a problem with the flow rate limitation presented in this proposal. 83

84 Item # 110 Comment Seq # 47 UPC SUBMITTER: Michael Cudahy Plastic Pipe and Fitting Association (PPFA) Revise text as follows: Sizing for Velocity. Water piping systems shall not exceed the maximum velocities listed in this section or Appendix A Copper Tube Systems. Maximum velocities in copper and copper alloy tube and fitting systems shall be limited to a maximum of eight (8) feet per second (fps) (2.4 mps) in cold water and five (5) fps in hot water (1.52 mps) Tubing Systems Using Copper Alloy Fittings. Maximum velocities through copper alloy fittings in tubing other than copper shall be limited to a maximum of eight (8) feet per second (fps) (2.4 mps) in cold water and five (5) feet per second (fps) in hot water (1.52 mps). Exception: Plastic piping systems utilizing brass fittings. CPVC, PEX and other plastic piping systems can use brass, a copper alloy, for fittings such as couplings, valves and/or transition fittings. This section was not intended to apply to these systems and this exception clarifies the code language. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Arnie Rodio, Pace Setter Plumbing Corp. Request to reject the code change proposal by this public comment. CPVC, PEX and other plastic piping systems can use brass, or copper alloy for fittings such as couplings, valves and/or transition fittings. This section was not intended to apply to these systems and this exception clarifies the code language. Plastic piping systems utilizing brass insert fittings greatly restrict the flow of water and increase velocity through the fitting. The issue of velocity through the fitting was not addressed. The velocities are calculated on the pipe size not the fitting size, which is different. Item # 111 Comment Seq # 48 UPC , Table 7-1 SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #111). 84

85 Revise text as follows: Item Materials for drainage piping shall be in accordance with one of the referenced standards in Table 7-1. Drainage piping shall be cast iron, galvanized steel, galvanized wrought iron, lead, copper, brass, Stainless Steel 304 or 316L, Schedule 40 ABS DWV, Schedule 40 PVC DWV, extra-strength vitrified clay pipe, or other approved materials having a smooth and uniform bore, except that: Add new Table as follows: Item 2 Table 7-1 Material Underground Drain, Waste and Vent Pipe and Fittings 1. For Building Sewer applications Above ground Drain, Waste and Vent Pipe and Fittings Building Sewer Pipe and Fittings Referenced Standard(s) Pipe ABS (Schedule 40) X X X ASTM D1527, ASTM D2661, ASTM D ASTM F628, ASTM F891 Asbestos-Cement X ASTM C428 1, ASTM C14 1 Brass X ASTM B43 Cast-Iron X X X ASTM A74, ASTM A888, CISPI 301 Copper (Type DWV) X X X ASTM B75, ASTM B251, ASTM B302, Galvanized Steel X ASTM A 53 Galvanized Malleable Iron PVC (Schedule 40, Type DWV) Referenced Standard(s) Fittings ASTM D2661, ASTM D ASME B16.12, ASTM A74, ASTM A888, CISPI 301 ASME B16.23, ASME B16.29 X ASME B 16.3 X X X ASTM D1785, ASTM D2665, ASTM F794 1, ASTM F891 ASTM D2665, ASTM F794 1 ASTM F1866 Stainless Steel 304 X ASME A ASME A Stainless Steel 316L X X X ASME A ASME A Vitrified Clay (Extra strength) X ASTM C700 ASTM C700 (Renumber existing Table 7-1 to Table 7-2(a) and place under Section , and renumber existing Table 7-2 to Table 7-2(b) and place under Section ) 85

86 All standards referenced in Table 7-1 are currently in Table 14-1 and are approved materials. This also correlates with Table 6-4 by listing the type of material approved for the installation and provides a user friendly referenced table. COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Item Materials for drainage piping shall be in accordance with one of the referenced standards in Table 7-1 except that: (Remainder of text unchanged) Materials for drainage fittings shall be in accordance with one of the referenced standards in Table 7-1 of the same diameter as the piping served, and such fittings shall be compatible with the type of pipe used. Drainage fittings shall be cast iron, malleable iron, lead, brass, copper, ABS, PVC, vitrified clay, stainless steel 304 or 316L 304 shall not be installed underground and shall be kept at least 6 inches (152 mm) aboveground), or other approved materials having a smooth interior waterway of the same diameter as the piping served, and all such fittings shall be compatible with the type of pipe used. Item 2 Material Underground Drain, Waste and Vent Pipe and Fittings Table 7-12(a) Above ground Drain, Waste and Vent Pipe and Fittings Building Sewer Pipe and Fittings Referenced Standard(s) Pipe ABS (Schedule 40) X X X ASTM D1527, ASTM D2661, ASTM D ASTM F628, ASTM F891 Asbestos-Cement X ASTM C428 1, ASTM C14 1 Brass X ASTM B43 Cast-Iron X X X ASTM A74, ASTM A888, CISPI 301 Copper (Type DWV) X X X ASTM B75, ASTM B251, ASTM B302, ASTM B306 Galvanized Steel X ASTM A 53 Galvanized Malleable Iron Referenced Standard(s) Fittiings ASTM D2661, ASTM D ASME B16.12, ASTM A74, ASTM A888, CISPI 301 ASME B16.23, ASME B16.29 X ASME B 16.3 PVC (Schedule 40, X X X ASTM D1785, ASTM D2665, Type DWV) ASTM D2665, ASTM F794 1 ASTM F794 1, ASTM F1866 ASTM F891 Stainless Steel 304 X ASME A ASME A Stainless Steel 316L X X ASME A ASME A Vitrified Clay (Extra X ASTM C700 ASTM C700 strength) 1. For Building Sewer applications 86

87 (Renumber existing Table 7-1 to Table 7-2(a) and place under Section , and renumber existing Table 7-2 to Table 7-2(b) and place under Section ) COMMITTEE STATEMENT: The modification provides a list of correct standards within their proper location. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Bruce Brenier, Rocky Mountain Colby Pipe Company Requests to accept the code change proposal as modified by this public comment. Item 1 (remains unchanged) Item 2 Material Underground Drain, Waste and Vent Pipe and Fittings 1. For Building Sewer applications Table 7-2(a) Above ground Drain, Waste and Vent Pipe and Fittings Building Sewer Pipe and Fittings Referenced Standard(s) Pipe ABS (Schedule 40) X X X ASTM D1527, ASTM D2661, ASTMD2680 1, ASTM F628 Co-Extruded ABS (Schedule 40) Pipe Asbestos-Cement X ASTM C428 1, ASTM C14 1 Brass X ASTM B43 Referenced Standard(s) Fittings ASTM D2661, ASTM D X X X ASTM F1488 ASTM D2661, ASTM D Cast-Iron X X X ASTM A74, ASTM A888, CISPI 301 Copper (type DMV) X X X ASTM B75, ASTM B251, ASTM B302, ASTM B306 Galvanized Steel X ASTM A 53 Galvanized Malleable Iron PVC Schedule 40, Type DWV ASME B16.12, ASTM A74, ASTM A888, CISPI 301 ASME B16.23, ASME B16.29 X ASME B 16.3 X X X ASTM D1785, ASTM D2665, ASTM F794 1, ASTM F891 ASTM D2665, ASTM F794 1 ASTM F1866 Co-Extruded PVC (Schedule 40) Pipe X X X ASTM F1488 ASTM D2665, ASTM F7941, ASTM F1866 Stainless Steel 304 X ASME A ASME A Stainless Steel 316L X X X ASME A ASME A Vitrified Clay (Extra Strength) X ASTM C700 ASTM C700 87

88 All standards referenced in Table 7-1 are currently in Table 14-1 and are approved materials. This also correlates by listing the type of material approved for the installation and provides a user friendly referenced table. The inclusion of ASTM F 1488 provides clarification to ensure only Schedule 40 series pipe is used and not DR, PS, or DR/PS series pipe that is also listed in the same standard. *Note: A copy of the standard was provided. Item # 112 Comment Seq # 49 UPC (New) SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Add new text as follows: All cast-iron soil pipe and fittings shall be listed and tested to comply with standards referenced in Table Such pipe and fittings shall be marked with country of origin and identification of the original manufacturer in addition to any markings required by referenced standards. It is important for the end user to identify the country of origin and original manufacturer to verify certifications and listings as well as when problems or failure occur in the field. This is a health and safety issue and needs to be addressed in the code. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment All cast-iron soil pipe and fittings shall be listed and tested to comply with standards referenced in Table Such pipe and fittings shall be marked with country of origin and identification of the original manufacturer in addition to any markings required by referenced standards. The proposed requirement for listing of country of origin is not a technical requirement and should not be part of a safety code. Further such marking is important; it should be required for all products, not just for cast-iron soil pipe. 88

89 Item # 116 Comment Seq # 50 UPC 2009 Table 7-3 SUBMITTER: Shabbir Rawalpindiwala Kohler Company Revise text as follows: TABLE 7-3 Drainage Fixture Unit Values Min. Size Trap and Plumbing Appliance, Trap Arm 7 Private Public Assembly 8 Appurtenance, or Fixture Shower, single-head trap / (Portions of Table not shown do not change) It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 gpm. Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 gpm. With this in mind, it is reasonable to revise the trap size to 1-1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1-1/2 nominal OD outlet for showers. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed minimum size trap for a shower does not adequately address the issue of stoppage. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT(s): Submitter: Greg Milleman, Valencia Water Company Douglas Bennett, Southern Nevada Water Authority Mary Ann Dickinson, Alliance for Water Efficiency Al Dietemann, Saving Water Partnership, 17 Seattle Area Water Utilities, Administered by Seattle Public Utilities Lynn Florey, Sonoma County Water Agency Jeanne Deaver, Santa Fe Irrigation District Rodd Greene, Yucaipa Valley Water District Paul Piazza, Town of Windsor Joone Lopez, Central Basin Municipal Water District Shawn Martin, Plumbing Manufacturers Institute Jose Martinez, Walnut Valley Water District 89

90 Kristina Ortez, Natural Resources Defense Council (NRDC) Thomas Pape, Best Management Partners Shabbir Rawalpindiwala, Kohler Co. Stacy L. Rodriguez, Eastern Municipal Water District John Schommer, Watermiser Request to accept the code change proposal as submitted by this public comment. SUBSTANTIATION (Greg Milleman): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 gpm. Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 gpm. With this in mind, it is reasonable to revise the trap size to 1-1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1-1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. the maximum discharge from a showerhead is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at Valencia Water Company understand IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past five years, Valencia Water Company has spent more than $400, dollars to improve water efficiency, with $200, being spent in 2007 alone. Valencia Water Company substantially stepped up its water efficiency measures in 2006/2007 and we plan to continue this into the future. Our conservation budget for 2008 is approximately $250,000.00, but will grow as opportunities for water efficiency present themselves. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for shower heads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Douglas Bennett): Consistent with the SNWA s support of the amendments on Item 38, it is appropriate to support the proposed reduction of the minimum shower trap diameter based upon the following: The proposed 1-1/2 trap size has more than twice the capacity needed to accommodate the maximum legal flow of any showerhead. ASME A titled, Plumbing Waste Fittings specifies a minimum 1-1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A

91 The new standard should reduce the net consumption of raw materials and energy in the production of the required drain parts. The 1-1/2 drain size will increase velocity of discharge, potentially increasing line carry and decreasing potential for blockage. In closing, this amendment appears to compliment water efficiency standard for showerheads. The SNWA is not aware of any negative consequences in terms of public health and safety and the smaller trap size may actually reduce the occurrence of blockage. This proposal appears to have significant economic and environmental benefits. SUBSTANTIATION (Mary Ann Dickinson): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. The Alliance for Water Efficiency understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 20 years, the Saving Water Partnership has spent more than forty million dollars to improve water efficiency. We have replaced more than 400,000 showerheads to more efficient models. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. By limiting the size of the drain line for showers, it should deter interest by builders and homeowners in defeating the water saving provisions of federal law. The Alliance for Water Efficiency understands and concurs with IAPMO s role in protecting the health and safety of the public. Ours is a similar mission. We are particularly concerned that the codes promote efficient and sustainable water use, vital to ensuring that the water supplies are able to meet the growing demand. Thus, the efficient use of water must be an important emphasis for the code in the protection of the health and safety of the public. The Alliance for Water Efficiency is a stakeholder-based 501(c)3 non-profit organization dedicated to the efficient and sustainable use of water. Located in Chicago, the Alliance serves as a North American advocate for water efficient products and programs, and provides information and assistance on water conservation efforts. Our membership includes water utility wholesalers and retailers, manufacturers of water plumbing fixtures and appliances, governmental agencies, research organizations, energy and environmental organizations, and other water use and conservation experts. 91

92 We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Al Dietemann): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. Seattle Public Utilities understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 20 years, the Saving Water Partnership has spent more than forty million dollars to improve water efficiency. We have replaced more than 400,000 showerheads to more efficient models. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. By limiting the size of the drain line for showers, it should deter interest by builders and homeowners in defeating the water saving provisions of federal law. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for shower heads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Lynn Florey): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A

93 This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at the Sonoma County Water Agency understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 10 years, the Sonoma County Water Agency as its water contractors have spent more than $82,000,000 dollars to improve water efficiency, expand the use of local water resources and develop recycled water to offset potable demand. The Sonoma County Water Agency also spends more than $53,000 each year to detect and repair leaks in our water distribution system. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for shower heads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Jeanne Deaver): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at the Santa Fe Irrigation District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of 93

94 water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. We participate in and fund conservation programs offered by the San Diego County Water Authority and the Metropolitan Water District, including a large scale distribution of water efficient showerheads. Our efforts are potentially undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Rodd Greene): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at the Yucaipa Valley Water District understand IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. We participate in and fund conservation programs offered by The Yucaipa Valley Water District strongly supports efforts to improve water efficiency. Our efforts are potentially undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Paul Piazza): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing 94

95 showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. The Alliance for Water Efficiency understands IAPMO s role in protecting the health and safety of the public. Ours is a similar mission. We are particularly concerned that the codes promote efficient and sustainable water use is vital to assure water supplies meet the growing demand. Thus, the efficient use of water must be an important emphasis for the code in the protection of the health and safety of the public. We at the Town of Windsor understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. A reliable source of water is paramount to all or our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past five years, the Town of Windsor has spent more than $300k to improve water efficiency. We have replaced more than 1,200 showerheads to more efficient models. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. We would support a legal requirement for one showerhead per 2,500 square inches. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Joone Lopez): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. 95

96 The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at the Central Basin understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 14 years, Central Basin has spent more than $5 million dollars to improve water efficiency. We have replaced more than 300,000 showerheads to more efficient models. We also spend more than $2.7 million each year on education and outreach to inform the community of the various issues we face with water reliability. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Shawn Martin): The existing 2 minimum trap size was appropriate when flow rates for showers were substantially larger. Currently, however, federal law and consensus standards limit the flow rate to 2.5 GPM (and lower flowrates are being advocated). At this flowrate, 1-1/2 traps provide more than sufficient drainage, even when partially blocked. It should be noted, that domestic kitchen sinks permit 1-1/2 traps even when dishwashers are installed. For these applications, kitchen faucets are regulated at 2.2 GPM, onto which the flow from the dishwasher is added. Given the fact that 1-1/2 traps have proven effective for these kitchen sink applications, it follows that it will be effective for current showers. As also stated by Mr. Viola in his Negative Vote, The change is also needed to create consistency with the national consensus standard ASME A titled, Plumbing Waste Fittings, which specifies a minimum 1 1/2 shower drain. SUBSTANTIATION (Jose Martinez): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were 96

97 a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at the Walnut Valley Water District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 10 years, Walnut Valley Water District spent more than $750,000 to improve water efficiency. We have replaced more than 1000 showerheads over the past few years to more efficient models. We also spend an estimated $250,000 each year to detect and repair leaks in our water distribution system. Our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (Kristina Ortez): The Natural Resources Defense Council (NRDC) represents over 1.2 million members and e- activists. We have been involved in water use efficiency for decades, and have advocated for legislation and regulating related to water conservation. NRDC supports efforts that contribute to sustainable water use and water management strategies, including improve industry standards that provide for water supply reliability for communities, agricultural and environmental purposes. NRDC supports an amendment to revise the trap size to 1-1/2 Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower that 2.5 GPM. NRDC believes it is reasonable to revise the trap size to 1-1/2 because this size is adequate for flow rate and drainage capacity. This is supported by national consensus standard ASME A titled, Plumbing Waste Fittings, which specifies a minimum 1-1/2 nominal OD outlet for showers. This amendment is needed to create consistency with ASME A NRDC believes that consistency is critical to ensuring best practices. We support this change, and believe it is the role of the UPC to make changes to reflect newer standards, requirements and consistency within the code. SUBSTANTIATION (Thomas Pape ): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A SUBSTANTIATION (Shabbir Rawalpindiwala): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. Smaller trap size provide better scouring due to higher flow velocity and kept the trap clean. 97

