I recently attended the second round of meetings to discuss proposed changes to the International Association of Plumbing and Mechanical Officials (IAPMO) model codes – Uniform Plumbing Code (UPC) and Uniform Mechanical Code (UMC) on behalf of ASA and HARDI.
These model codes are considered for adoption as regulations by state and local government agencies across the U.S. The UPC and UMC Technical Committees reviewed public comments received in response to the Technical Committees’ initial positions taken on proposals submitted in 2021. I am happy to say that ASA provided a strong voice at the hearings both through direct public testimony and through significant collaboration with other associations throughout the supply chain, both prior to and during the meetings, ensuring our positions on key issues were understood and in a majority of cases approved by the Technical Committees.
In 2021, ASA took positions on 36 separate proposals for the UPC and the Technical Committee supported ASA’s position on 83% of the proposals. The results of the recent May 2022 meetings resulted in ASA continuing to have strong support for our positions. The following highlight some of the key proposals discussed:
Temperature limiting devices for shower and combination shower-tub: ASA supported the deletion of specific temperature-limiting mechanisms and ASSE product standards associated with those mechanisms from the UPC. The rationale for our support is the mechanisms and applicable ASSE standards are not directly related to use in shower and combination shower-tubs and could lead to the misuse of the products in the field, and ultimately, consumer dissatisfaction. The Technical Committee continued to support ASA’s position on this issue.
Minimum fixture pipe branch sizes: ASA continued to support the proposal submitted by the Plastic Pipe Institute to allow for the use of 3/8-inch nominal tubing size in specific fixture applications including lavatories and water closets. ASA supports this proposal based on its overall support of the need to properly size all plumbing system piping systems in accordance with the new water efficiency fixtures and reduced water use leading to oversized systems based on current model code requirements. The proposal was not supported by the Technical Committee. It should be noted that the use of the 3/8-inch nominal tubing size is acceptable in other model plumbing codes.
Drainage pan for water heaters: The current UPC requires “Where a water heater is located in an attic, in or on an attic ceiling assembly, floor-ceiling assembly, floor-subfloor assembly or where damage results from a leaking water heater, a watertight pan of corrosion-resistant materials shall be installed beneath the water heater…” A proposal was considered to provide specific thickness requirements for the drain pans and flame spread index requirements for plastic drain pans. The proposal was provided with no substantiation for the thickness dimensions, and there is concern the ASTM flame spread index standard referenced is not appropriate. The Technical Committee did approve the proposal by majority vote, however, it did not receive the required 2/3 affirmative vote that will be needed in the letter ballot process. This proposal was also considered under the UMC.
Potential new product markets or expansion of existing markets: The following products were accepted by the Technical Committee for inclusion into the UPC:
- Acceptance of Polyolefin Pipe and Joints: The Technical Committee approved the addition of polyolefin pipe and joints for Drain Waste and Vent applications using both heat-fusion and mechanical joints.
- Cure-in-Place (CIPP) Rehabilitation of Sewer Piping: A proposal to allow for the use of CIPP for sewer piping and service lateral piping was originally rejected by the Technical Committee but based on revisions to the proposal, the Technical Committee voted in support of the inclusion of CIPP into the UPC.
- Combined Treatment and Dispersal (CTD) Systems: The Technical Committee preliminarily approved the inclusion of requirements in Appendix H – Private Sewage Disposal Systems, for combined treatment and dispersal systems certified to NSF/ANSI 40. It is my understanding that some ASA distributor member companies provide these types of systems to the marketplace and the inclusion into Appendix H will help in further expanding the use of the systems and acceptance by regulatory authorities. The systems utilize natural onsite biological treatment of the sewage water prior to the treated secondary waste being released into the onsite subsoil.
There have been strong collaborative efforts by various industry associations, including ACCA, ASA, ASHRAE, HARDI, PHCC and others.
The major focus of our advocacy work during the hearings related to the incorporation of requirements for the use of A2L refrigerants and expressing our opposition to the possible use of press-connect fittings for refrigeration system joints. I am pleased to say that there was a strong collaborative effort by various industry associations in preparing for the meeting and providing testimony at the meeting. Collaboration was achieved through the following organizations: ACCA, ASA, ASHRAE, HARDI, PHCC and others.
A2L Refrigerants: Through the collaborative effort noted above, we were able to convince the Technical Committee to reverse its rejection of the incorporation of A2L refrigerant requirements and approve one of two proposals submitted by the industry. These changes are critical for providing code guidance on the implementation of regulatory requirements related to greenhouse gas emission and changing to low GHG emitters such as A2L refrigerants.
Refrigerant Line Joints: A proposal to accept an amended version of the industry proposal related to A2Ls with a requirement that only brazed joints could be used was rejected. Unfortunately, another proposal requiring “all joints on refrigeration piping installed in concealed spaces shall be brazed” was accepted by the Technical Committee by a slim majority; but will require a 2/3 affirmative vote in the letter ballot process to continue forward. If adopted, the fact that a significant amount of refrigeration piping is installed in concealed spaces will lead a significant reduction in the use of alternate types of joining systems currently on the market and being used without any known safety or performance issues.
