IAPMO Letter Ballot changes some of the outcome from Denver meeting.

The International Association of Plumbing and Mechanical Officials (IAPMO) has announced the results of the Letter Ballot on the public comments that were discussed at the code change hearing this past May in Denver. You may recall that those results were discussed in my June 2008 column (“IAPMO Close To History”). While history seemed to be in the making, as an IAPMO member I’m concerned that some of IAPMO’s old ways may be creeping back.

For many years, critics accused the IAPMO code change process of being controlled by   certain special-interest groups. IAPMO then changed to a consensus process to remove any dominance in the voting on code changes. That doesn’t mean that remnants of the old alliances haven’t been working overtime to figure out how to maintain control over the Uniform Plumbing Code.

It is interesting to view the voting patterns on a number of the code changes in the written ballot. Rather than requiring a majority vote, the procedures allow only one-third of the Plumbing Technical Committee (TC) to control certain votes. This is a unique twist in  the procedures.

Once the Denver meeting was completed, the code change results were distributed to the TC in a letter ballot. It requires a two-thirds vote of the TC to confirm the hand vote in Denver. Hence, if more than one-third of the TC votes against the code change result, the action is reversed.


For the first time ever in the new process, the TC has reversed itself on a number of code changes. Many of those changes were the hot issues of the hearings, including some green initiatives.

The very first and very last code changes on the letter ballot dealt with air admittance valves. The American Society of Plumbing Engineers (ASPE) submitted the last code change to allow the use of air admittance valves in engineered designs. The TC voted to reject the public comment that sought to reverse their initial acceptance of the ASPE code change.

I should point out that the vote to reject the public comment does nothing to reverse the initial decision of the code change, which is another interesting twist. By rejecting the vote on the public comment, the code change reverts back to the TC’s original recommendation. The original recommendation was to accept the code change. Hence, air admittance valves are still slated to be accepted in the engineered section of the Appendix.

The proposal with the greatest number of comments was the change on showerheads. As previously reported, the code change would restrict a shower to one showerhead with a flow of 2-1/2 gpm. This change would prohibit the concept of multiple showerheads. In the letter ballot, this change was overwhelmingly defeated. Many of the representatives of manufacturers, inspectors, and labor voted against the measure. This results in the rejection of the code change and the continued practice of using excessive water in a shower. This vote is contrary to the direction that IAPMO is taking as an organization, which is fully supporting green building initiatives.

Many considered this to be one of the most important code changes for the green movement. The reversal of this change is a major setback and a statement in favor of the anti-green campaign.

Another change that has been beaten to death is the installation of water heaters in closets off of bedrooms and bathrooms. The change would bring the Uniform Plumbing Code in line with the requirements in the National Fuel Gas Code. A public comment was submitted to reject the change. The TC voted to reject the public comment. However, this is another case where the code change reverted back to the original recommendation, which was to accept the change. Hence, there is no change in the recommendation to accept the code change.

A change that made a lot of sense and followed engineering protocol was the lowering of the minimum trap size of a shower drain from 2 inches to 1-1/2 inches. It is interesting to note that, with a showerhead flowing 2-1/2 gpm, a 2-inch drain pitched at 1/4 inch per foot cannot maintain the minimum recommended velocity of two feet per second. However, a 1-1/2-inch drain can maintain a velocity above two feet per second. This didn’t seem to matter, with the vote being against the code change. This reverts back to the misguided concept that bigger is better.

One of the ASPE code changes submitted proposed the acceptance of its new standard on siphonic roof drainage. While several members voted against this change, the vote fell one short of rejecting the public comment. This is another case where it would not have made any difference, since the original recommendation was for approval as submitted. Siphon roof drainage is still slated to be added to the code.

Most Troubling

One of the most troubling displays of Committee manipulation occurred on a code change that I submitted to recognize floor drain trap seal protection devices. I chaired the Working Group that developed the new ASSE 1072 standard.

A competing manufacturer of a product that utilizes a different technology sent a letter to all the TC members after the Denver hearings, encouraging them to vote against the change to accept floor drain trap seal protection devices. The best way to describe this letter is to say that it was written in an attempt to restrict a competing new technology.

The letter clearly states that the devices should not be accepted in place of “fresh water trap primer valves,” such as the ones manufactured and sold by the author’s company. The TC voted to reverse the Committee’s recommendation of approval of the code change.

All the items that were reversed by the TC are automatically appealed to the Standards Council. This is the process of checks and balances. It is possible that the Standards Council may not uphold all the votes.

The Report on Comments (ROC) has published the final votes and results of the Denver code change hearing. The ROC can be downloaded from the IAPMO Web site, www.iapmo.org.

The final code change hearing on the public comments will occur at the IAPMO annual meeting to be held Sept. 28 – Oct. 3 in Atlanta. The IAPMO membership will be given an opportunity to vote on the published comments.