98 W.M. Paul Gerhard (Civil Engineer and a Member of American Public Health Association) in his book states much depends on a proper size of traps for waste pipe: the smaller the trap the better will it be scoured. He recommends to choose a trap a quarter or half an inch smaller than the diameter of the waste pipe to which is attached. The flushing stream is thus concentrated, and its scouring power increased within the trap, while, on the other hand, a trap an inch larger than the waste-pipe is sure to fill up in time with sediment. Adoption of this change would show a serious commitment to the Green movement which IAPMO is committed to. SUBSTANTIATION (Stacy L. Rodriguez): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at the Eastern Municipal Water District understands IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. Eastern has spent millions of dollars over the past years in order to improve water efficiency. Also, Eastern has provided and distributed low flow showerheads since We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. SUBSTANTIATION (John Schommer): It was logical to have a trap size of 2 when showerheads had no limit on the flow rate. Current federal law and national consensus standards limit showerheads to a flow rate of 2.5 Gallons Per Minute (GPM). Water agencies through their replacement program are publicizing replacement of existing showerheads with flow rates lower than 2.5 GPM. With this in mind, it is reasonable to revise the trap size to 1 1/2 because as revised this minimum trap size is adequate for flow rate and drainage capacity. Furthermore, nationally consensus standard ASME A titled, Plumbing Waste Fittings specifies a minimum 1 1/2 nominal OD outlet for showers. The change is needed to create consistency with ASME A

99 This size shower drain has worked successfully for years. Furthermore, the size is adequate for a flow of more than 5 GPM. The maximum discharge from a shower head is 2.5 GPM. Despite the printed Committee Statement, the issue of stoppage was addressed during the Committee discussion; decreasing the size of the trap increases water velocity and water depth, which scientific research has proven to decrease the occurrence of blockages. The Technical Committee statement does not accurately reflect the reasons stated by TC Members for the rejection of the proposal. Several members expressed concern for the trap not accommodating the shower being converted to multiple showerheads or the installation of showerheads exceeding the Federal legal maximum (EPAct). TC Members stated high flow and multiple showers were a growing trend (though made conflicting statements when discussing Item 38). It is not the role of the UPC to aid and abet violators of Federal law. The minimum trap size was established when water wasting showers were prevalent. We at the (Watermiser) understand IAPMO s role in protecting the health and safety of the public. We too serve the health, safety, and well-being of the public. A reliable source of water is paramount to all of our interests. Efficient and sustainable water use is vital to assure water supplies meet the growing demand. In the past 17 years, Watermiser water conservation products have spent more than 2 million dollars to improve water efficiency in both showerheads and of Watermiser Flow control devices. Each year our efforts are undermined by the lack of plumbing code provisions to deter the subversion of the Federal water efficiency regulations. We urge IAPMO to adopt provisions to deter the subversion of the Federal water efficiency standards for showerheads. If IAPMO does not act, we will be compelled to initiate ordinances and legislation at the local and state level to stop this water waste. Such actions will likely result in many variations of laws that are non-uniform from each city, county and state. This issue can be more easily resolved by amending the UPC. Item # 117 Comment Seq # 51 UPC 2009 Table 7-3 SUBMITTER: Douglas Kirk PHCC of California Revise text as follows : TABLE 7-3 Drainage Fixture Unit Values (DFU) Min. Size Plumbing Appliance, Trap and Appurtenance, or Fixture Trap Arm 7 Private Public Assembly 8 Sinks Special Purpose / Laundry...1-1/ (Portions of Table not shown do not change) 99

100 To correct inconsistencies with Table 7-3 and 7-5. For informational purposes footnote 2 requires a 2 (51 mm) minimum drain. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Julius Ballanco, JB Engineering and Code Consulting, P.C. Request to accept the code change proposal as modified by this public comment. TABLE 7-3 Drainage Fixture Unit Values (DFU) Min. Size Trap and Plumbing Appliance, Appurtenance, or Fixture Trap Arm 78 Private Public Assembly 89 Sinks Special Purpose 1-1/ Laundry 1-1/ Urinal non-water supplied 1-1/2 2, (Portions of Table not shown do not change) 7 Minimum trap size shall be based on the fixture outlet size. 78 Trap sizes shall not be increased to the point where the fixture discharge may be inadequate to maintain their self-scouring properties. 89 Assembly [Public Use (See Table 4-1)]. With the addition of non water supplied urinals, there should be a listing in the drainage fixture unit table to reflect the proper size and fixture unit value. When Dr. Roy B. Hunter developed the fixture unit measure of probability, it was based on two factors, the flow rate and the time interval between uses. For a non water supplied urinal, the flow rate is the rate of an individual urinating. The medical profession has indicated that the normal discharge of urine is one pint during urination. The minimum time interval between uses is 43 seconds. That would be when individuals are lined up to use a urinal such as at half time of a football game. This means that within a one minute period of time, slightly more than 1 pint of urine will enter the drainage system from a non water supplied urinal. That would translate to between 0.15 and 0.2 DFUs. 100

101 However, it is common practice to not use any number value less than 0.5. Therefore, I have proposed adding a value of 0.5 DFUs for non water supplied urinals. The drain size could be small in diameter, however, it is common practice to have a minimum size of 1-1/2 inch for drainage piping from waste fixtures. In keeping with this practice, I have listed a minimum pipe size of 1-1/2 inch. However, if there is a larger size opening on the fixture, the drainage pipe size would have to be a minimum of the fixture outlet size. Item # 119 Comment Seq # 52 UPC SUBMITTER: Dennis Byrnes Image Components Revise text as follows: Changes in Direction of Drainage Flow Changes in direction of drainage piping shall be made by the appropriate use of approved fittings and shall be of the angles presented by a one-sixteenth (1/16) bend, one-eighth (1/8) bend, or one-sixth (1/6) bend, selectable angle bend other approved fittings of equivalent sweep. Each change in direction, from pipe section to pipe section, shall be made in a maximum of two dimensions or planes to maintain alignment and minimize the number of changes in flow direction. This proposal is to add a selectable angle bend to the existing list of available bends and to limit the way bends can be combined to accomplish a change in direction. Combining several bends for unusual angles sometimes results in three dimensional changes which creates misalignment of the piping and multiple changes in flow direction. A selectable angle bend allows installers to fit unusual changes of pipe direction with one bend (instead of combining several standard bends) thus maintaining pipe alignment and avoiding multiple changes in flow direction at unusual changes in pipe direction. The selectable angle bend has been listed with IAPMO R&T to ASTM 2665 (PVC) and ASTM 2661 (ABS) for several years. See attached product literature. Samples available upon request. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed text eliminates to utilize various fittings and materials with this type of fitting. There is no technical justification for this text or method of installation based on the proposed fittings. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Dennis Byrnes, Image Components Request to accept the code change proposal as modified by this public comment. 101

102 706.0 Changes in Direction of Drainage Flow Changes in direction of drainage piping shall be made by the appropriate use of approved fittings and shall be of the angles presented by a one-sixteenth (1/16) bend, one-eighth (1/8) bend, one-sixth (1/6) bend, or other approved fittings of equivalent sweep. In horizontal piping and building sewers, any combination of fittings shall be made with their centerlines aligned so as to maintain uniform slope. The originally submitted change was directed to Section Changes of Direction. This statement directs readers to refer also to Sections and as shown below Grade of Horizontal Drainage Piping. Horizontal drainage piping shall be run in practical alignment and a uniform slope of not less than onefourth (1/4) inch per foot (20.9 mm/m) or 2 percent toward the point of disposal Building sewers shall be run in practical alignment and at a uniform slope of not less than onefourth (1/4) inch per foot (20.9 mm/m) toward the point of disposal. Section requires the appropriate use of approved fittings and Sections and 718.1, both require a uniform slope. For the purposes of this document, the word inline shall mean with their centerlines aligned. The manufacturing segment of the plumbing industry has traditionally offered a limited number of fixed angle bends. For example, the plastic pipe industry offers four fixed angle bends (1/4, 1/6, 1/8 and 1/16 bends). These bends, whether alone or in combination with each other, offer a total of six (6) inline angle combinations, where a uniform slope can be maintained. What happens for the other 60 or 70 other practical angles that are encountered? In the industry, the most common method of creating bends with non-standard angles is to roll several fixed angle bends together to form a custom angle. This rolling technique is performed by combining and offsetting the centerlines of two or more fixed angle bends to achieve a single change in direction. It is considered by many installers in the plumbing field to be an art. And it is a skill that requires knowledge, experience and timing. The knowledge to know what angle is needed for the change in direction, experience to understand how two (or three) different angles, when combined, will result in the desired angle and timing because in the case of plastic fittings, the cements used to seal the joints harden quickly. Until recently, when a selectable angle bend was added to the ASTM standards and became a UPC approved fitting, rolling was the only way of making a non-standard change in direction. Other methods, which include heating and bending the pipe or forcibly flexing the pipe are usually not acceptable. While making changes of direction of horizontal drainage piping, there is an inherent problem when nonstandard angles are encountered. The problem occurs when creating a change of direction using the rolling or combination technique. While almost any angle can be achieved by rolling two or more bends together, it is impossible to maintain a uniform slope in the piping. This happens because once the centerlines of the bends being rolled are offset, the piping deviates from its uniform slope. This can cause abrupt changes in the speed of the flow including increases and/or decreases of the slope. The problem is well known in the industry and particularly in the field, but without specific code language, it is often ignored and is very difficult to enforce. Figure 1A and 1B show two examples (67.5 and 70 degrees) of how slope remains uniform when fitting combinations are installed inline. Figure 2 shows four of the many possible examples of a 70-degree horizontal change of direction where the rolled combinations (one 1/8 bend and one 1/8 street bend) exhibit a deviation in the slope. The first shows how both pipes could be on the same slope but the flow must transition through a steep drop and make two changes of direction before entering the lower section of pipe. The slope is not uniform and the downstream section of pipe is significantly lower. 102

103 The second and third examples show the rolled combination needed for the piping to arrive back to the point where a pipe with a uniform slope would have occurred. Surely these combinations of fittings would be unacceptable but possibly overlooked in the field. The fourth shows a steep increase in the slope. Of all the many possible rolled combinations, none of them yield a uniform slope. In summary, the only way to make a change of direction and maintain a uniform slope in a horizontal piping system is if only one bend is used or a combination of bends are installed inline. As an alternate to the originally submitted changes, the attached comment is offered for your consideration. This language would require that the approved fittings are installed in a particular way that ensures compliance with the already established requirements of the code. Item # 122 Comment Seq # 53 UPC (New) SUBMITTER: Dave Cantrell Seattle-King County Public Health Add new text as follows: Grinder Pump Ejector. Grinder pumps shall be permitted to be used Discharge Piping. The discharge piping shall be sized per the manufacturer s instructions and shall not be less than 1-1/4 inches (32 mm) in diameter. A check valve and fullway-type shutoff valve shall be located within the discharge line. Similar to a macerating toilet system, the discharge from a grinder pump may be smaller than that of a sewage ejector. The manufacturer s installation instructions will dictate the size of discharge. Without some direction in the code, for the user to follow including the manufacturer s installation instructions, one could draw the conclusion that he discharge requirements for sewage ejectors in Section would apply. However, the check valve and gate valve requirements should apply to grinder pumps as well as sewage ejectors and macerating toilet systems. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: John Halliwill, Halliwill and Associates Request to accept the code change proposal as modified by this public comment Grinder Pump Ejector. Grinder pumps shall be permitted to be used Discharge Piping. The discharge piping shall be sized per the manufacturer s instructions and shall not be less than 1-1/4 inches (32 mm) in diameter. A check valve and fullway-type shutoff valve shall be located within the discharge line. 103

104 I prefer that the Technical Committee review, consider and approve my comment to reconsider my original proposal. While the original proposal by Dave Cantrell does provide additional requirements I believe my proposal included additional specific requirements to help the contractor, journeyman and inspector understand how these important installations should be installed. Item # 123 Comment Seq # 54 UPC (New) SUBMITTER: John Halliwill Halliwill and Associates Insert new text as follows: Grinder Pump Ejector. Grinder pumps shall be permitted to be used The discharge pipe from the grinder pump shall be sized per the pump manufacturers instructions and shall not be less than 1-1/4 inches (32 mm) in diameter The discharge line from the grinder pump shall be provided with an accessible backwater or swing check valve and gate or ball valve. If the gravity drainage line to which such discharge line connects is horizontal, the method of connection shall be from the top through a wye branch fitting. The gate or ball valve shall be located on the discharge side of the backwater or check valve. Gate or ball valves, when installed in drainage piping, shall be a fullway type with working parts of corrosion-resistant metal The flow rate through the discharge pipe shall maintain a minimum of two (2) gpm The grinder pump enclosure shall be vented to the venting system of the building or through the roof as required for regular plumbing systems. The minimum size of the vent shall be as recommended by the manufacturer Cleanouts shall be installed according to Section of this code. During this last code change cycle this section was changed to use mandatory language. No language was added to give the AHJ information on how to install these types of pumps. The only current language is contained in Section Installation Practices. There are no specific code sections that say how to install these systems. The only coverage is for sewage ejectors or sewage pumps is contained among the subsections of Section of this code. By adding some specific references into this section it is hoped that the AHJ and others will be able to properly size these systems and not use the minimum requirements for sewage ejectors or pumps. I have been involved in code discussions where inspectors and others were trying to require two and three inch discharge piping for these pumps. Unless specifically designed for these loads the pumps will not discharge the waste from the basin into the drainage system. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on committee action taken on Item 122 as the proposed text is preferred. 104

105 A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: John Halliwill, Halliwill and Associates Request to accept the code change proposal as modified by this public comment Grinder Pump Ejector. Grinder pumps shall be permitted to be used The discharge pipe from the grinder pump shall be sized per the pump manufacturers instructions and shall not be less than 1-1/4 inches (32 mm) in diameter The discharge line from the grinder pump shall be provided with an accessible backwater or swing check valve and gate or ball valve. If the gravity drainage line to which such discharge line connects is horizontal, the method of connection shall be from the top through a wye branch fitting. The gate or ball valve shall be located on the discharge side of the backwater or check valve. Gate or ball valves, when installed in drainage piping, shall be a fullway type with working parts of corrosion-resistant metal The flow rate through the discharge pipe shall maintain a minimum of two (2) feet per second The grinder pump enclosure shall be vented to the venting system of the building or through the roof as required for regular plumbing systems. The minimum size of the vent shall be as recommended by the manufacturer Cleanouts shall be installed according to Section of this code. I am requesting the Technical Committee (TC) to reconsider my original proposal because I believe it is more complete than the one that they accepted shown on UPC Comment #122. Such as I have included a requirement for the venting of the sump. I have modified the comment to include the TC concerns with the use of macerating toilet systems. I reviewed data from the internet and it appears that all of the requirements for the standard grinder system that was originally installed outside the building at or near the junction of the building drain and the building sewer are the same as the macerating toilet system except for the size of the discharge pipe. It should also be noted that at times the standard grinder pump is installed in the building subject to the Authority Having Jurisdiction. Additionally, I have changed the minimum flow rate requirement because after reviewing the 2006 National Standard Plumbing Code Section (b.) and the history of the Uniform Plumbing Code. I have found this is the design figure that should be used. Item # 124 Comment Seq # 55 UPC (New) SUBMITTER: John Halliwill Halliwill and Associates Add new text as follows: Final Air Test. The final test of the completed drain, waste and vent system shall be tested with air or shall be permitted to be also tested with either the addition of smoke or peppermint. 105

