Differing Opinions
by Julius Ballanco, P.E., CPD
December 1, 2011
The 2012 edition of the International Plumbing Code expands the use of air-admittance valves with the addition of the newer standard ASSE 1049. Photo courtesy of Studor
The air-admittance valve debate heats up.
As the three remaining
model plumbing codes are finalized for the 2012 editions, the one difference
that really sticks out is each code’s approach to air-admittance valves. Two
codes are definitely struggling with the concept of AAVs, while the other is doing
just fine.
The code doing just fine is the ICC International Plumbing Code. In the 2012
edition, it expanded the use of AAVs with the addition of the newer standard
ASSE 1049. This standard is applicable to AAVs for chemical waste applications.
Chemical and special waste systems can now be vented with an AAV provided it is
certified for resistance to the chemicals involved. One manufacturer (Studor)
has developed a polypropylene AAV that conforms to ASSE
1049.
IAPMO’s Uniform Plumbing Code and the PHCC National Standard Plumbing Code are
struggling with their references to AAVs. Both codes want their identity to
include that they do not allow AAVs. That isn’t really accurate, but it is what
they would like you to believe.
At the recent meeting of the IAPMO Standards Council, an appeal to add AAVs to
the 2012 Uniform Plumbing Code was denied. Basically, the reason for denial was
that the will of the membership was opposed to AAVs. That’s not much of a
reason when a code is a consensus document. Shouldn’t there be a proper
technical justification?
Previous IAPMO Standards Councils used to require the Plumbing Technical
Committee to come up with proper justification for not accepting AAVs other
than, “We just don’t like them.” That has never really happened, but words are
thrown together that still boil down to, “We just don’t like them.”
On many occasions, the Plumbing Technical Committee has approved the
recognition of AAVs only to have the letter ballot fail to obtain a two-thirds
majority. Hence, it is not the will of the IAPMO membership. It is the will of
the “1/3 plus 1” minority.
In some people’s minds, 25 years of use in the United States and the installation
of more than 20 million valves is not justification for accepting a product.
Forget all the laboratory tests that prove AAVs are equivalent. Some people
want field testing. I’m not sure if it will take 50 years of use and 100
million valves installed before the field testing is proven. If you think about
it, it wasn’t that long ago we brought plumbing indoors in this country.
Aren’t They Already There?
What the Standards Council
and the membership seem to ignore is the fact that AAVs already are permitted
by the Uniform Plumbing Code. Section 911.0 allows the engineering of a vent
system. Any engineered design can incorporate an AAV. Engineers would be smart
to use the requirements in the International Plumbing Code to validate the engineered
vent design.
The National Standard Plumbing Code is somewhat different in its approach to
AAVs. It has included AAVs as an engineered design in its appendix for quite
some time. The problem is it requires every use of an AAV to be on a drawing
sealed by a P.E. That is not a problem in a commercial building, where P.E.s already
are required to sign and seal every plumbing engineering drawing. The problem
occurs in residential or minor repairs where plans are not
required.
A proposed change would have added AAVs to the venting section without the need
for an engineered design. After all, the code already allows AAVs. The Code
Committee turned down the change with the reason reduced to, “We just don’t
like them.” Of course, this is rather strange since AAVs are allowed in an
engineered design.
The problem with the National Standard Plumbing Code is there is no membership
vote or oversight of the Code Committee. What the committee says, goes. That’s
not the best system in the country for developing a plumbing code. It also may
be the reason it is used by only one state (New Jersey) and parts of other
states, including Maryland.
Costly Appeal
The proponent of the code
change attempted to appeal the decision of the Code Committee. That is, until
he was informed such an appeal would cost more than $20,000. That’s right, PHCC
charges more than $20,000 to appeal a decision of its Code Committee.
There is absolutely no way to justify charging someone this amount of money to
appeal a questionable decision by a code committee. But PHCC is of the opinion
that an appellant should pay all the costs associated with an appeal, including
the staff time. I find that outrageous.
As a result of this high cost, the code-change proponent did not appeal the
Code Committee’s decision to not accept AAVs in the venting chapter.
The result is that two codes will again avoid identifying AAVs in the venting
section of their respective codes while the International Plumbing Code embraces
the acceptance of AAVs.
When looking at the map of code acceptance, the International Plumbing Code
dominates with statewide adoptions. The Uniform Plumbing Code has many states,
but not nearly the number ICC has. Interestingly, many states that have adopted
the Uniform Plumbing Code also have amended the adoption to accept
AAVs.
As for the National Standard Plumbing Code, it is almost a nonentity. With only
one statewide adoption, there isn’t any major push to use the code in other
states or jurisdictions.
Perhaps IAPMO and PHCC will realize that the lack of recognition of AAVs has
hurt their stature, not helped it when dealing with acceptance of the code. I
believe we have reached the point where those who “just don’t like AAVs” should
admit that they are wrong. It is time to move on.
I wish all of you a Merry Christmas, Happy Hanukkah and a wonderful New Year.
Julius Ballanco, P.E., CPD
jbengineer@aol.com
Julius Ballanco, P.E., is Editorial Director of PM Engineer and president of J.B. Engineering and Code Consulting, P.C. in Munster, IN. Prior to starting J.B. Engineering, he served as head of plumbing and mechanical engineering for Building Officials and Code Administrators International, one of the organizations that formed the International Code Council (ICC). His engineering consulting work includes the design of plumbing, mechanical and fire-protection systems; forensic engineering; training; and serving numerous manufacturers in different capacities. In addition, Ballanco is the current president of ASPE and a member of both ICC and IAPMO. He can be reached by e-mail at jbengineer@aol.com.
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Title: AAV's
By: Terry Moore
Posted: January 5, 2012 6:56 PM
I would only say this as to Julius Ballanco comment wanting people to admit they are wrong as to the use of AAV's. Mr. Ballanco I have listen to many of your discussions on plumbing codes and it disappoints me that a person such as your self would not realize that all state codes are not the same. You want to make blank statements as though you are the ultimate authority on codes and AAV's. Well, AAV's are a mechanical device and anything mechanical can fail. I have yet to see a vent stack stop operating due to mechanical failure. Louisiana does not accept AAV,s and for good reason just like you cannot have one code that fits all states. I think maybe it is time you realize this and move on yourself.