Cincinnati Hearings Spur IPC Changes

A number of changes to the International Plumbing Code were approved at the International Code Council (ICC) hearings, held at the end of February and the beginning of March in Cincinnati. These changes addressed issues in several areas of plumbing-system design.

By Ron George, CIPE, CPD, President, Ron George Design & Consulting Services, Newport, Mich. May 1, 2005

A number of changes to the International Plumbing Code were approved at the International Code Council (ICC) hearings, held at the end of February and the beginning of March in Cincinnati. These changes addressed issues in several areas of plumbing-system design.

Bathtub scald prevention

One issue was that of bathtub scalding. During the previous code revision cycle in 2002, a very important change was approved to place hot water temperature limits on bathtub fixtures. Since an American Society of Sanitary Engineering (ASSE) standard—1070—was still under development, it was purposely not referenced, and only a maximum temperature limit of 120°F was included in the IPC change. During challenge hearings that followed in Overland Park, Kan., one party attempted to add the 1070 standard, which prompted some confusing testimony. The membership, as a result, denied the code change. That action eliminated any temperature-limit protection for bathtubs until this most recent code cycle, when the water temperature limitation finally passed. Bathtubs will now be required to have pressure-balancing or thermostatic mixing valves in addition to the maximum temperature limit of 120°F.

Gang showers

There was also a code change approved to allow mixing valves that meet the new ASSE 1069 standard for gang-shower applications. There was some confusing language in this code change because the title was “Multiple showers supplied with a single-tempered water-supply pipe.” A single-tempered water pipe means the shower valve is either a push-button metering faucet or a simple on/off valve with tempered water served by a thermostatic mixing valve meeting the ASSE 1069 standard. The code change not only added ASSE 1069 thermostatic mixing valves, which are designed for this application, but it went a little too far, in my opinion, by requiring ASSE 1016-rated pressure-balanced, thermostatic or combination-balanced pressure/thermostatic mixing valves as end-use devices. These valves must be supplied with both hot and cold water. The code change passed with a modification, but I believe the language is still confusing. In fact, it may need to be revisited in the next code cycle, as there are two types of gang showers, in my opinion, and these need to be defined.

Legionella and scalding issues

Another proposed code change—one that was not approved—dealt with a minimum hot-water storage temperature (140°F) to prevent Legionella bacteria growth in water-heater storage tanks. A companion code change, requiring maximum delivery temperature for hot-water systems to be 120°F, was also rejected. This proposal would have required the use of thermostatic mixing valves on just about every hot-water system. In the end, insufficient testimony was presented to convince the committee that Legionella or scalding were significant enough problems to warrant such a change. (For a different take on the Legionella issue, see Legionella: Be Proactive, not Reactive .)

The case was further hindered by testimony from the Gas Appliance Manufacturers Assn., on behalf of water-heater manufacturers, opposing any increase in hot-water storage temperatures.

Multiple shower heads

The subject of mandatory water-conservation measures for multiple shower heads also resurfaced at the Cincinnati hearings. During the last cycle a water-conservation proponent proposed limiting each shower to one head per valve to conform with the Energy Policy Act of 1992, which limits the maximum flow rate from a shower head to 2.5 gallons per minute (gpm). The proponent testified that numerous companies sell showers with multiple heads, and are thus in violation of the act, which was designed to conserve water. The committee, last year, denied the change, but this year, the same water-conservation proponent was back, this time proposing that fixture-unit adjustments and drain-size adjustments be made for multiple-head showers. The committee, however, also denied these changes, reasoning that it was unfair to tie the number of shower heads and body sprays to such adjustments, since not all shower heads and body sprays flow at 2.5 gpm or spray simultaneously.

The International Code Council (ICC) hearings were held during the last week of February and the first week of March in Cincinnati.

The ICC does an excellent job overall, particularly when it comes to making the hearings accessible to everyone. This includes broadcasting the code hearings live on the Internet.

The most recent hearings involved final code changes before the publication of the 2006 International Codes (I-Codes) in late 2006. (There are two, 18-month code change cycles for each three-year publishing cycle of the I-Codes.) Public comments to the ICC code changes are due by mid-June 2005, and final action on all code changes will be voted on at hearings during ICC’s Annual Meeting, the last week of September in Detroit.

Canadian Standards

In this particular cycle in Cincinnati, the Canadian Standards took a pretty hard hit. In fact, most of the proposals to list the Canadian Standards were denied. Many of these standards were proposed as additional product standards to be listed with product standards already in the International Plumbing Code. The problem seemed to be that the committee saw the Canadian Standards as not always equal to the standards that are currently listed in the I-Codes.

One of the key complaints from some of the opposing code committee members was that they received only very large electronic files of all the standards and not hard copies for review. This, they said, made it difficult to review all of the differences in the standards. Further, testimony revealed a concern that the Canadian Standards had some dimensions, tolerances and performance requirements that differed from the standards currently referenced in the I-Codes. Perhaps the biggest problem, despite a number of questions from the committee, was that there was no one to speak on behalf of the proposed Canadian Standards.

From my perspective, the problem is that each standard develops in its respective region of the world. Now that we have a more global economy, these differences are becoming more significant. For example, one of the ICC staff analysis comments indicated that the Canadian Standards were developed only for Canadian products. However, the I-Codes are supposed to be used internationally, including Canada. It became a struggle for the code committee to allow the Canadian Standards to be listed in the I-Codes because the perception was that they would have to lower the bar in some instances in order to accommodate them.

Finding harmonization

The good news is that there has been an effort undertaken by the American Society of Mechanical Engineers and the American Society of Sanitary Engineering to create a standards harmonization that will try to find a point where the Canadian Standards are acceptable both in the United States and in Canada. This begs the question: Are U.S. and Canadian Standards non-standardized standards? Maybe the problem is that the various national standards are not harmonized.

Why standards?

Of course, an even bigger question is “What’s the big deal with plumbing standards?” In order to truly understand the importance of standards, perhaps it is best to look back to an incident from the early 20th century.

On Feb. 7, 1904, a fire broke out in the basement of John E. Hurst and Company in Baltimore. Fire departments responded from Washington, D.C., Philadelphia and New York. However, each city had its own unique fire-hose threads and could not connect to Baltimore’s hydrant system. Those fire departments were forced to watch as the fire progressed. Before it was over, the fire had burned for more than 30 hours and destroyed approximately 2,500 buildings in an 80-block area. As a result the National Bureau of Standards, now the National Institute of Standards and Technology (NIST), began a study of fire-hose couplings, and more than 600 couplings were collected and analyzed from across the country. Based on this research, a standard hose coupling and an interchangeable coupling device for non-standard hoses were adopted as a national model. That document continues today as NFPA 1963, Standard for Fire Hose Connections .

Mix, but not match

A similar thing seems to be happening today with the Canadian Standards organization. It’s as though they came to the fire with an incompatible hose thread. There is nothing wrong with their standards. The problem is, when they try to “mix their hose” with neighboring hydrants, the two simply do not match.

The U.S. and Canadian Standards have different sizes, tolerances and minimum performance requirements. The proponents of adopting the I-Codes without the Canadian Standards argue that if the Canadian Standards are allowed, then there is a potential for mismatched products that would need to be approved by code officials. This is a significant issue, and there will need to be some compromise as one or both standards must be modified to a point where everyone agrees upon one standard, or at the very least, that the two standards should have the same minimum requirements.