106 Where testing with air the fixtures need to be installed, all trap openings need to be properly filled with water, the building drain sealed and the stack(s) sealed. No water, other liquids or waste are to be added to the system once it is sealed. Apply air pressure until either the entire system or sections of the system indicate that they are being subjected to at least a one (1) inch water column. The test is to be maintained for a minimum of fifteen (15) minutes before the start of the inspection and the test shall indicate that the system is tight at all points Where testing with smoke, it shall be made by filling all the traps with water and then introducing into the entire system a pungent, thick smoke produced by one or more smoke machines. When the smoke appears at the stack or stack openings on the roof they shall be closed and a pressure equivalent to a one (1) inch water column shall be built and maintained for fifteen (15) minutes before the inspection starts Where the peppermint test is used, two (2) ounces of oil of peppermint shall be introduced for each line or stack The drain, waste and vent testing required by Sections and shall be met where the system has been tested according to this section and found that it is tight at all points. Sections and requires a test of the drain, waste and vent system. The proposed test method will allow an alternative method to the requirements contained in by not having to remove the fixtures in a moved building and also would help eliminate possible water damage to the moved building and its contents if water were used to test the system and there was a leak. Section says there shall be a final test but the code does not indicate what the test requirements are. Thus, this section gives the AHJ a method for testing when none is currently stated in the code. This method was used by contractors and verified by inspectors when I was working in the field as a plumbing inspector. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Testing procedures currently utilized are sufficient and procedures proposed are not acceptable. Air testing on plastic pipe and fittings is not a safe practice. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: John Halliwill, Halliwill and Associates Request to accept the code change proposal as submitted by this public comment. The Technical Committee (TC) stated Testing procedures currently utilized are sufficient and procedures proposed are not acceptable. Air testing on plastic pipe and fittings is not a safe practice. I am requesting that the TC reconsider their original decision to reject because as I stated in my original proposal that there are currently no requirements on how to do a final test in the code. The method described has been used successfully for many years, and I understand is still used and that I observed for at least twenty years as a Plumbing Inspector in the field. I have also reviewed the International 106

107 Plumbing Code and the National Standard Plumbing Code for any requirements that they may have. I have found that while they are not the same as suggested, I believe that having requirements is another justification for there being requirements in the Uniform Plumbing Code. This would give the contractor, inspectors and other installing these important systems additional information on how to test these important systems. I have spoken with contractors and inspectors over the years that have no idea what a final test is let alone how to do one. I have also checked with the Technical Staff at the Plastic Pipe and Fittings Association to see if this was a problem from their perspective. Their initial comment was they did not feel this was a problem because this pressure test did not exceed the normal operating pressure in the plumbing system before a trap failure that would release any additional pressure. This item is to be discussed with their committee and when they have met I have requested a letter of finding from them. Item # 129 Comment Seq # 56 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revise text as follows: Chemical Waste Chemical or industrial liquid wastes that are likely to damage or increase maintenance costs on the sanitary sewer system, detrimentally affect sewage treatment, or contaminate surface or subsurface waters shall be pretreated to render them innocuous prior to discharge into a drainage system. Detailed plans and specifications of the pretreatment facilities shall be required by the Authority Having Jurisdiction. Piping conveying industrial, chemical, or process wastes at ambient and high temperatures (maximum 180 F) from their point of origin to sewer-connected pretreatment facilities shall be of such material and design as to adequately perform its intended function to the satisfaction of the Authority Having Jurisdiction. Drainage discharge piping from pretreatment facilities or interceptors shall conform to standard installation procedures. Copper tube shall not be used for chemical or industrial wastes as defined in this section. Not all chemicals at all temperatures are appropriate for every piping material used in chemical waste systems. This proposed code change will alert designer, installer and Authority Having Jurisdiction to assure that appropriate materials are specified and used in the field. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The submitter needs to address all temperature ranges within these types of systems. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting 107

108 Request to accept the code change proposal as modified by this public comment Chemical or industrial liquid wastes that are likely to damage or increase maintenance costs on the sanitary sewer system, detrimentally affect sewage treatment, or contaminate surface or subsurface waters shall be pretreated to render them innocuous prior to discharge into a drainage system. Detailed plans and specifications of the pretreatment facilities shall be required by the Authority Having Jurisdiction. Piping conveying industrial, chemical, or process wastes at all temperatures between ambient and 140 F from their point of origin to sewer-connected pretreatment facilities shall be of such material and design as to adequately perform its intended function to the satisfaction of the Authority Having Jurisdiction. Drainage discharge piping from pretreatment facilities or interceptors shall conform to standard installation procedures. Copper tube shall not be used for chemical or industrial wastes as defined in this section. Not all chemicals at all temperatures are appropriate for every piping material used in chemical waste systems. This proposed change will alert designers, installers and the Authority Having Jurisdiction to ensure that appropriate materials are specified and used in these systems. While some materials are tested in appropriate consensus standards to 180 F we have lowered the high temperature exposure to 140 F to be in line with 140 F maximum allowed to be discharged under pressure into any part of a drainage system in accordance with Section Item # 131 Comment Seq # 57 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revise text as follows: Each waste pipe receiving or intended to receive the discharge of any fixture into which acid or corrosive chemical is placed, and each vent pipe connected thereto, shall be constructed of CPVC, PP, PVDF, chemical-resistant glass, high-silicon iron pipe, or lead pipe with a wall thickness of not less than one-eighth (1/8) inch (3.2 mm); an approved type of ceramic glazed or unglazed vitrified clay; or other approved corrosion-resistant materials approved for use based on the chemicals discharging into the chemical waste system. This proposed code change will add CPVC to recognized materials for chemical waste systems and clarify that not all materials are resistant to various types of chemical waste systems. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on committee action taken on Item 130 as the proposal is preferred. 108

109 A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Sidney Cavanaugh, Cavanaugh Consulting Request to accept the code change proposal as submitted by this public comment. We only want to comment on the second part of our proposal since the Technical Committee added CPVC to this section by their action on Item 130. We still believe there is merit in adding the words approved for use based on the chemicals discharging into the chemical waste system. It is still necessary to clarify that not all materials are resistant to all chemicals discharged into chemical waste systems and that the appropriate material must be used dependent on those chemicals. Item # 133 Comment Seq # 58 UPC , , , SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #133). Revise text as follows: Vent pipe and fittings shall be in accordance with one of the referenced standards in Table 7-1. cast iron, galvanized steel, galvanized wrought iron, copper, brass, Schedule 40 ABS DWV, Schedule 40 PVC DWV, stainless steel 304 or 316L (stainless steel 304 pipe and fittings shall not be installed underground and shall be kept at least six inches (152 mm) aboveground), or other approved materials having a smooth and uniform bore except that: No galvanized malleable wrought-iron, or galvanized steel pipe or 304 stainless steel shall be used underground and shall be kept at least six (6) inches (152 mm) aboveground ABS and PVC DWV piping installations shall be installed in accordance with the applicable standards referenced in Table 14-1 IS 5, IS 9, and Chapter 15 Firestop Protection. Except for individual single-family dwelling units, materials exposed within ducts or plenums shall have a flame-spread index of not more than 25 and a smoke-developed index of not more than 50 when tested in accordance with the Test for Surface-Burning Characteristics of the Building Materials (see the Building Code standards based on ASTM E-84 and ANSI/UL 723) Vent fittings shall be cast iron, galvanized malleable iron, or galvanized steel, copper, brass, ABS, PVC, stainless steel 304 or 316L, or other approved materials., except that no galvanized malleable iron, or galvanized steel, or 304 stainless steel shall be used underground and shall be kept at least six (6) inches (152 mm) aboveground. Stainless steel 304 pipe and fittings shall not be installed underground and shall be kept at least 6 inches (152 mm) aboveground. These sections needed revision based on adding Table 7-1 for DWV pipe applications along with their respective standards. Section indicates that All IAPMO Installation Standards are included in 109

110 Appendix I for the users of this code. They are not considered as a part of this code unless formally adopted as such by the Authority Having Jurisdiction. Using the terms IAPMO Installation Standards as a requirement in the code does not correlate and contradicts Section COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Vent pipe and fittings shall be in accordance with one of the referenced standards in Table 7-1 except that: No galvanized malleable iron, or galvanized steel or 304 stainless steel shall be used underground and shall be kept at least six (6) inches (152 mm) aboveground ABS and PVC DWV piping installations shall be in accordance with the applicable standards referenced in Table 14-1, and Chapter 15 Firestop Protection. Except for individual single-family dwelling units, materials exposed within ducts or plenums shall have a flame-spread index of not more than 25 and a smoke-developed index of not more than 50 when tested in accordance with the Test for Surface-Burning Characteristics of the Building Materials (see the Building Code standards based on ASTM E-84 and ANSI/UL 723) Conductors installed aboveground in buildings shall be in accordance with one of the referenced standards in Table 7-1 for aboveground drain, waste and vent pipe. constructed of materials specified in Table Leaders shall be of seamless copper water tube, Type K, L, or M; Schedule 40 copper pipe; Schedule 40 copper alloy pipe; type DWV copper drainage tube; service weight cast-iron soil pipe or hubless cast-iron soil pipe; aluminum sheet metal, galvanized steel sheet metal, or copper sheet metal; standard weight galvanized steel pipe; Class DL or XL lead pipe; stainless steel 304 or 316L (stainless steel 304 pipe and fittings shall not be installed underground and shall be kept at least 6 inches (152 mm) aboveground); or Schedule 40 ABS or Schedule 40 PVC plastic pipe Leaders installed outside shall be constructed of materials specified in Table 14-1 in accordance with one of the referenced standards in Table 7-1 for aboveground drain, waste and vent pipe; aluminum sheet metal; galvanized steel sheet metal; or copper sheet metal Underground Building Storm Drains. All Underground building storm drains shall be in accordance with one of the referenced standards in Table 7-1 for underground drain, waste and vent pipe. constructed of materials specified in Table Building Storm Sewers. Building storm sewers shall be in accordance with one of the referenced standards in Table 7-1 for building sewer pipe. constructed of materials specified in Table COMMITTEE STATEMENT: Modification to align standards with the type of material utilized for storm drainage. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Toni Crimi, A.C. Consulting Solutions, Inc. Request to accept the code change proposal as modified by this public comment Vent pipe and fittings shall be in accordance with one of the referenced standards in Table 7-1 except that: 110

111 No galvanized malleable iron, or galvanized steel or 304 stainless steel shall be used underground and shall be kept at least six (6) inches (152 mm) aboveground ABS and PVC DWV piping installations shall be in accordance with the applicable IAPMO installation standards referenced in Table 14-1, and Chapter 15 Firestop Protection. Except for individual single-family dwelling units, materials exposed within ducts or plenums shall have a flamespread index of not more than 25 and a smoke-developed index of not more than 50 when tested in accordance with the Test for Surface-Burning Characteristics of the Building Materials (see the Building Code standards based on ASTM E-84 and ANSI/UL 723) Conductors installed aboveground in buildings shall be in accordance with one of the referenced standards in Table 7-1 for aboveground drain, waste and vent pipe Leaders installed outside shall be in accordance with one of the referenced standards in Table 7-1 for aboveground drain, waste and vent pipe; aluminum sheet metal; galvanized steel sheet metal; or copper sheet metal Underground Building Storm Drains. Underground building storm drains shall be in accordance with one of the referenced standards in Table 7-1 for underground drain, waste and vent pipe Building Storm Sewers. Building storm sewers shall be in accordance with one of the referenced standards in Table 7-1 for building sewer pipe. The revised proposal presented here is intended to retain the revised text for vent pipes and vent fittings. In regards to installation, the reference to Chapter 15 is sufficient to provide information on when and how to provide firestopping around these types of pipes. The existing approach in section 303.7, where the term IAPMO Installation Standards is used is a better approach than the proposed revision. Appendix I provides the users of this code with a useful resource. Alternatively, if the concern is with having material in Appendix I that is not contained in any mandatory references in the body of the Code, then a more appropriate solution is to remove the material and reference documents from Appendix I altogether, given that there are better options available in the marketplace. Furthermore, this section of the Code is not specifically related to firestopping at all. The need to firestop these pipes is already in section This additional language is redundant. The IFC has particular concerns with respect to the mandatory use ASME A , Standard for Qualification of Installers of Firestop Systems and Devices for Piping Systems. One currently existing means that a user has of ensuring that the installer is knowledgeable in fire stop installation is by requiring that the installer meet a minimum qualification standard. The FM Global Standard for Approval of Firestop Contractors and the UL Qualified Firestop Contractor Program were developed to provide users with a benchmark that firestopping installers must meet in order to be approved or registered. Such contractors must pass examinations based on the accepted industry reference materials, codes and standards, the FCIA Manual of Practice, and must undertake continuing education to maintain their standing. Re-examination is required every three years. Under the UL Qualified Contractor Program, candidates are offered a U.S. or Canadian examination based on US or Canadian code requirements. Installers, qualified to the standards, can be found throughout North America. Users can determine that the work has been performed by qualified installers by seeking the FM Global or UL/ULC mark on the completed fire stops in the field and by inquiring about certification from the installer. In addition, trade associations and others may offer detailed training for installation personnel. A mandatory reference to ASME A as proposed here would prohibit these qualified firms and programs from complying with the UPC based solely on the fact that the individuals performing the function may not have 4 years of plumbing experience. Consequently, this proposed Code change would prohibit experienced, qualified, even certified contractors and individuals from installing firestopping around piping. 111

112 PUBLIC COMMENT 2: Submitter: Bill McHugh, Firestop Contractors International Association Request to reject the code change proposal by this public comment. FCIA comments that the reference to ASME A be rejected completely. The Firestop Contractors International Association comments that this standard is not applicable, as it requires that all firestopping be installed by journeyworkers who have passed a 4 year apprenticeship in plumbing. Item # 134 Comment Seq # 59 UPC SUBMITTER: Jack Beuschel Studor, Inc. Revise text as follows: Each vent pipe or stack shall extend through its flashing and shall terminate vertically not less than six (6) inches (152 mm) above the roof nor less than one (1) foot (305 mm) from any vertical surface. Exception: Individual, branch, and stack vents shall be permitted to terminate to an air admittance valve in accordance with Section 911. In plumbing installations it has been necessary to extend vent pipes to the atmosphere. This has resulted in problems relating to extensive vent piping, roof penetrations requiring vent pipe flashings that eventually leak, floor penetrations requiring fire-stopping devices, weakening of building frames, and frost closures as well as pollution of the environment and indoor air by sewer gas. Air admittance valves (AAVs) can resolve problems since they permit a relatively easier solution than venting to the atmosphere. Since there are less open pipes, the possibility of water entering the building through vent pipe roof flashings is substantially reduced. The AAV opens under negative pressure conditions allowing air to enter the DWV system preventing siphonage of the water trap. The valve closes by gravity under neutral and positive pressure, preventing the escape of sewer gas. It operates by means of a pressure/gravity-activated sealing assembly that acts as a one-way valve. Positive pressure will find relief through the open pipe relief vent required on the building drain when AAVs are installed. Systems in which AAVs are installed in conjunction with a minimum of one open vent pipe protect fixture traps against siphonage and backpressure, and air circulation is ensured throughout all parts of the system in compliance with the intent of Section of the UPC. Studies have proven that by installing AAVs in the DWV system both positive and negative pressure transients are reduced and better controlled than in an open pipe system. Installation of AAVs has no adverse effect on the operation of the system and provides benefits in terms of trap seal protection under all conditions. AAVs have been installed in Europe since 1972 and in the USA since The valves have been field tested and have proven to be a safe alternative to open pipe vents. The performance standards for AAVs are ASSE 1050 and 1051 and NSF

113 The Technical Committee was provided with a report titled, Building Drainage Waste and Vent systems: Options for efficient pressure control. To review a copy of this report, please contact: Jack Beuschel, Studor Inc., 1125G 47th St. North, Clearwater, FL , (727) COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on committee action taken on Item 239. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Jack Beuschel, Studor, Inc. Request to accept the code change proposal as submitted by this public comment. I disagree with the Committee s action to deny Studor s original proposals made in Items 3, 134 and 139 based on the Committee s action on Item 239, which is to include air admittance valves (AAVs) in Appendix L. This action does not constitute a technical reason to deny Studor s original proposals to include AAVs in the body of the UPC. With regard to the explanation of the negatives I would like to comment as follows: AAVs have been installed in Europe since early 1970 and in the USA since There are millions of valves installed; they have been field tested and found to equivalent to open pipe venting systems. The recent study prepared by Dr. Michael Gormley and Prof. John Swaffield titled Building Drainage Waste and Vent Systems: Options for Efficient Pressure Control shows that systems in which AAVs are installed are equivalent to open pipe vented systems in low-rise buildings in terms of trap seal retention and are superior to open pipe systems in high-rise buildings. This study is referenced in Items 134 and 139. During the last 37 years millions of valves have been installed worldwide without any documented evidence that they have created a health hazard or health risk. AAVs are not mechanical since they are not operated by a mechanism (such as a spring or lever). The valves open under negative pressure and close by gravity (both natural forces, not mechanical). DWV systems in which AAVs are installed always have a minimum of one open vent pipe that will relieve any positive pressure that might develop in the system. The states of Wisconsin and Colorado were referenced. It is interesting to note that AAVs were approved in both states in Since then thousands of valves have been installed in those states and they have successfully protected the health of the public. Item # 135 Comment Seq # 60 UPC , 908.4, , , SUBMITTER: Bob Adler Chair, Correlation Task Group The following is recommended by the Correlation Task Group (see Correlation Task Group Report Item #135). Revise text as follows: 113