The next steps involved in the IAPMO process will be a letter ballot sent out to the Technical Committee members so they can formally document their positions on each of the public comments submitted and discussed at the meetings. As noted several times above, a change to the current UPC or UMC will require a 2/3 affirmative ballot of the Technical Committee. Following the balloting process, IAPMO will publish the results of the Committee votes in mid-August followed by a review of items of interest from the IAPMO membership presented at the Technical Membership meeting being held on Sept. 13, during the IAPMO Annual Meeting in Charlotte, North Carolina. I will be present at the meeting representing both ASA and HARDI. Ultimately, the final proposals accepted at the completion of the process will be incorporated into the 2024 version of the model codes for consideration of adoption by state and local authorities.
In addition to the above, I have been representing ASA and HARDI in working closely with other trade associations, in opposing a proposal to remove the use of press-connect fittings from the past two published versions of the UMC by removing reference to UL 207, the national standard for refrigeration fittings. The full review process of the proposal has been completed and the IAPMO Board of Directors announced on May 22 the rejection of the proponents appeal and the Board supported the Standards Council decision to reject the proposed changes. This is the final step in the process and our opposition to the proposals has been fully upheld.
STANDARDS ACTIVITY
ASHRAE 15.2 Published - ASHRAE 15.2 has been published. ASHRAE 15.2 is a safety standard designed to accommodate the use of A2L-classified refrigerants in low-rise residential applications and is intended for use by manufacturers, installers, contractors, service technicians, building code officials and others.
Standard 15.2 requires that all products be listed to a national product safety standard and installed per the manufacturer’s installation instructions. Specific requirements are included for which refrigerants can be used, the maximum allowable refrigerant charge, accessories and interconnecting piping, so that in the event of a full release of the refrigerant charge, the concentration in the space remains safely below the lower flammability limit of the refrigerant. To learn more about the standard click here.
Draft IAPMO IGC 1123 California Proposition 65 Compliance, Products and Materials - IAPMO recently announced for public review draft standard IGC 1123 intended to provide criteria and a model for conducting product and material assessment against California Proposition 65 to determine if labeling is required based on the requirements of Proposition 65. ASA has opposed the development of a standard in this area based on lack of value or market need and has submitted comments in opposition to the development of the standard. However, in our opposition to the standard we note if IAPMO proceeds in the development of a guidance document not intended for third-party certification or adoption into regulation or codes we would not be in opposition. Comments were due by June 6.
FEDERAL REGULATORY ACTIVITY
The Department of Energy (DOE) has been very active in publishing proposed changes and final rulings related to the Energy Policy and Conservation Act (EPCA).
Hot Water Storage Tanks - the U.S. Department of Energy (DOE) has published a Federal Register notice of final determination pertaining to energy conservation standards for unfired hot water storage tanks (UFHWSTs). In this final determination, DOE determines that the standards for UFHWSTs do not need to be amended. DOE has determined that it lacks clear and convincing evidence that more-stringent standards for UFHWSTs would save a significant additional amount of energy and would be economically justified.
Faucets and Showerheads - DOE has published a Federal Register notice proposing to amend the test procedures for faucets and showerheads to incorporate the current version of the referenced industry standard, American Society of Mechanical Engineers Standard A112.18.1-2018, “Plumbing Fixture Fittings." DOE also proposes to add definitions for low-pressure water dispensers and pot fillers and exclude them from the faucet definition. Finally, DOE proposes to provide further detail for conducting the flow rate measurement. DOE is seeking comment from interested parties on the proposal. DOE will accept comments, data, and information regarding this NOPR until Aug. 1. ASA is collaborating with PMI in reviewing and preparing comments on the proposed amendments.
STATE ACTIVITY
California – Amendments to CA Proposition 65, Clear Labeling Requirements has been put on hold after significant opposition on the proposed amendments from ASA along with a large number of other trade associations that joined in a coalition brought together by the CAL-Chamber. ASA’s opposition is based on the potential cost of implementing the proposed changes and the potential market confusion that would be created by the proposed ruling, especially for the consumer.
Louisiana Construction Code - Louisiana uses the International Mechanical Code (IMC) as its State Code and are in the process of considering the adoption of the 2021 edition of the IMC. We have been actively involved in the process and opposing a proposal to not adopt the acceptance of press-connect fittings for refrigeration systems based on compliance with UL 207 as currently allowed in the IMC 2021 and instead, adopt requirements that would not be consistent with UL 207 and ultimately, impacting the ability to distribute press-connect fittings for use in refrigeration systems in the State. The LA State Uniform Construction Code Council recently reviewed the issue and asked that the task group that submitted the proposal work with industry representatives and the standards developer, UL, to resolve the issue. We continue to work on this issue in opposition to the proposed changes.
Stay tuned for more updates on the development process as it progresses and please feel free to contact me at any time if you have any questions. ASA members may obtain additional up-to-date information on all of our codes and standards activities by visiting the member’s only section of the ASA website at asa.net. In addition, readers are always encouraged to contact me directly at jkendzel@asa.net with questions or comments related to regulatory, codes and standards activities impacting our markets.
