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During this last quarter, I have had the opportunity to be part of an aggressive development project related to revisions to existing Product Category Rules (PCRs) for the following plumbing fixtures: electronic bidet seats, residential toilets, commercial lavatory faucets, commercial toilets, and commercial urinals. My guess is the first question you might have is — What is a PCR? As with most codes and standards activities, there are several acronyms involved in explaining the purpose of PCRs and the potential impact of the initiative on your business. So let me provide some background.

A PCR is the product category-specific requirement for conducting life cycle assessment (LCA) studies and reporting their findings through Environmental Product Declarations (EPD). An EPD report tells the life cycle story of a product in a single, comprehensive report. The EPD provides information about a product’s impact upon the environment, such as global warming potential, smog creation, ozone depletion and water pollution. Finally, an LCA is to quantify the environmental impacts that arise from material inputs and outputs, such as energy use or air emissions, over the product’s entire life cycle (production, distribution, installation, use and disposal) to assist consumers in making decisions that will benefit the environment.

There is a significant amount of information on LCAs that can be found online, and I encourage you to take a bit of time to research the information to determine how it may impact your specific activities in the supply chain. As we progress toward increased awareness and increased codes and standards activities promoting and even mandating sustainability requirements related to the products we produce and the way we manage our businesses, having a good understanding of LCAs and what they mean to you will become more critical.

The PCRs we are working on are being developed under the facilitation of a third-party PCR developer, Sustainable Minds, and the project is being sponsored by TOTO. The PCR Committee is comprised of many stakeholders who either manufacture the product(s), use the product and subject matter experts. The originally published PCRs and the revisions being conducted are based on the Product Category Rule Guidance Document for Kitchen and Bath Vessel Fixtures (Version 1.1). The Committee has set an aggressive goal of completing the revision process by the end of the year so stay tuned for updates.


The American Society of Sanitary Engineering (ASSE) held its mid-year conference in Chicago the first week of April. The following are some key takeaways from the ASSE Product Standards Committee meeting and the IAPMO Product Standards Committee meeting held during the ASSE Conference:

  • ASSE 1004 – Performance Requirements for Commercial Dishwashing Machines was considered for withdrawal by the Committee until it was noted there was one manufacturer having a product listed to the Standard. If you have any reason for ASSE 1004 to continue to be in publication, please contact me.
  • A discussion was held on the potential of developing a new standard for secondary water treatment systems within a building. ASSE staff will consider the potential for the development of such a standard.
  • It was noted that the California Energy Commission is seeking proposals to further reduce the water usage in water closets and urinals. ASSE staff will follow up to see if ASSE/IAPMO is currently involved. ASA has been monitoring these activities for some time now with a general position opposing any further reduction in water usage requirements.


The Uniform Solar, Hydronics & Geothermal Code Technical Committee (TC) met on May 16 to go over proposals for revisions. The full meeting monograph can be found by clicking here. There were two proposals of interest highlighted below:

Proposal to require dual-purpose water heaters to be configured to maintain fluid separation between the portable water and hydronic system fluid. (see item 030, public comment 1 in the meeting monograph). This public comment was accepted by the TC.

Proposed requirement that ABS and PVC transition joints for drainpipe and fittings in hydronic systems be made using listed transition solvent cement based on ASTM D3138 (see item 47, public comment 1 in the meeting monograph).

The IAPMO Water Efficiency Standard (WE-Stand) TC met on May 17 to go over public proposals on revisions to the Standard. The full meeting monograph can be found by clicking here. Highlights of the meeting are provided below:

  • Public comment submitted to state a specific leakage rate requirement for bath and shower diverters in accordance with the industry standard. The TC voted not to accept the proposal; however, the ASA Codes and Standards Committee will continue to take a position in favor of the public comment during the formal balloting process. (see item 046, public comment 1)
  • Public comment submitted to remove marking requirements for tagging, labeling, or marking shower control valves with the manufacturer’s minimum rated flow was not approved by the TC however, the ASA Codes and Standards Committee will continue to support the proposal during the official balloting process. (see item 047, public comment 1)
  • A new concept using a maximum hot water system ratio based on the dwelling unit footprint was accepted by the TC. However, the ASA Codes and Standards Committee opposes the concept based on it being too restrictive and will continue to oppose the proposal during the formal balloting process. (see item 113, public comment 1).

As always, I encourage you to contact me directly if you have any questions related to the content of this article or if I can be of any assistance related to questions or concerns associated with codes or standards impacting our industry. You can contact me at