114 204.0 Bathroom (Group) - A room equipped with a shower or bathtub A group of fixtures consisting of a water closet, lavatory, bathtub or shower, urinal or bidet and emergency floor drain Horizontal Bathroom Wet Venting for Bathroom (Groups) Where permitted. Any combination of fixtures within one (1) or two (2) bathrooms located on the same floor level and for private use in dwellings and guest rooms shall be permitted to be vented by a wet vent. The wet vent shall be considered the vent for the fixtures and shall extend from the connection of the dry vent along the direction of the flow in the drainpipe to the most downstream fixture drain or trap arm connection to the horizontal branch drain. Each wet-vented fixture drain or trap arm shall connect independently to the wet-vented horizontal branch drain. Each individual fixture drain or trap arm shall connect horizontally to the wet-vented horizontal branch drain or shall be provided with a dry vent. The trap to vent distance shall be in accordance with Table Only the fixtures within the bathroom(s) shall connect to the wet vented horizontal branch drain. Any additional fixtures shall discharge downstream of the wet vent system and be conventionally vented Vent Connection. The dry vent connection to the wet vent shall be an individual vent or common vent for the lavatory, bidet, shower or bathtub. Only one wet-vented fixture drain or trap arm shall discharge upstream of the dry-vented fixture drain connection Size. The wet vent shall be sized based on the fixture unit discharge into the wet vent. The wet vent shall be not less than 2 inches (50 mm) in diameter for 4 dfu or less, and not less than 3 inches (80 mm) in diameter for 5 dfu or more 4 dfu. The dry vent shall be not less than 2 inches (50 mm) in diameter. This definition should correlate and define fixtures that are located in a bathroom. This is critical, as Section requires the user to identify what fixtures are included in a bathroom for horizontal wet venting. Without the correlation, the user cannot apply horizontal wet venting for a single or double bathroom group. In addition, the term bathroom and bathroom groups are used throughout the code and appendices. For example, a bathroom or bathroom group may consist of a water closet, lavatory, bathtub or shower, including a urinal or bidet, an emergency floor drain or both. This would total a maximum of 5 fixtures for one bathroom group (1 water closet, 1 lavatory, 1 bathtub or shower, 1 urinal or bidet and 1 emergency floor drain). No mix or matching and only one of each type of fixture listed. For a double bathroom group a maximum of 10 fixtures [2 water closets, 2 lavatories, 2 bathtubs or showers (or 1 bathtub and 1 shower) 2 urinals or bidet (or 1 bidet and 1 urinal) and 2 emergency floor drains]. This section permits wet venting bathrooms in dwellings and guestrooms; however, both terms are not defined in this code. The intent of this section is to provide for the wet venting of bathroom located for private use as described by the terms dwelling and guestrooms (see definition of private use). The fixtures located in these bathroom groups are intended for the use of an individual or family. The proposed code change further clarifies the intent of this section by requiring each fixture drain/trap arm to connect independently to the horizontal wet vented branch in the horizontal plane to prevent S- traps and disruption of flow. Therefore, the order or location of various fixture drains is irrelevant regardless of where water closets are installed. The alternative is to provide a dry vent. Lastly, the trap to vent distance provisions apply and should be referenced. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. 114

115 PUBLIC COMMENT 1: Submitter: Richard Wagner, Chair, Horizontal Wet Venting Task Group The following is recommended by the Horizontal Wet Venting Task Group (see Horizontal Wet Venting Task Group Report for Item #135). Request to accept the code change proposal as modified by this public comment: Bathroom (Group) - A group of fixtures consisting of a water closet, one or two lavatories, and either a bathtub, a combination bath/shower or a shower and may include a urinal, bidet and emergency floor drain Wet Venting Vertical Wet Venting Where permitted. (No change to existing text) Size. (No change to existing text) Vent Connection. (No change to existing text) Horizontal Wet Venting for Bathroom Groups Where permitted. Any combination of fixtures Water closets, bathtubs, showers and floor drains within one (1) or two (2) bathrooms groups, located on the same floor level and for private use shall be permitted to be vented by a wet vent. The wet vent shall be considered the vent for the fixtures and shall extend from the connection of the dry vent along the direction of the flow in the drainpipe to the most downstream fixture drain or trap arm connection to the horizontal branch drain. Each wet-vented fixture drain or trap arm shall connect independently to the wet-vented horizontal branch drain. Each individual fixture drain or trap arm shall connect horizontally to the wet-vented horizontal branch drain or shall be provided with a dry vent. The trap to vent distance shall be in accordance with Table Only the fixtures within the bathroom(s) groups shall connect to the wet vented horizontal branch drain. The water closet fixture drain or trap arm connection to the wet vent shall be downstream of any fixture drain or trap arm connections. Any additional fixtures shall discharge downstream of the wet vent system and be conventionally vented Vent Connection. The dry vent connection to the wet vent shall be an individual vent or common vent for the lavatory, urinal, bidet, shower or bathtub. Only one wet-vented fixture drain or trap arm shall discharge upstream of the dry-vented fixture drain connection Size. The wet vent shall be sized based on the fixture unit discharge into the wet vent. The wet vent shall be not less than 2 inches (50 mm) in diameter for 4 dfu or less, and not less than 3 inches (80 mm) in diameter for 5 dfu or more. The dry vent shall be sized by Tables 7-3 and 7-5 based on the total fixtures units discharging into the wet vent. The dry vent shall be not less than 2 inches (50 mm) in diameter. These modifications provide clarity in intent by stating a prescriptive method for the design and installation requirements. The modifications take into consideration the approved UPC TIA and the assembly action to Item 135 as modified. Prescriptive coverage is needed to prevent improper installation practices. In determining the adequacy of a drainage system, with a particular type of venting method, it is necessary first to determine the trap-seal losses which occur in the system under loading conditions. In addition, it is also necessary to establish a criterion of satisfactory trap performance; this is, to establish between trap-seal losses that may be considered satisfactory and those that may be 115

116 considered sufficiently large enough to impair the ability of the trap to prevent the entrance into the building of sewer gas in objectionable amounts. The location of a water closet is relevant for the installation of this type of system as pressures in the drainage system may be generated from pressureassist water closets. Therefore, a water closet fixture drain or trap arm connection to the wet vent must be downstream of any other wet vented fixture drain or trap arm connection to prevent the possibility of trap seal losses or self-siphoning of traps. PUBLIC COMMENT 2 (Assembly Action): Submitter: David Ledda, City of San Francisco Request to accept the code change proposal as modified by this public comment Bathroom (Group) - A group of fixtures consisting of a water closet, lavatory, bathtub or shower, urinal or bidet and emergency floor drain. APPENDIX L L Horizontal Bathroom Wet Venting for Bathroom (Groups). L Where permitted. Any combination of fixtures within one (1) or two (2) bathrooms located on the same floor level and for private use shall be permitted to be vented by a wet vent. The wet vent shall be considered the vent for the fixtures and shall extend from the connection of the dry vent along the direction of the flow in the drainpipe to the most downstream fixture drain or trap arm connection to the horizontal branch drain. Each wet-vented fixture drain or trap arm shall connect independently to the wet-vented horizontal branch drain. Each individual fixture drain or trap arm shall connect horizontally to the wet-vented horizontal branch drain or shall be provided with a dry vent. The trap to vent distance shall be in accordance with Table Only the fixtures within the bathroom(s) shall connect to the wet vented horizontal branch drain. Any additional fixtures shall discharge downstream of the wet vent system and be conventionally vented. The water closet trap arm connection to the wet vent shall be downstream of the other fixture arm connections. L Vent Connection. The dry vent connection to the wet vent shall be an individual vent or common vent for the lavatory, bidet, shower or bathtub. Only one wet-vented fixture drain or trap arm shall discharge upstream of the dry-vented fixture drain connection. L Size. The wet vent shall be sized based on the fixture unit discharge into the wet vent. The wet vent shall be not less than 2 inches (50 mm) in diameter for 4 dfu or less, and not less than 3 inches (80 mm) in diameter for 5 dfu or more 4 dfu. The dry vent shall be not less than 2 inches (50 mm) in diameter. (Renumber remaining sections) L2.0 Engineered Plumbing Systems: L 2.1 Definition. Engineered Plumbing System: A system designed for a specific building project with drawings and specifications indicating plumbing materials to be installed, all as prepared by an engineer, contractor or other a person registered or licensed to perform plumbing design work. This section potentially permits water closets to be upstream of fixtures, such as a tub or shower, or to even permit unvented lavatories; thereby creating a condition where the traps could be siphoned and the possibility exist for sewer gas to permeate. The specific conditions for horizontal wet venting should be put back into Appendix L, were the problems can be adequately addressed by an engineered design. 116

117 Item # 138 Comment Seq # 61 UPC (New) SUBMITTER: Robert Evans American Society of Plumbing Engineers Add new text as follows: Engineered Vent System General. The design and sizing of a vent system shall be permitted to be determined by accepted engineering practice. The system shall be designed by a registered design professional and approved in accordance with Section Minimum Requirements. An engineered vent system shall provide protection of the trap seal in accordance with Section Design Options. Engineered systems specified in Appendix L shall be permitted to be used in engineered vent systems. This new section will provide the reference to engineered vent systems. This section will add understanding regarding an engineered vent system. It will also limit the design of engineered systems to registered design professionals. This is consistent with the state laws for architects and professional engineers. Section references the proposed new section on trap seal protection. This is an important design factor for vent systems. By stating this requirement, it will be clear to the authority having jurisdiction that the system must be designed to prevent pressure excursions that exceed 1-inch of a water column. COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Engineered Vent System General. The design and sizing of a vent system shall be permitted to be determined by accepted engineering practice. The system shall be designed by a registered design professional and approved in accordance with Section Minimum Requirements. An engineered vent system shall provide protection of the trap seal in accordance with Section Design Options. For other engineered design systems specified in see Appendix L. shall be permitted to be used in engineered vent systems. COMMITTEE STATEMENT: The modification maintains consistency with other references to the appendices. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Brent Hipshfer, City of Palo Alto 117

118 Request to accept the code change proposal as modified by this public comment Engineered Vent System General. The design and sizing of a vent system shall be permitted to be determined by accepted engineering practice. The system shall be designed by a registered design professional and approved in accordance with Section Minimum Requirements. An engineered vent system shall provide protection of the trap seal in accordance with Section Design Options. For other engineered design systems see Appendix L. Proposed Section should be deleted. Section (both as submitted and as modified by the Technical Committee) contains unnecessary, ambiguous and inappropriate reference to Appendix L. Item # 139 Comment Seq # 62 UPC (New) SUBMITTER: Jack Beuschel Studor, Inc. Add new text as follows: Air Admittance Valves Where permitted. An individual vent, branch vent, vent stack or stack vent shall be permitted to terminate with a connection to an air admittance valve. Air admittance valves shall be installed in accordance with the manufacturer s installation instructions and this section Individual and branch type air admittance valves. Individual and branch type air admittance valves shall only vent fixtures located on the same floor level Installation requirements. Fixtures being vented by individual or branch type air admittance valves shall connect to a horizontal drainage branch that meets one of the following requirements: a. The horizontal branch shall connect to the drainage stack or building drain a maximum of thirty-five (35) feet from the top of the stack, or. b. The horizontal branch shall be provided with relief vent, not less than one and one-half (11/2) inches in diameter. The relief vent shall connect to a vent that extends to the outdoor air. The relief vent shall be located between the fixture(s) vented by the air admittance valve and the connection to the stack Stack type air admittance valves. Stack type air admittance valves shall be permitted to vent fixtures on different floor levels Maximum stack height. The maximum stack height of a drainage stack being vented by an air admittance valve shall be fifty (50) feet. 118

119 911.6 Location. Individual and branch type air admittance valves shall be located not less than four (4) inches above the horizontal pipe of the trap arm. Stack type air admittance valves shall be located not less than six (6) inches above the flood level rim of the highest fixture being vented. Air admittance valves shall be located within the maximum developed length permitted for the vent piping. Air admittance valves shall be located not less than six (6) inches above building insulation material Access and ventilation. All air admittance valves shall be accessible and located within a space that allows air to enter the valve Size. The air admittance valve shall be rated for the size of the vent to which it is connected Vent to outdoors. A minimum of one vent shall extend outdoors to the open air for every plumbing system Limitation of installation. Air admittance valves shall not be installed on special waste systems and shall not be located within supply or return air plenums. In plumbing installations it has been necessary to extend vent pipes to the atmosphere. This has resulted in problems relating to extensive vent piping, roof penetrations requiring vent pipe flashings that eventually leak, floor penetrations requiring fire-stopping devices, weakening of building frames, and frost closures as well as pollution of the environment and indoor air by sewer gas. Air admittance valves (AAVs) can resolve problems since they permit a relatively easier solution than venting to the atmosphere. Since there are less open pipes, the possibility of water entering the building through vent pipe roof flashings is substantially reduced. The AAV opens under negative pressure conditions allowing air to enter the DWV system preventing siphonage of the water trap. The valve closes by gravity under neutral and positive pressure, preventing the escape of sewer gas. It operates by means of a pressure/gravity-activated sealing assembly that acts as a one-way valve. Positive pressure will find relief through the open pipe relief vent required on the building drain when AAVs are installed. Systems in which AAVs are installed in conjunction with a minimum of one open vent pipe protect fixture traps against siphonage and backpressure, and air circulation is ensured throughout all parts of the system in compliance with the intent of Section of the UPC. Studies have proven that by installing AAVs in the DWV system both positive and negative pressure transients are reduced and better controlled than in an open pipe system. Installation of AAVs has no adverse effect on the operation of the system and provides benefits in terms of trap seal protection under all conditions. AAVs have been installed in Europe since 1972 and in the USA since The valves have been field tested and have proven to be a safe alternative to open pipe vents. The performance standards for AAVs are ASSE 1050 and 1051 and NSF 14. The Technical Committee was provided with a report titled, Building Drainage Waste and Vent systems: Options for efficient pressure control. To review a copy of this report, please contact: Jack Beuschel, Studor Inc., 1125G 47th St. North, Clearwater, FL , (727) COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on committee action taken on Item 239. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Jack Beuschel, Studor, Inc. 119

120 Requests to accept the code change proposal as submitted by this public comment. I disagree with the Committee s action to deny Studor s original proposals made in Items 3, 134 and 139 based on the Committee s action on Item 239, which is to include air admittance valves (AAVs) in Appendix L. This action does not constitute a technical reason to deny Studor s original proposals to include AAVs in the body of the UPC. With regard to the explanation of the negatives I would like to comment as follows: AAVs have been installed in Europe since early 1970 and in the USA since There are millions of valves installed; they have been field tested and found to equivalent to open pipe venting systems. The recent study prepared by Dr. Michael Gormley and Prof. John Swaffield titled Building Drainage Waste and Vent Systems: Options for Efficient Pressure Control shows that systems in which AAVs are installed are equivalent to open pipe vented systems in low-rise buildings in terms of trap seal retention and are superior to open pipe systems in high-rise buildings. This study is referenced in Items 134 and 139. During the last 37 years millions of valves have been installed worldwide without any documented evidence that they have created a health hazard or health risk. AAVs are not mechanical since they are not operated by a mechanism (such as a spring or lever). The valves open under negative pressure and close by gravity (both natural forces, not mechanical). DWV systems in which AAVs are installed always have a minimum of one open vent pipe that will relieve any positive pressure that might develop in the system. The states of Wisconsin and Colorado were referenced. It is interesting to note that AAVs were approved in both states in Since then thousands of valves have been installed in those states and they have successfully protected the health of the public. Item # 142 Comment Seq # 63 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revised text as follows: Traps Prohibited. No form of trap that depends for its seal upon the action of bladders, check-valves or any other type of movable parts shall be used. No trap that has concealed interior partitions, except those of plastic, glass, or similar corrosion-resisting material, shall be used. S traps, bell traps, and crown-vented traps shall be prohibited. No fixture shall be double trapped. Drum and bottle traps shall be installed only for special conditions. No trap shall be installed without a vent, except as otherwise provided in this code. This clarification is necessary to protect the public health and safety. COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Traps Prohibited. No form of trap that depends for its seal upon the action of bladders, check-valves or any other type of movable parts shall be used. No trap that has concealed interior partitions, except those of plastic, glass, or similar corrosion-resisting material, shall be used. S traps, bell traps, and crown-vented traps shall be 120

121 prohibited. No fixture shall be double trapped. Drum and bottle traps shall be installed only for special conditions. No trap shall be installed without a vent, except as otherwise provided in this code Bladders, check valves or any other type of devices with moveable parts shall not be considered a trap. COMMITTEE STATEMENT: The proposed concept was accepted and the modification relocated text to the appropriate section. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Sidney Cavanaugh, Cavanuagh Consulting Request to accept the code change proposal as modified by this public comment Traps Prohibited. No form of trap that depends for its seal upon the action of movable parts shall be used. No trap that has concealed interior partitions, except those of plastic, glass, or similar corrosion-resisting material, shall be used. S traps, bell traps, and crown-vented traps shall be prohibited. No fixture shall be double trapped. Drum and bottle traps shall be installed only for special conditions. No trap shall be installed without a vent, except as otherwise provided in this code Bladders, check valves or any other type of devices with moveable parts shall not be considered a trap and are prohibited. While we are in complete support of the Committee action to approve and amend the original proposal to Item 142 we would like the committee to considered an editorial change to the wording, which would add and are prohibited. If the original wording had been added to there would be no doubt that they are prohibited but the added sentence simply says they are not a trap. Either go back to the original submittal or make this editorial change to eliminate any doubt that they are prohibited. PUBLIC COMMENT 2: Submitter: John Halliwill, Halliwill and Associates Request to reject the code change proposal by this public comment. The new section should be deleted for the following reasons. 1. Because the existing code wording is very specific as to what types of traps are prohibited this additional prescriptive wording is not needed. 2. Adding this additional prescriptive wording would not allow for future technologies as they are developed and would not allow for these new products to be installed even though they may provide better performance. 3. The existing code adequately protects the public health and safety in regards to traps. 4. There has been no scientific evidence presented to substantiate and support the original proposal in Section

122 Item # 144 Comment Seq # 64 UPC SUBMITTER: Daniel Gleiberman Falcon Waterfree Technologies Revise text as follows: Trap Seals. Each fixture trap shall have a water liquid seal of not less than two (2) inches (51 mm) and not more than four (4) inches (102 mm), except where a deeper seal is found necessary by the Authority Having Jurisdiction. Traps shall be set true with respect to their water seals and, where necessary, they shall be protected from freezing. The definition for a trap says water. This change will align this section with the definition. There are chemical waste system where water in the trap could present a dangerous reaction with the chemicals flowing through the trap seal. COMMITTEE ACTION: Accept as Amended by the TC Amend proposal as follows: Trap Seals. Each fixture trap shall have a liquid seal of not less than two (2) inches (51 mm) and not more than four (4) inches (102 mm), except where a deeper seal is found necessary by the Authority Having Jurisdiction. Traps shall be set true with respect to their water liquid seals and, where necessary, they shall be protected from freezing. COMMITTEE STATEMENT: Based on committee action for waterless urinals therefore, this definition should be revised to reflect that some fixture traps may incorporate a liquid seal instead of water. The modification adds the word liquid to the second sentence for consistency. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Arnie Rodio, Pace Setter Plumbing Request to reject the code change proposal by this public comment. I disagree with the committee decision to approve. Trap seals should be water. Everyone understands what water is. Liquid can be anything from water, oil, detergent, gasoline, urine, or blood. Under this code change you don t need trap primers you can just pour cooking oil into the trap to maintain a seal. To protect traps from freezing just add anti-freeze. It may seem extreme but this change opens up a Pandora s box. It is designed to allow waterless urinals but the change is not limited just to waterless urinals and their traps. It applies to all traps. 122

123 Item # 146 Comment Seq # 65 UPC SUBMITTER: Julius Ballanco JB Engineering and Code Consulting PC/REP Sure-Seal Revise text as follows: Trap Seal Protection. Floor drain or similar traps directly connected to the drainage system and subject to infrequent use shall be protected with a trap seal primer, except where not deemed necessary for safety or sanitation by the Authority Having Jurisdiction. Trap seal primers shall be accessible for maintenance. Floor drains and traps subject to evaporation due to infrequent use shall be protected with a water supplied trap seal primer, drainage supplied trap seal primer, or floor drain trap seal protection device. Water supplied trap seal primers shall be accessible for maintenance. I submitted a similar change the previous cycle. Unfortunately, the standard regulating floor drain trap seal protection deices was not completed at the time. This section needs strong language to emphasize that trap seal protection is required. This is not something that is left to someone s discretion. One of the key factors in preventing the escape of sewer gas is the protection of trap seals that are subject to evaporation. Numerous articles have been published identifying loss of floor drain trap seals as a possible cause of he spread of SARS. There are three types of protection methods for trap seals: one is a water supplied device, one connects to the drain, and one provides a barrier. All three of these trap seal protection devices are listed. Furthermore, all three are regulated by standards. Hence, it is appropriate to identify that any one of the three methods is acceptable for providing trap seal protection. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed standard is in draft form and is premature in that the standard has not been published. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Julius Ballanco, JB Engineering and Code Consulting PC/REP Sure-Seal Request to accept the code change proposal as submitted by this public comment. At the time of the Plumbing Technical Committee Meeting, ASSE 1072 had not yet been published as a standard. I requested that the code change be rejected since the standard was not available. The standard is now available and published by ASSE. Therefore, I would request that the change be approved as originally submitted. The justification in the original submittal provides the technical reason for acceptance. See substantiation above on proposal. (Standard(s) was provided for review) 123

124 Item # 147 Comment Seq # 66 UPC SUBMITTER: Sidney Cavanaugh Cavanaugh Consulting Revise text as follows: Grease Interceptors Where it is determined by the Authority Having Jurisdiction that waste pretreatment is required, an approved type of grease interceptor(s) complying with the provisions of this section shall be correctly sized and properly installed in grease waste line(s) leading from sinks and drains, such as floor drains and floor sinks and other fixtures or equipment in serving establishments such as restaurants, cafes, lunch counters, cafeterias, bars and clubs, hotels, hospitals, sanitariums, factory or school kitchens, or other establishments where grease may be introduced into the drainage or sewage system in quantities that can effect line stoppage or hinder sewage treatment or private sewage disposal. A combination of interior (hydromechanical) and exterior (gravity) grease interceptors shall be allowed in order to meet grease separation needs of the Authority Having Jurisdiction when space or existing physical constraints of existing buildings necessitate such installations. A grease interceptor shall not be required for individual dwelling units or for any private living quarters. Water closets, urinals, and other plumbing fixtures conveying human waste shall not drain into or through the grease interceptor. This code change recognized the need for combinations of grease interceptors for renovation projects involving existing buildings where there is insufficient space to install a large enough in-ground grease interceptor (gravity type) to meet local sewer ordinance requirements. While current code language needs a method for calculating overall separator capacity when multiple interceptors are installed, this is a move in the right direction and will helpfully open dialogue on the issue and, perhaps, generate a committee proposal or public comment to include a table for such sizing. Such as a weighing index for currently determining interior separator capacity versus the grease generating characteristics at the service point. The plumbing code currently ranks hydromechanical interceptors [mostly interior use] by a GPM rating and larger [mostly exterior] gravity interceptors by a capacity rating. A fixture grease discharge potential rating would seem to merge these into a workable table; for example, rotisserie oven [high grease discharge], wok range [moderately high grease discharge], and three-compartment pot washing sink [moderate grease discharge]. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION PUBLIC COMMENT 1: Submitter: Tim Collings, Chair (UPC FOG Task Group) The following is recommended by the FOG Task Group (see FOG Task Group Report Item #147) Request to accept the code change proposal as modified by this public comment Grease Interceptors Where it is determined by the Authority Having Jurisdiction that waste pretreatment is required, an approved type of grease interceptor(s) complying with the provisions of this section shall be correctly sized and properly installed in grease waste line(s) leading from sinks and drains, such as floor drains and floor sinks and other fixtures or equipment in serving establishments such as restaurants, cafes, lunch counters, cafeterias, bars and clubs, hotels, hospitals, sanitariums, factory or school kitchens, or 124

125 other establishments where grease may be introduced into the drainage or sewage system in quantities that can effect line stoppage or hinder sewage treatment or private sewage disposal. Any combination of interior (hydromechanical), and exterior (gravity) grease interceptors and engineered systems shall be allowed in order to meet this code and other applicable requirements grease separation needs of the Authority Having Jurisdiction, when space or existing physical constraints of existing buildings necessitate such installations. A grease interceptor shall not be required for individual dwelling units or for any private living quarters. Water closets, urinals, and other plumbing fixtures conveying human waste shall not drain into or through the grease interceptor. This code change recognizes the need for combinations of grease interceptors for renovation projects involving existing buildings where there is insufficient space to install a large enough in-ground grease interceptor (gravity type) to meet local sewer ordinance requirements. PUBLIC COMMENT 2: Submitter: Luke Ismert, Schier Products Request to accept the code change proposal as modified by this public comment Grease Interceptors Where it is determined by the Authority Having Jurisdiction that waste pretreatment is required, an approved type of grease interceptor(s) complying with the provisions of this section shall be correctly sized and properly installed in grease waste line(s) leading from sinks and drains, such as floor drains and floor sinks and other fixtures or equipment in serving establishments such as restaurants, cafes, lunch counters, cafeterias, bars and clubs, hotels, hospitals, sanitariums, factory or school kitchens, or other establishments where grease may be introduced into the drainage or sewage system in quantities that can effect line stoppage or hinder sewage treatment or private sewage disposal. A combination of interior (hydromechanical) and exterior (gravity) grease interceptors shall be allowed in order to meet grease separation needs of the Authority Having Jurisdiction when space or existing physical constraints of existing buildings necessitate such installations. A grease interceptor shall not be required for individual dwelling units or for any private living quarters. Water closets, urinals, and other plumbing fixtures conveying human waste shall not drain into or through the grease interceptor. It is inaccurate and confusing to those enforcing the code to equate hydro-mechanical to interior and gravity to exterior. Hydro-mechanical refers to units that incorporate a flow control device or orifice to assist in the separation of fats, oils, and grease. It does not refer to the location of the interceptor. Likewise, gravity refers to interceptors that employ a large liquid volume in lieu of a flow control device in separating fats, oils, and grease, and not to the physical location of the unit. The ASME A112 series of grease interceptor standards allows for interceptors of both designs to be certified at GPMs ranging from 4 through 100 GPM, and that can be installed indoors or outdoors. The terms interior and exterior are more accurate and intuitive. Further, gravity grease separation works the same way no matter where the interceptor is located. Item # 148 Comment Seq # 67 UPC 2009 Table 10-2, SUBMITTER: Rand Ackroyd Chair, UPC Fog Task Group The following is recommended by the FOG Task Group (see the Fog Task Group Report #148). 125

126 Item 1 Delete existing Table 10-2 and substitute as follows: Table 10-2 Hydro Mechanical Grease Interceptor (HGI) Sizing Chart* DFU HGI Flow (gpm) *Based on intermittent potentially full flow in drainage lines. Table 10-2 Hydro-mechanical Interceptor Sizing Using Gravity Flow Rates (1) (1) For interceptor sizing by fixture capacity see the example below. (2) ¼ (.240) slope per foot based on Manning s formula with friction factor N=.012 Item 2 Diameter of Grease Waste Pipe Add new sizing example as follows: Maximum Full PipeFlow (gpm) (2) Size of Grease Interceptor One-Minute Drainage Period (gpm) EXAMPLE FOR SIZING HYDROMECHANICAL INTERCEPTOR(S) USING FIXTURE CAPACITY Step 1: Determine the flow rate from each fixture. [Length] X [Width] X [Depth] / [231] = Gallons X [.75 fill factor] / [Drain Period (1 min or 2 min)] Step 2: Calculate the total load from all fixtures that discharge into the interceptor. Two-Minute Drainage Period (gpm) Fixtures Compartments Load (gallons) Size of Grease Interceptor One-Minute Drainage Two-Minute Drainage Period (gpm) Period (gpm) Compartment size 12 x 24 x Hydrant 3 Rated Appliance

127 Item 3 Revise text as follows: Each plumbing fixture or piece of equipment connected to a hydromechanical grease interceptor shall be provided with discharge into an approved type of vented flow control installed in a readily accessible and visible location. Flow control devices shall be designed and installed so that the total flow through such device or devices shall at no time be greater than the rated flow of the grease interceptor. No flow-control device having adjustable or removable parts shall be approved. The vented flow-control device shall be located such that no system vent shall be between the flowcontrol and the grease trap interceptor inlet. The vent or air inlet of the flow-control device shall connect with the sanitary drainage vent system, as elsewhere required by this code, or shall terminate through the roof of the building, and shall not terminate to the free atmosphere inside the building. Exception: Listed grease interceptors with integral flow controls or restricting devices shall be installed in an accessible location in accordance with the manufacturers instructions. Substantiation for Item 1 & 2 The actual flow in gpm per dfu is different for various fixtures. In existing Table 10-2, a dfu is equated at 2.5 gpm and another instance has a value of only 0.3 gpm. Performance standards for hydro-mechanical interceptors are based on actual peak gpm flow rate and not on average flow as compared to drainage fixture units. It is imperative that the code scientifically substantiate the result and removes any interpretive processes in sizing. The revision to Table 10-2 from dfu to gpm for sizing hydro-mechanical grease interceptors provides correlation with published consensus standards ASME A and PDI G101. The logical starting point is to base the size of the interceptor on the actual gallons per minute produced by the fixtures or, the size of the drainpipe leaving the establishment or the inlet of the interceptor. Without this revision to Table 10-2, current sizing methods permit undersized hydromechanical grease interceptors installed in various establishments. Substantiation for Item 3 The revision to Section provides a clarification that a vent flow control device is not required for each plumbing fixture but rather each fixture or equipment discharges into an approved type vented flow control device. This device is installed upstream from the interceptor that controls the rate of flow through the interceptor and a vent downstream, which allows air to be drawn into the flow stream and must be installed in accordance with the manufacturer s installation instructions thereby, negating the misconception. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Tim Collings, Chair (UPC FOG Task Group) The following is recommeded by the FOG Task Group (see FOG Task Group Report Item #148) 127

128 Request to accept the code change proposal as modified by this public comment. Item 1 Diameter of Grease Waste Pipe Table 10-2 Hydro-mechanical Interceptor Sizing Using Gravity Flow Rates (1) (1) For interceptor sizing by fixture capacity see the example below. (2) ¼ (.240) slope per foot based on Manning s formula with friction factor N=.012 Table 10-2 Hydro Mechanical Grease Interceptor (HGI) Sizing Chart * 1,2,3 DFU HGI Flow (gpm) *1 Based on intermittent potentially full flow in drainage lines. 2 When the total flow rate of directly connected fixture(s) or appliance(s) is known, the grease interceptor shall be sized based on the known flow rate. 3 When the DFUs or the actual total flow rate for a given installation are unknown, then the interceptor shall be sized based on the maximum DFU s allowable for the grease waste pipe size based on Table 7-5. Item 2 Maximum Full Pipe Flow (gpm) (2) Size of Grease Interceptor One-Minute Drainage Period (gpm) EXAMPLE FOR SIZING HYDROMECHANICAL INTERCEPTOR(S) USING FIXTURE CAPACITY Step 1: Determine the flow rate from each fixture. [Length] X [Width] X [Depth] / [231] = Gallons X [.75 fill factor] / [Drain Period (1 min or 2 min)] Step 2: Calculate the total load from all fixtures that discharge into the interceptor. Two-Minute Drainage Period (gpm) Fixtures Compartments Load (gallons) Size of Grease Interceptor One-Minute Drainage Two-Minute Drainage Period (gpm) Period (gpm) Compartment size 12 x 24 x Hydrant 3 Rated Appliance

129 Item 3 (Text remains unchanged) The FOG Task Group agreed that the existing Table 10-2 of the 2006 UPC is identical to proposed new Table 10-2 for fully loaded nominal size pipes at 2% slope that the deletion of fixture unit references and intermediate interceptor sizes did not compromise the intent of the section. Further, FOG Task Group agreed that the deletion of the intermediate sizes could create oversized interceptors and financial burden. The task group felt that it was necessary to include another sizing option in lieu of proposed Item 2 when the actual total flow rates of directly connected fixtures or appliances are known. Presently Table 10-2 does not address the issue of when the DFU s are unknown such as for a shell restaurant. The resulting option bases sizing on the maximum capacity of the waste pipe. PUBLIC COMMENT 2: Submitter: Richard Wagner, The Poole & Kent Corporation Request to reject the code change proposal by this public comment. The basis of both existing and proposed Tables 10-2 and the one-minute and two-minute drainage periods for hydro-mechanical grease interceptors is questioned. Item 148 proposes to replace Table 10-2 for sizing hydro-mechanical grease interceptors based on the connected drainage fixture units (DFU) with one based on the maximum full pipe flow rates for 2 through 6 drain pipes at 1/4 slope. The required interceptor sizes are based on either a one-minute or two - minute drainage period. First, the correlation of GPM to DFUs in existing Table 10-2 has no apparent basis. One (1) DFU is typically equated to 7.5 GPM without diversity. The diversity that is reflected in UPC Table 7-5 between connected DFUs and drainage pipe sizes does not necessarily apply to commercial kitchens, which have more time-dictated coincident peak load periods. Second, the scopes of ASME A and PDI G101 include grease interceptors only up to 100 GPM capacity. Grease interceptors of this size typically serve a limited number of fixtures, not an entire commercial kitchen. Third, ASME A and PDI G101 size hydro-mechanical grease interceptors based on a 75% full volume for a one-minute drainage period, or when conditions permit (???), a two-minute drainage period. Neither document indicates what conditions permit a two-minute drainage period. Logic says that the drainage period of a fixture depends on its relative volume with respect to its outlet drain size. the following are the results of a series of at-home tests one weekend: A 24 x 21 x 14 deep sink with 1-1/2 drain outlet drained in 2 minutes, 30 seconds from 75% full with its strainer basket removed. A 15 x 14 x 6 deep compartment of a two-compartment kitchen sink with 1-1/2 drain outlet drained in 25 seconds from 75% full. Neither drained in the ASME & PDI 1-minute or 2-minute periods. Both drained at rates of approximately 10 GPM. Two (2) lavatories with 1-1/4 drain outlets drained in 19 seconds from 75% full. Neither drained in the ASME & PDI 1-minute or 2-minute periods. Both drained at approximately 6 GPM. 129

130 FIXTURE DRAINAGE FLOW RATES FOR SIZING HYDRO-MECHANICAL AND GRD GREASE INTERCEPTORS FIXTURE FLOW 1-1/4 Sink Drain Outlet (each) 7.5 GPM 1-1/2 Sink Drain Outlet (each) 15 GPM 2 Sink Drain Outlet (each) 22.5 GPM Floor Drain without Indirect Waste 0 GPM Floor Drain or Floor Sink with Indirect Waste (1) Commercial Dishwasher (2) NOTES (1) The GPM drain load shall e the total indirect waste flow in GPM. (2) The GPM drain load for a commercial dishwasher shall be not less than the manufacturer s peak rate of drain flow with a full tank. Further support that the drainage GPM flow of a fixture is a function of its outlet pipe size is the following formula which can be found in Engineered Plumbing Design by Alfred Steele and Engineered Plumbing Design II published by ASPE: q= d 2 h 1/2 where q=rate of discharge, GPM d=diameter of outlet orifice, inches h=mean vertical height of water service above the outlet orifice, feet The two publications include the following explanation: The rate of flow in a fixture drain should be the same as the rate of flow discharged at the fixture outlet. The flow from the fixture outlet is comparable to flow from a water supply orifice discharging under flow pressure. For a fixture, the orifice can be taken as the minimum diameter of the waste outlet and the flow pressure is equivalent to the height of water above that minimum diameter. There is a decrease in the rate of flow from a fixture as the water level in the fixture decreases. The discharge time associated with this formula would be a function of the volume being drained, further indicating that there is no basis for the ASME & PDI one-minute and two-minute drainage periods. This formula produces higher flow rates than were indicated by the at home tests described above because the sinks tested had cross bars or other restrictions in their drain outlets. I suggest that the UPC FOG Task Group review their proposed sizing method for hydro-mechanical grease interceptors. Item # 150 Comment Seq # 68 UPC 2009 Table 10-2 SUBMITTER: Rand Ackroyd Rand Engineering Revise tables as follows: Delete existing Table 10-2 and substitute as follows: 130

131 Table 10-2 Hydro Mechanical Grease Interceptor (HGI) Sizing Chart* DFU HGI Flow (gpm) *Based on intermittent potentially full flow in drainage lines. Diameter of Grease Waste Pipe Table 10-2 Hydro-mechanical Interceptor Sizing Using Gravity Flow Rates (1) Maximum Full Pipe Flow (gpm) (2) Size of Grease Interceptor One-Minute Drainage Period (gpm) Two-Minute Drainage Period (gpm) (1) For interceptor sizing by fixture capacity see the example below. (2) ¼ (.240) slope per foot based on Manning s formula with friction factor N=.012 Item 2 Add new sizing example as follows: EXAMPLE FOR SIZING HYDROMECHANICAL INTERCEPTOR(S) USING FIXTURE CAPACITY Step 1: Determine the flow rate from each fixture. [Length] X [Width] X [Depth] / [231] = Gallons X [.75 fill factor] / [Drain Period (1 min or 2 min)] Step 2: Calculate the total load from all fixtures that discharge into the interceptor. Fixtures Compartments Load Size of Grease Interceptor (gallons) One-Minute Drainage Two-Minute Drainage Period (gpm) Period (gpm) Compartment size 12 x 24 x Hydrant 3 Rated Appliance

132 Substantiation for Item 1 & 2 The actual flow in gpm per dfu is different for various fixtures. In existing Table 10-2, a dfu is equated at 2.5 gpm and another instance has a value of only 0.3 gpm. Performance standards for hydro-mechanical interceptors are based on actual peak gpm flow rate and not on average flow as compared to drainage fixture units. It is imperative that the code scientifically substantiate the result and removes any interpretive processes in sizing. The revision to Table 10-2 from dfu to gpm for sizing hydro-mechanical grease interceptors provides correlation with published consensus standards ASME A and PDI G101. The logical starting point is to base the size of the interceptor on the actual gallons per minute produced by the fixtures or, the size of the drainpipe leaving the establishment or the inlet of the interceptor. Without this revision to Table 10-2, current sizing methods permit undersized hydromechanical grease interceptors installed in various establishments. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on submitters request. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Max Weiss, Weiss Research Request to accept the code change proposal as submitted by this public comment. As a member on all task groups, including the 11/29/07 group, commissioned to address inaccuracies, subjective methodologies, arithmetic inconsistencies and general lack of scientific merit of UPC Chapter 10 including Appendix H, I must oppose the FOG Task Group recommendation on the following grounds: 1. Lack of disparate demographic member representation; (see submitter s comment Item #148) 2. Lack of technical merit; (see submitter s comment Item #148) 3. ANSI Consensus Standard inconsistency; (see submitter s comment Item #148) 4. UPC Code inconsistency. (see submitter s comment Item #148) All resulting in a technically indefensible recommendation essentially regressing toward the morass from which, Chapter 10 is gradually emerging. The central issue is the most precise, consistent, objective and scientifically defensible method of quantifying flow from an establishment employing a grease interceptor for the purpose of pretreatment requirements compliance. The process of sizing an interceptor is simply quantifying the peak flow possible from a connected facility and selecting the interceptor capable of accommodating that flow. Peak flow quantification is necessary because a container, tank, etc., receiving a flow greater than its design velocity will result in scouring of the contents. The purpose of a grease interceptor is to prevent its contents from entering the collection system. 132

133 Grease interceptor design velocity [size] is determined one on two ways; in the instance of a gravity grease interceptor, it is the application of Stokes Law which descries the degree to which a particle of a given size, density and viscosity will separate from water of a given temperature, viscosity and velocity relative to time. The physical disparities of the particle and water and the incoming velocity determine the dimensions of a gravity interceptor necessary to effect a given degree of separation and retention. Accepted practice states the size of a gravity interceptor be sufficient to retain the flow for 30 minutes. The recommendation of the group contradicts the fundamental design principles of the product thereby compromising suitability of the device to the task. The contradiction is the result of subjective variations of the quantification of flow from the connected facility. Below are examples of inconsistent DFU values relative to GPM found in the Group s recommended Table gallon capacity w/ 30 min. retention = gpm 35 DFU/GPM = = gpm 172 DFU/GPM = = gpm 172 DFU/GPM = = gpm 172 DFU/GPM = = gpm 172 DFU/GPM =.29 Note in the Group recommended Table 10-2 the same DFU values equate to different GPM and different DFU/GPM values. The inconsistencies are not uniform in their variation relative to gpm; relative to Table 7.5 or any description of value anywhere in the code or other engineering reference. The variations are random throughout the table without rationalization or justification. Using either of the Group recommended Tables, it is not possible to accurately determine GPM flow. Therefore, not possible to know what to multiply X 30 [as indicated in the recommended footnote] Further, one facility will have a variety of flows depending upon what style interceptor is attached; what size interceptor is selected. Such result is not acceptable, credible or, useable. The Group rationale states in part, Sizing gravity grease interceptors in accordance with the submitted revision would result in less frequent maintenance and cleaning, and service difficulties, which results in hydrogen sulfide, odors, and corrosion. First, this goal is obtainable without throwing Chapter 10 back into disrepute. Second, results in concurrent diminishment of interceptor performance efficiency. Third could only pertain to Gravity Grease Interceptors. The Group recommendation is not scientifically valid, mathematically credible or, relevant. Item # 151 Comment Seq # 69 UPC , Table 10-3 SUBMITTER: Max Weiss Weiss Research Revise text as follows: Sizing Criteria Sizing. The volume of the interceptor shall be determined by using Table If drainage fixture units (DFUs) are not known, the interceptor shall be sized based on the maximum DFUs allowed for the pipe size connected to the inlet of the interceptor. Refer to Table 7-5, Drainage Piping, Horizontal. 133

134 Table 10-3 Gravity Grease Interceptor Sizing DFUs (1) Interceptor Volume (2) gallons 21 (3) 750 gallons 35 1,000 gallons 90 (3) 1,250 gallons 172 1,500 gallons 216 2,000 gallons 307 (3) 2,500 gallons 342 3,000 gallons 428 4,000 gallons 576 5,000 gallons 720 7,500 gallons ,000 gallons ,000 gallons Notes (1) The maximum allowable DFUs plumbed to the kitchen drain lines that will be connected to the grease interceptor. (2) This size is based on: the DFUs, the pipe size from this code; Table 7-5; Useful Tables for flow in half-full pipes (ref: Mohinder Nayyar Piping Handbook, 3rd Edition, 1992). (3) Based on 30-minute retention time (ref.: Metcalf & Eddy, Inc. Small and Decentralized Wastewater Management Systems, 3rd Ed. 1998). Rounded up to nominal interceptor volume. Gravity Grease Interceptor Sizing Example: Given: A restaurant with the following fixtures and equipment. One food preparation sink; three floor drains - one in the food prep area, one in the grill area, and one receiving the indirect waste from the ice machine; a mop sink; a dishwasher with a maximum discharge flow rate of 20 gpm discharging into a dedicated receptor; and two public restrooms, each with one water closet and one lavatory. Kitchen Drain Line DFU Count (from Table 7-3): 3 floor 2 DFUs each = 6 DFUs Mop 3 DFUs each = 3 DFUs Food prep 3 DFUs each = 3 DFUs 4 DFUs (Table 7-4) = 4 DFUs Total 16 DFUs Using Table 10-3, the grease interceptor will be sized at 750 gallons. TABLE 10-3 GRAVITY INTERCEPTOR SIZING DISCHARGE SIZING USING FIXTURE CAPACITY Calculation of fixture capacity: [Length} X [Width] X [Depth] / [231] = Gallons X [.75 fill factor] / [Drain Period (1 or 2)] Add hydrant capacity (gpm supply to faucet); Add rated appliances such as dishwasher, water wash hood at manufacturers ratings. EXAMPLE: Fixture Compartment Size Compartments Load,gal 24x24x Total hydrant supply and rated discharges Total Discharge The selection listed is based on application of the sizing formula above. 134

135 DISCHARGE SIZING USING PIPE SIZE & SLOPE Pipe Dia. Slope/Ft. (1) Full Pipe Flow (2) gpm gpm gpm gpm gpm (1) Inches drop per foot of run (Total vertical distance from atmospheric to invert of interceptor divided by length of pipe.) (2) Based on Mannings formula with friction factor N=.012; CAST IRON SOIL PIPE AND FITTINGS HANDBOOK; Ch 8, Flow Theory And Capacity; pp: [Full Pipe]; Cast iron Soil Pipe Institute (CISPI); 5959 Shallowford Road, Suite 419; Chattanooga, TN GRAVITY INTERCEPTOR SIZING Multiply the result of either Fixture Capacity or Pipe Size (above) by 30 to reflect required retention time (3). Ex gpm X 30 = 1,760 gal. capacity. (Using fixture content above to calculate maximum fixture capacity). Ex gpm X 30 = 1,760 gal. capacity. (Using 3 pipe slope to calculate maximum pipe capacity). (3) Based on 30 minute retention time (ref. Metcalf and Eddy Inc. 3rd Edition. Small and Decentralized Wastewater Management Systems 1998) Current sizing methods in this code for gravity and hydromechanical grease interceptors requires one facility to discharge different volumes at different velocities depending on the type of interceptor connected obviously an unintended consequence of calculating from the interceptor to the facility. Grease interceptors must be sized to peak flow calculation to avoid scouring contents and or creating conduit flow through the interceptor. Drainage Fixture Units (DFU) are not acceptable tools for sizing grease interceptors because DFU s are an averaging device based on intermittent flow estimations used to size drainage piping and do not provide a precise statement of maximum flow possible from a given facility. All facilities discharge at peak flow all they are capable of discharging or all the connected drain is capable of carrying. The type of interceptor connected does not alter the facility discharge. Peak facility discharge is measured in and expressed as gallons per minute (gpm) and liters per minute (l/pm). Gravity interceptors retain a given number of gallons for a given number of minutes; the gallons must be the peak demand from the facility. The minutes of retention are designated by the AHJ. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Based on committee action taken on Item 152 which clarifies the intent of the Table. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Tim Collings, Chair (UPC FOG Task Group) 135

136 The following is recommended by the FOG Task Group (see FOG Task Group Report for Item #151) Request to accept the code change proposal as modified by this public comment Sizing Criteria. Gravity Grease Interceptor Sizing Example: Given: A restaurant with the following fixtures and equipment. One (1) food preparation sink; three (3) floor drains - one (1) in the food prep area, one (1) in the grill area, and one (1) receiving the indirect waste from the ice machine; a mop sink; a dishwasher with a maximum discharge flow rate of twenty (20) gpm discharging into a dedicated receptor; and two (2) public restrooms, each with one water closet and one (1) lavatory. Kitchen Drain Line DFU Count (from Table 7-3): 3 floor 2 DFUs each = 6 DFUs Mop 3 DFUs each = 3 DFUs Food prep 3 DFUs each = 3 DFUs 4 DFUs (Table 7-4) = 4 DFUs Total 1216 DFUs Using Table 10-3, the grease interceptor will be sized at 750 gallons. This is an editorial change only to be consistent with Section Item # 152 Comment Seq # 70 UPC 2009 Table 10-3 SUBMITTER: Rand Ackroyd Rand Engineering Delete Table 10-3 and substitute as follows: TABLE 10-3 Gravity Grease Interceptor Sizing DFUs (1) Interceptor Volume (2) gallons 21 (3) 750 gallons 35 1,000 gallons 90 (3) 1,250 gallons 172 1,500 gallons 216 2,000 gallons 307 (3) 2,500 gallons 342 3,000 gallons 428 4,000 gallons 576 5,000 gallons 720 7,500 gallons ,000 gallons ,000 gallons Notes (1) The maximum allowable DFUs plumbed to the kitchen drain lines that will be connected to the grease interceptor. 136

137 (2) This size is based on: the DFUs, the pipe size from this code; Table 7-5; Useful Tables for flow in half-full pipes (ref: Mohinder Nayyar Piping Handbook, 3rd Edition, 1 (3) Based on 30 minute retention time (ref: Metcalf & Eddy, Inc. Small and Decentralized Wastewater Management Systems, 3rd Ed. 1998). Rounded up to nominal interceptor volume. TABLE 10-3 Gravity Interceptor Sizing Pipe Dia. (1) Full Pipe Flow (nominal) (2) Interceptor size based on 30 minute retention time. (3) Rounded up to the next nominal size gpm 750 gallons gpm 2000 gallons gpm 4000 gallons gpm 7500 gallons gpm gallons (1) For interceptor sizing by fixture capacity see the example below. (2) _ (.240)slope per foot based on Mannings formula with friction factor N=.012; CAST IRON SOIL PIPE AND FITTINGS HANDBOOK; Ch. 8, Fl ow Theory And Capacity; pp: [Full Pipe]; Cast Iron Soil Pipe Institute (CISPI); 5959 Shallowford Road, Suite 419; Chattanooga, Tn (3) Based on 30 minute retention time (ref.) Metcalf & Eddy, Inc. 3rd Ed. Small and Decentralized Wastewater Management Systems, 1998) and rounded up to nominal interceptor volume. GRAVITY INTERCEPTOR SIZING USING FIXTURE CAPACITY Calculation of fixture capacity: [Length] X [Width] X [Depth] / [231] = Gallons X [.75 fill factor] Add hydrant capacity (gpm supply); Add rated appliances such as dishwasher, water wash hood at manufactures ratings. Interceptor Sizing = fixture capacity x 30 EXAMPLE: Fixture Compartment Size, in. Compartments Load, gal Recommended Interceptor Size, Based on 30 minute retention time Rounded up to the next nominal size 24x24x gallons It was never the intent of a DFU in the Code to have a direct equivalent in GPM. The actual flow in GPM per DFU is different for different fixtures. In Table 10-3 a DFU is equated at 2.5 GPM in one instance and a DFU in another instance has a value of only 0.3 GPM! The GPM s associated with DFU s is different for the each size interceptor within the Table This is obviously a serious flaw in introducing DFU s into this table for sizing. All the performance standards for interceptor design and performance are based on actual peak GPM flow. DFU s are an average flow, not peak flows. It is imperative that the CODE be able to scientifically substantiate the result. The correction is simple, replace DFU s with actual peak GPM s for sizing. It is logical to simply base the size of the interceptor on the maximum gallons per 137

138 minute flow of the drain pipe leaving the establishment entering the inlet of the interceptor. A retention time of 30 minutes is widely recognized for sizing gravity interceptors. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION PUBLIC COMMENT 1: Submitter: Merrill Seiler, Orange County Sanitation District Request to reject the code change proposal by this public comment. The Orange County Sanitation District (OCSD) appreciates the work of the FOG Task Group and supports the code change recommendations produced during the November 29, 2007 meeting. In particular, OCSD supports the rejection of Item 152 which proposed to significantly alter the gravity grease interceptor sizing schedule currently found in Table 10-3 of the 2006 UPC. The OCSD fully supports the Table 10-3 standards adopted in the 2006 UPC and the recommended addition of the 300 gallon volume to the existing table schedule. It is OCSD s opinion that acceptance of Item 152 as proposed would have placed excessive economic burden on food service establishments by significantly increasing gravity grease interceptor sizes unnecessarily. Based upon my grease interceptor inspection experience, I ve concluded that prior interceptor sizing formulas tended to produce oversized installations that often create septic conditions which will lead to acidic conditions and/or hydrogen sulfide buildup. Table 10-3 in the 2006 UPC addressed the issue by eliminating extraneous factors from the sizing equation that tended to inflate the calculated volume. Item 152 s proposed change based upon full pipe flow, while well intentioned to assure 30 minute retention under every conceivable condition, would revert back to the oversized installation problem. So far, the application of Table 10-3 in the 2006 UPC appears to be providing economical, as well as functional sizes. PUBLIC COMMENT 2: Submitter: Luke Ismertm, Schier Products Request to accept the code change proposal as modified by this public comment. Pipe Dia. (1) Full Pipe Flow (nominal) (2) TABLE 10-3 Gravity Interceptor Sizing Interceptor size based on 30 minute retention time. (3) Rounded up to the next nominal size (listed units may be sized using grease capacity) gpm 750 gallons or listed minimum of 500 lbs. grease capacity gpm 2,000 gallons or listed minimum of 750 lbs. of grease capacity gpm 4,000 gallons or listed minimum of 1,000 lbs. of grease capacity gpm 7,500 gallons or listed minimum of 2,000 lbs. of grease capacity gpm 15,000 gallons or listed minimum of 4,000 lbs. of grease capacity. 138

139 Exception: Listed Gravity Grease Interceptors may be sized by liquid gallons or their listed grease capacity. When sizing by listed grease capacity, the interceptor s listed grease capacity must be 3rd party certified. To achieve viable interceptor pumping schedule, 500 lbs. is the minimum acceptable listed grease capacity. (1) For interceptor sizing by fixture capacity see the example below. (2) _ (.240) slope per foot based on Mannings formula with friction factor N=.012; CAST IRON SOIL PIPE AND FITTINGS HANDBOOK; Ch. 8, Flow Theory And Capacity; pp: [Full Pipe]; Cast Iron Soil Pipe Institute (CISPI); 5959 Shallowford Road, Suite 419; Chattanooga, Tn (3) Based on 30 minute retention time (ref.) Metcalf & Eddy, Inc. 3rd Ed. Small and Decentralized Wastewater Management Systems, 1998) and rounded up to nominal interceptor volume. GRAVITY INTERCEPTOR SIZING USING FIXTURE CAPACITY Calculation of fixture capacity: [Length] X [Width] X [Depth] / [231] = Gallons X [.75 fill factor] Add hydrant capacity (gpm supply); Add rated appliances such as dishwasher, water wash hood at manufactures ratings. Interceptor Sizing = fixture capacity x 30 EXAMPLE: Fixture Compartment Size, in. Compartments Load, gal Recommended Interceptor Size, Based on 30 minute retention time Rounded up to the next nominal size 24 x 24 x ,500 gallons Problem: Current table does not allow for the use of properly listed and certified gravity grease interceptors that offer large grease capacities, but do not meet minimum gallon requirements. Solution: Incorporate grease capacity equivalents into the table as an alternate sizing method for listed gravity grease interceptors. Additionally, insert Exception paragraph below the table explaining when and how the grease capacity equivalents may be used. Discussion/Substantiation: We must begin the move towards measuring gravity grease interceptors in terms of flow rate and grease capacity, instead of indicator metrics like liquid holding capacity and retention time. We have a standard that these units can be tested to, and the UPC code calls for all interceptors, regardless of size or location, to be listed yet we re not enforcing it. We cannot let another code cycle be completed without working towards incorporating this common sense metric. Reasons include: 1. Liquid Holding Capacity can be a misleading indicator of grease capacity. There is not a direct correlation between liquid volume and grease capacity. This is evidenced by the many examples of huge interceptors short circuiting and having very poor grease capacities. Conversely, there are relatively small gravity interceptors that achieve huge grease capacities. For example, Schier s GB-250 is certified by NSF to the ASME A standard at 100 GPM, and listed by IAPMO 1. At that flow rate it achieved 93% efficiency and held an astounding 1,076 lbs grease capacity. This product out-performs traditional baffle-style interceptors 4 to 5 times its size, but is not allowed per the table above due to the liquid holding capacity requirement. 2. Retention time can be a misleading indicator of grease capacity. Interceptor volumes are currently calculated based on 30-minute retention time. This makes the hasty assumption that influent is perfectly distributed once it enters the unit, and stays inside the interceptor for its calculated retention period. In 139

140 reality, most gravity grease interceptors have been constructed with little or no thought given to the flow pattern that occurs inside the interceptor, and the result is often short-circuiting and poor grease retention. Evidence that flow pattern is a huge factor is found WERF s lasted update on the F.R.O.G. project 2, in which they achieved significant differences in grease retention when baffle placement was varied. Further, removing the baffles entirely resulted in one of the best performing units! More evidence that flow pattern is important is seen again with Schier s GB-250. It s huge grease capacity was achieved with only a 2.5 minute retention time (100 GPM, 250 gallons capacity). 3. The UPC code requires a listed unit. The UPC requires all grease interceptors, regardless of size or location, to be listed. (Chapter 14, Referenced Standards, UPC 2003 UPC). 4. We are already set up to test and list gravity grease interceptors. The ASME A type C 3 standard allows gravity grease interceptors (no air intake vent or external flow control) to be testd at flow rates up to 100 GPM and nearly unlimited grease capacities 3. For instance, there is no reason why a concrete outdoor interceptor couldn t be tested and certified at 100 GPM, which would give it a listed grease capacity. We would no longer need to guess at grease capacity by requiring certain liquid holding capacities or retention times. In the near future, this standard can surly be expanded to include greater flow rates, but until then, multiple 100 GPM units can be piped in parallel (not in series) to achieve the required flow rates. Piping relatively smaller units in parallel is certainly more viable than requiring massive, un-pump-able grease interceptors just satisfy a rule-of-thumb minimum liquid holding capacity. 5. Current requirements stifle innovation. Basing size around liquid holding capacity is the same as dictating how to build an interceptor this all but kills innovation. After all, the whole point of a grease interceptor is to efficiently separate grease. Car manufacturers are held to a fuel efficiency standard, not told how to build their engines. Proof that innovation has been slowed is that we are still using box with baffle designs circa If grease capacity was used as the main metric, innovative designs could be allowed to compete in the marketplace. 6. Listed Units make code enforcement easier. Due to confusing language and ever-changing requirements, engineers, contractors, and code officials are in a state of confusion. Moving to a simple system that required all units to be listed and to have minimum grease capacities at certain flow rates would end much of the confusion. The discussion could move to more important topics like cleaning frequency, Kitchen Best Management Practices, etc. 7. Current requirements make concrete the most often used material. Requiring large interceptors all but ensures they will be made from concrete (it s inexpensive). Concrete, while great for certain uses, is a terrible material to use in the construction of grease interceptors, as it corrodes when in contact with FOG and many other chemicals found in commercial kitchen wastewater 4. These interceptors are not only expensive to install initially, but even more expensive to replace. Even coated units eventually fail if the coating is scratched or otherwise penetrated. In spite of all of these reasons, we realize that we cannot make an overnight move to grease capacity requirement, which is why we have proposed simply adding the grease capacity equivalents as an alternative sizing method for listed gravity grease interceptors. IAPMO s proven code review process will help perfect minimum grease capacities over time. 1NSF Test Report for Schier GB-250 furnished upon request 2FROG Project report provided upon request, or attainable via NC State University s Dr. Joel DuCoste 3Reference ASME A Reference Portland Cement Association Effects of Substances on Concrete and Guide to Protective Treatments PUBLIC COMMENT 3: Submitter: Tim Collings, Chair (UPC FOG Task Group) 140

141 The following is recommended by FOG Task Group (see Task Group Report for Item #152) Request to accept the code change proposal as modified by this public comment. (1) For interceptor sizing by fixture capacity see the example below. (2) _ (.240)slope per foot based on Mannings formula with friction factor N=.012; CAST IRON SOIL PIPE AND FITTINGS HANDBOOK; Ch. 8, Flow Theory And Capacity; pp: [Full Pipe]; Cast Iron Soil Pipe Institute (CISPI); 5959 Shallowford Road, Suite 419; Chattanooga, Tn (3) Based on 30 minute retention time (ref.) Metcalf & Eddy, Inc. 3rd Ed. Small and Decentralized Wastewater Management Systems, 1998) and rounded up to nominal interceptor volume. GRAVITY INTERCEPTOR SIZING USING FIXTURE CAPACITY Calculation of fixture capacity: [Length] X [Width] X [Depth] / [231] = Gallons X [.75 fill factor] Add hydrant capacity (gpm supply); Add rated appliances such as dishwasher, water wash hood at manufactures ratings. Interceptor Sizing = fixture capacity x 30 EXAMPLE: TABLE 10-3 Gravity Interceptor Sizing Pipe Dia. (1) Full Pipe Flow (nominal) (2) Interceptor size based on 30 minute retention time. (3) Rounded up to the next nominal size gpm 750 gallons gpm 2,000 gallons gpm 4,000 gallons 5.75 gpm 7,500 gallons gpm 15,000 gallons Fixture Compartment Size, in. Compartments Load,gal Recommended Interceptor Size, Based on 30 minute retention time Rounded up to the next nominal size 24x24x gallons TABLE 10-3 Gravity Interceptor Sizing DFUs (1),(4) Interceptor Volume (2),(3) gallons gallons 35 1,000 gallons 90 1,250 gallons 172 1,500 gallons 216 2,000 gallons 307 2,500 gallons 342 3,000 gallons 428 4,000 gallons 576 5,000 gallons 720 7,500 gallons ,000 gallons ,000 gallons 141

142 Notes (1) The maximum allowable DFUs plumbed to the kitchen drain lines that will be connected to the grease interceptor. (2) This size is based on: the DFUs, the pipe size from this code; Table 7-5; Useful Tables for flow in half-full pipes (ref: Mohinder Nayyar Piping Handbook, 3rd Edition, 1 (3) Based on 30 minute retention time (ref: Metcalf & Eddy, Inc. Small and Decentralized Wastewater Management Systems, 3rd Ed. 1998). Rounded up to nominal interceptor volume. (4) When the flow rate of directly connected fixture(s) or appliance(s) have no assigned DFU values, the additional grease interceptor volume shall be sized based on the known flow rate (gpm) multiplied by 30 minutes. Gravity Grease Interceptor Sizing Example: Given: A restaurant with the following fixtures and equipment. One (1) food preparation sink; three (3) floor drains - one (1) in the food prep area, one (1) in the grill area, and one (1) receiving the indirect waste from the ice machine; a mop sink; a dishwasher with a maximum discharge flow rate of twenty (20) gpm discharging into a dedicated receptor; and two (2) public restrooms, each with one (1) water closet and one (1) lavatory. Kitchen Drain Line DFU Count (from Table 7-3): 3 floordrains@2dfuseach= 6DFUs Mop sink@3dfuseach= 3DFUs Food prep DFUs each = 3 DFUs 4 DFUs (Table 7-4) = 4 DFUs Total 1216 DFUs Using Table 10-3, the grease inceptor will be sized at 750 gallons. Table 10-3 for Gravity grease interceptors was never addressed by the previous FOG task group of July Sizing gravity grease interceptors in accordance with the submitted revision would result in less frequent maintenance and cleaning, and service difficulties, which results in hydrogen sulfide, odors, and corrosion. Testimony submitted from California sewer agencies indicated that reasonably sized interceptors stimulates more frequent maintenance and mitigates hydrogen sulfide, odors and corrosion concerns. Testimony was also provided that Table 10-3 of the 2006 UPC is being utilized successfully. Also, the code acknowledges the minimum interceptor size of 300 gallons so the table should be revised to be consistent. The deletion of footnote 3 reference in column 1 of 10-3, and adding it to the header of column 2 is needed to correct a clerical error. The task group felt that footnote 4 was necessary to include a sizing option when the flow rates of directly connected fixtures or appliances are known. This is an editorial change only to be consistent with Section

143 Item # 153 Comment Seq # 71 UPC SUBMITTER: Max Weiss Weiss Research Revise text as follows: Hydromechanical Grease Interceptors Each All plumbing fixtures or piece of equipment connected to a hydromechanical grease interceptor shall be provided with discharge through an approved type of vented flow control installed in a readily accessible and visible location. Flow control devices shall be designed and installed so that the total flow through such device or devices shall at no time be greater than the rated flow of the connected grease interceptor. No flow-control device having adjustable or removable parts shall be approved. The vented flow-control device shall be located such that no system vent shall be between the flow control and the grease trap inlet. The vent or air inlet of the flow-control device shall connect with the sanitary drainage vent system, as elsewhere required by this code, or shall terminate through the roof of the building, and shall not terminate to the free atmosphere inside the building. Exception: Listed grease interceptors with integral flow controls or restricting devices shall be installed in an accessible location in accordance with the manufacturers instructions. As currently worded each fixture would be required to have a separate flow control dedicated to that fixture. That was not the TG intent. The intent was to ensure all connected fixtures discharged through the flow control and the aggregate flow did not exceed the rating of the interceptor. Originally discussed in the assigned Task Group. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Tim Collings, Chair (FOG Task Group) The following is recommended by the FOG Task Group (see FOG Task Group Report for Item #153) Request to accept the code change proposal as modified by this public comment Hydromechanical Grease Interceptors All plumbing fixtures or equipment connected to a Type A and B hydromechanical grease interceptor shall discharge through an approved type of vented flow control installed in a readily accessible and visible location. Flow control devices shall be designed and installed so that the total flow through such device or devices shall at no time be greater than the rated flow of the connected grease interceptor. No flow-control device having adjustable or removable parts shall be approved. The vented flow-control device shall be located such that no system vent shall be between the flow control and the grease trap interceptor inlet. The vent or air inlet of the flow-control device shall connect with the sanitary drainage vent system, as elsewhere required by this code, or shall terminate through the roof of the building, and shall not terminate to the free atmosphere inside the building. 143

144 Exception: Listed grease interceptors with integral flow controls or restricting devices shall be installed in an accessible location in accordance with the manufacturers instructions. The FOG Task Group supports the TC action. However, additional modifications are necessary to address the fact that ASME A also covers Type C and D which do not require external flow control devices. The remaining changes are editorial. Item # 157 Comment Seq # 72 UPC (New), Table 14-1 SUBMITTER: Robert Evans American Society of Plumbing Engineers Add new text as follows: Siphonic Roof Drainage System. A siphonic roof drainage system shall be designed in accordance with ASPE 45. MANDATORY REFERENCED STANDARDS TABLE 14-1 Standards for Materials, Equipment, Joints, and Connections. Where more than one standard has been listed for the same material or method, the relevant portions of all such standards shall apply. Standard Number Standard Title Application ASPE Siphonic Roof Drainage System Design Manual (Note: Standard not included with proposal) ASPE has published a new standard for siphonic roof drainage systems. This standard provides the design criteria that must be followed for the proper operation of a siphonic roof drainage system. By referencing this new standard, the Authority Having Jurisdiction will understand which standard to follow when evaluating a siphonic roof drainage system. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: K. Anthony Wilcocksom, City of Walnut Creek Requests to reject the code change proposal by this public comment. Not a proven system; still in development states and the standard was not provided for review. This is an engineered system and does not belong in the text of the code.the code proposal fails to provide prescriptive installation standards. ASPE 45 is just a design manual and does not provide prescriptive installation standards. 144

145 Item # 161 Comment Seq # 73 UPC SUBMITTER: Ted Lemoff, NFPA Revise text as follows: Gas-Piping System Any arrangement of gas piping supplied by one (1) meter or pressure regulator, and each arrangement of gas piping serving a building, structure, or premises, whether individually metered or not. The current definition excludes most systems where propane is the fuel, as they do not have a meter. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed text is confusing and would not add clarity to existing text. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment Gas-Piping System Any arrangement of gas piping supplied by one (1) meter and each arrangement of gas piping serving a building, structure, or premises, whether individually metered or not. I submitted a proposal (#161) to revise , which was rejected. I note that appears to restate the scope of Chapter 12, (A), and is not needed. Therefore, request deletion of text. If the committee believes that this section is crucial then accept as submitted is preferred. Item # 166 Comment Seq # 74 UPC SUBMITTER: Bryan Popp Dormont Manufacturing Company Delete text without substitution: Excess Flow Valve. When automatic excess flow gas shutoff devices (valves) are used, they shall be listed and approved and shall be sized for the maximum flow anticipated for the main or branch of the fuel gas system in which the excess flow valve is installed. 145

146 There is no consensus standard to which these devices are listed. There are complex and potentially dangerous issues associated with recognizing and allowing these nonstandard devices in the fuel piping system. These issues include but are not limited to: a misperception that the excess flow valve closes or shuts-off the flow of gas; nuisance trips associated with flow surges and improper installation; many current designs can be installed backwards; failure to trip without adequate pressure drop; no consensus standard for design certification for intended temperature range and no consensus standard for durability. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: Section 1210 requires listing and proper sizing, which are key elements for excess flow valves, therefore text should not be deleted. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment Excess Flow Valve. When Where automatic excess flow gas shutoff devices (valves) are installed used, they shall be listed and approved for the application and shall be sized for the maximum flow anticipated for the main or branch of the fuel gas system in which the excess flow valve is and installed in accordance with the manufacturer instructions. This comment proposed new text that was added to the 2008 edition of NFPA 54, and is similar to text accepted for the UMC. The revisions recognize that there are many excess flow valves that are listed but intended for different applications that would not provide safety in fuel gas piping systems; and redundant text is deleted. Item # Comment Seq # 75 UPC SUBMITTER: UPC Technical Committee Proposal Delete text and replace as follows: Tubing in Partitions. This provision shall not apply to tubing that pierces walls, floors, or partitions or to tubing installed vertically and horizontally inside hollow walls or partitions without protection along its entire concealed length where both of the following requirements are met: [NFPA 54: 7.3.4] (1) A steel striker barrier not less than inches (1.3 mm) thick, or equivalent, is installed between the tubing and the finished wall and extends at least 4 inches (100 mm) beyond concealed penetrations of plates, fire stops, wall studs, and so on. (2)The tubing is installed in single runs and is not rigidly secured. 146

147 Tubing in Partitions. This provision shall not apply to tubing that pierces walls, floors, or partitions. Tubing installed vertically and horizontally inside hollow walls or partitions without protection along its entire concealed length shall meet the following requirements be installed in accordance with through Tubing shall only be installed horizontally or vertically A steel striker barrier not less than in. (1.3 mm) thick, or equivalent, shall be installed between the tubing and the finished wall and shall extend at least 4 in. (100 mm) beyond concealed penetrations of plates, fire stops, wall studs, and similar construction features The tubing shall be installed in single runs and shall not be rigidly secured Where the wall or partition contains batt-type insulation the insulation shall not restrict the movement of the tubing. [NFPA 54:7.3.4] Section prohibits the installation of tubing in partitions that contain insulation (must be hollow). Soft type of insulation would not necessary restrict the movement of tubing (in the event of a nail penetration). COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to reject the code change proposal by this public comment. This comment proposes rejection of proposal ; which was rejected and will not appear in the 2008 edition of NFPA 54, and will retain the requirement that tubing be installed only in hollow walls and partitions. Item # Comment Seq # 76 UPC SUBMITTER: UPC Technical Committee Proposal Revise text as follows: Electrical Bonding and Grounding. (A) Each aboveground portion of a gas piping system that is likely to become energized shall be electrically continuous and bonded to an effective ground-fault current path. Gas piping shall be considered to be bonded when it is connected to gas utilization equipment appliances that are connected to the equipment appliance grounding conductor of the circuit supplying that equipment appliance CSST Gas piping systems shall be bonded to the electrical service grounding electrode system at the point where the gas service enters the building. The bonding jumper shall not be smaller than 6 AWG copper wire. [NFPA 54:7.13.1] (B)

148 Gas piping systems installed inside buildings have demonstrated a propensity to become energized from nearby lightning strikes. Conventional bonding of gas piping through the equipment grounding conductor (NFGC and NEC (B)) has proven inadequate (in these circumstances) to prevent arcing between the gas piping and other nearby electrically conductive systems. CSST manufacturers collectively report dozens of damaged systems caused by improper or inadequate bonding resulting in fire damage or loss of property. Therefore, modifications are proposed to this section to allow alternative methods for direct bonding of gas piping to the grounding system to insure a minimum threshold of protection from all threats (including indirect lightning strikes) that are likely to energize the piping. Current bonding of gas piping to the equipment-grounding conductor will continue to be permitted. Similar language has been submitted to the NEC (National Electrical Code) for the 2008 cycle. Evidence presented to the committee indicates that CSST systems have been damaged by arcing. The proposed text is consistent with CSST systems manufacturers recommendations. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff Request to accept the code change proposal as modified by this public comment Electrical Bonding and Grounding Pipe and Tubing other than CSST. Each above ground portion of a gas piping system other than CSST that is likely to become energized shall be electrically continuous and bonded to an effective ground-fault current path. Gas piping, other than CSST shall be considered to be bonded when it is connected to appliances that are connected to the appliance grounding conductor of the circuit supplying that appliance. [NFPA 54: ] CSST gas piping systems shall be bonded to the electrical service grounding electrode system at the point where the gas service enters the building. The bonding jumper shall be not smaller than 6 AWG copper wire. [NFPA 54:7.13.1] Gas piping shall not be used as a grounding conductor or electrode. This does not preclude the bonding of metallic piping to a grounding system. [NFPA 54: ] Where a lightning protection system is installed, the bonding of the gas piping system shall be in accordance with NFPA 780. This comment recommends revisions that were made to text extracted from NFPA 54 that was revised in the 2008 edition. The revision to (B) clarifies that the requirement is not intended to prohibit bonding of metallic piping system. New paragraph clarifies that a lighting protection system, where installed, is covered by a separate code, NFPA 780, Item # Comment Seq # 77 UPC SUBMITTER: UPC Technical Committee Proposal Revise text as follows: 148

149 Connecting Gas Equipment. (6) Gas-fired food service (commercial cooking) equipment listed for use with casters or otherwise subject to movement for cleaning, and other large and heavy gas utilization equipment that can be moved, shall be connected in accordance with the connector manufacturer s installation instructions using a listed appliance connector complying with ANSI Z21.69, Standard for Connectors for Movable Gas Appliances. The building gas supply branch connection for commercial cooking appliances shall be oriented as follows: The building gas supply branch connection shall be oriented vertically downward. The bottom of the building gas supply branch connection shall be located not less than 36 in. (914 mm) and not more than 42 in. (1067 mm) above the floor. The building gas supply branch connection shall be directly behind the appliance it serves and not obstructed by any other appliance or equipment. The connector shall be installed and oriented in accordance with the connector manufacturer s installation instructions. [NFPA 54: ] This additional language increases safety by reducing the risk of fugitive gas, potential fires and subsequent losses in commercial kitchens. Specific safety improvements include: Reducing dangerous strain on improperly installed Connectors for Movable Gas Appliances. Standardizes the configuration of building gas supply manifolds in commercial kitchens so that designers, installers, code officials and users have consistent and safe building gas supply manifolds in commercial kitchens. Increases the likelihood that the connector manufacturer s installation and use instructions will be followed. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment Connecting Gas Equipment. (6) Gas-fired food service (commercial cooking) equipment listed for use with casters or otherwise subject to movement for cleaning, and other large and heavy gas utilization equipment that can be moved, shall be connected in accordance with the connector manufacturer s installation instructions using a listed appliance connector complying with ANSI Z21.69, Standard for Connectors for Movable Gas Appliances. The commercial cooking appliance connector installation shall be configured in accordance with the manufacturer s installation instructions. (NFPA 54: ) The building gas supply branch connection for commercial cooking appliances shall be oriented as follows: The building gas supply branch connection shall be oriented vertically downward. The bottom of the building gas supply branch connection shall be located not less than 36 in. (914 mm) and not more than 42 in. (1067 mm) above the floor. The building gas supply branch connection shall be directly behind the appliance it serves and not obstructed by any other appliance or equipment. The connector shall be installed and oriented in accordance with the connector manufacturer s installation instructions. [NFPA 54: ] 149

150 In the ROP, was modified by adding very specific requirements for the installation of gas connectors for commercial cooking appliances to remain consistent with an identical change to NFPA 54. This text was found to be potentially restrictive for some connectors, which was not the intent. The proposed further revisions retain the concerns for proper installation of commercial cooking appliance connectors, gut the text is revised to only reference the connector manufacturer s installation instructions so as not to unintentionally prohibit any connectors that are listed. Item # Comment Seq # 78 UPC SUBMITTER: UPC Technical Committee Proposal Add new text as follows: Suspended Low-Intensity Infrared Tube Heaters. Suspended low-intensity infrared tube heaters shall not be connected to the building piping system with rigid pipe or semi-rigid metallic tubing. [NFPA 54: ] Renumber remaining text. In the past several years, gas leakage from fractured copper tubing has caused multiple major incidents. The cause was traced to the use of copper tubing as a gas connector on tube heaters, which are not secure to the structure. The new paragraph recognizes these failures of copper pipe and tubing in this service. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed text is overly restrictive and prohibits other applications. A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA David Delaquila, Air-Conditioning, Heating and Refrigeration Institute Request to accept the code change proposal as modified by this public comment Suspended Low-Intensity Infrared Tube Heaters. Suspended low-intensity infrared tube heaters shall not be connected to the building piping system with rigid pipe or semi-rigid metallic tubing. [NFPA 54: ] a connector listed for the application in accordance with ANSI Z21.24/CGA 6.10, Connectors for Gas Appliances. (A) The connector shall be installed in accordance with the tube heater installation instructions, and shall be in the same room as the appliance. (B) Only one connector shall be used per appliance. 150

151 SUBSTANTIATION (Ted Lemoff): This comment recommend reversal of the action of proposal , with further revisions that are incorporated in the 2008 edition of NFPA 54. The new requirement for the installation of radiant tube heaters provides specific requirements for the connector to assist installers and code officials. There have been several accidents caused by failure of copper tubing due to cold working. This will require other materials, and now provides reference specifications for appropriate connectors in this service. SUBSTANTIATION (David Delaquila): This is currently accepted proposed language to revise the National Fuel Gas Code, ANSI Z223/NFPA The Standard for Connectors for Gas Appliances, ANSI Z21.24/CGA 6.10, has been revised to add construction and performance requirements to address applications such as these. Item # Comment Seq # 79 UPC SUBMITTER: UPC Technical Committee Proposal Add new text as follows: Where installed at a manifold, the appliance shutoff valve shall be located within 50 ft (15 m) of the appliance served, measured in a straight line, and shall be readily accessible and permanently identified. The piping from the manifold to within 6 ft of the appliance shall be designed, sized and installed in accordance with Chapter 12 [NFPA 54: ] (Renumber remaining text) The change adds a paragraph extracted from NFPA 54 and clarifies the committee s intent on how to measure the distance. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT 1: Submitter: Ted Lemoff, NFPA Request to accept the code change proposal as modified by this public comment Where installed at a manifold, the appliance shutoff valve shall be located within 50 ft (15 m) of the appliance served, measured in a straight line, and shall be readily accessible and permanently identified. The piping from the manifold to within 6 ft of the appliance shall be designed, sized and installed in accordance with Chapter 12. [NFPA 54: ] This comment proposes a revision consistent with NFPA The paragraph was revised to clarify the intent. 151

152 PUBLIC COMMENT 2: Submitter: Bryan Popp, Dormont Manufacturing Company Steven Silber, Director of Training Local 342 RECOMMENDATION (Assembly Action): Request to reject the code change proposal by this public comment. SUBSTANTIATION (Bryan Popp): Negative comments from the committee raised very valid concerns. Additionally, permitting the shutoff valve very remote from the appliance will encourage users of Excess Flow Valves and Quick Disconnects to rely on these devices as the shut off valve during disconnecting service of the appliance. Excess Flow valves when closed as defined and permitted by the 2006 language of the UPC will permit up to 10 SCFH of fuel gas into the room where the appliance is disconnected. SUBSTANTIATION (Stephen Silber): A gas shut-off valve located up to 50 feet from the appliance being served may have a fatal out come. In a situation where a leak may occur this would lead to confusion as to where to shut off the gas and present code language is preferred. In order to correlate the UMC rejected this code change, therefore this proposal should be rejected. Item # Comment Seq # 80 UPC SUBMITTER: UPC Technical Committee Proposal Add new text as follows: Shutoff valves serving appliances installed in vented fireplaces and ventless firebox enclosures shall not be required to be located within 6 ft (1.8 m) of the appliance where such valves are readily accessible and permanently identified. The piping from the shutoff valve to within 6 ft (1.8 m) of the appliance shall be designed, sized and installed in accordance with Chapter 12. (Renumber remaining text) The proposed paragraphs were added to the 2006 edition of NFPA 54, but were not included in the UPC. They are proposed here, with a revision (shown underlined) from the NFPA ROP based on reports of the text being misinterpreted to exclude compliance with other provisions of Chapter 12. The revised text addresses these issues. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT (Assembly Action): Submitter: Stephen Silber, Director of Training Local

153 Request to reject the code change proposal by this public comment. Reason; The problem with the new text is that it proposes a safety hazard and similar to the reasoning to Item Current language is preferred and restrictions should be maintained. Item # 174 Comment Seq # 81 UPC SUBMITTER: Robert Torbin Cutting Edge Solutions LLC Revise text as follows: For conditions other than those covered by Section , such as longer runs or greater gas demands, the size of each gas piping system shall be determined by standard engineering methods acceptable to the Authority Having Jurisdiction, and each such system shall be so designed that the total pressure drop between the meter or other point of supply and any outlet when full demand is being supplied to all outlets, will at no time exceed five tenths (0.5) inches (12.7 mm) water column pressure shall comply with the requirements of Section The proposed change will make the selection of the maximum pressure drop consistent within the code and with the National Fuel Gas Code. Currently, there is a conflict within the code between Section and Section and Section regarding allowable pressure drop. COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: Submitter: Ted Lemoff, NFPA Requests to accept the code change proposal as modified by this public comment Table for Sizing Gas-Piping Systems. Tables through shall be used to size gas piping in conjunction with one of the methods described in Sections through [NFPA 54:6.3] For conditions other than those covered by Section , such as longer runs or greater gas demands, the size of each gas piping system shall be determined by standard engineering methods acceptable to the Authority Having Jurisdiction, and each such system shall be so designed that the total pressure drop between the meter or other point of supply and any outlet when full demand is being supplied to all outlets, shall comply with the requirements of Section The following regulations, as set forth in this section and in Section , Required Gas Piping Size, shall be the standard for the installation of gas piping. All natural gas regulations and tables are 153

154 based on the use of gas having a specific gravity of sixty hundredths (0.60), supplied at six (6) to eight (8) inches ( mm) water column pressure at the outlet of the meter or regulator. For undiluted liquefied petroleum gas, gas piping may be sized at eleven (11) inches (279 mm) water column pressure at the outlet of the meter or regulator and specific gravity of one and fifty hundredths (1.50). Delete Table 12-7, and replace with Table 12-8 for Table 12-7 throughout Chapter