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As I go about my job inspecting, reviewing plans and enforcing Massachusetts Fuel, Gas and Plumbing Code 248 C.M.R., I sometimes have a difference of opinion about a particular section of the code. When this happens, whether it's with the plumber, architect or builder, it has come quite routine for me to hear things like, "Why?" "When did they put that in the code?" "Since when?" and "I work all over the state, and this is the only town that makes me do that," among many other colorful expressions. But none more than when I tell them they must install a metering faucet. Why? What's the mystery? Have I been misinterpreting the code? It wouldn't be the first time. Then, when I do go over the big bridge and visit other cities' and towns' fine establishments, low and behold, there are new toilet facilities with no metering faucets. I must be wrong...or am I? Let's check out our code and see if we can make some sense of this rarely enforced section of the code.
First, in Section 2.14 8 f, the heading is Conservation of Hot Water. Right away there could be a misunderstanding. Does this mean you only have to install a metering faucet on the hot water? Perhaps, if you really went by the letter of the code. However, the practical answer is no, it wouldn't make much common sense to install a separate hot water faucet on a lav. And don't forget the code also refers to conservation of cold water, and the intent of the code is to save water and energy.
Next, Section 2.14 f 2, subtitled Lavatories in rest rooms of public facilities shall.... This is crystal clear to me. The faucets shall be installed "(on a lavatory) (in a rest room) (of public facilities). Not (on a hand sink) (in the kitchen) (of a restaurant)." But some of the confusion comes from the term "public facilities." This is easily explained; simply look up the definition of public in the code. "Public or Public Use. In the classification of plumbing fixtures, public shall apply to every fixture not defined under Private or Private Use. Private or Private Use. In the classification of plumbing fixtures, private shall apply to fixtures in residences, apartments, condominiums, and to private guest rooms in hotel and motels." So, if the lavatory is not in a residence, apartment, condominium, or the private guestroom of a hotel or motel, Section 2.14 8 f 2 must be applied. Now we know where metering faucets must be used.
Next, under the heading Lavatories in rest rooms of public facilities shall..., there are three paragraphs beginning with the words "Be equipped." These are not choices; the faucets must meet each of these requirements. The only options are whether you want to use an electronic, linkage or metering type faucet in the first paragraph. The maximum water temperature must be 110 degrees, and they must be capable of delivering a maximum of .25 gallons, unless you use an electronic or linkage type faucet. Then it must deliver a maximum of .5 gpm.
Now we know what type of faucet to use. The key is to find a faucet that you can adjust the temperature at the faucet. Otherwise, you will have to install a tempering valve under the lav to get 110 degrees. You absolutely cannot turn down the water heater, because the minimum temperature for hot water as defined is 120 degrees. So, why do we call 110 degrees hot water at the lav? Also, other fixtures in the building would require hotter water.
Last but not least what about a handicapped lavatory? I'm sure this is where most of the confusion and misinterpretation comes from. So, let's take this one step at a time. First, we must refer to Section 2.10 19 m 1 and 2, Handicap Factory Requirement, "#1. Fixtures shall be installed in conformance with 521 C.M.R. 3.30.0 Public Toilets (for fixture dimension requirements only). #2. When public rest rooms are installed, handicap fixtures shall be installed to comply with the requirements of 248 C.M.R. 2.10 19 m." Number 2 says "(when public rest rooms are installed)"; therefore, we go back to the definition of public. That solves that--handicap toilet rooms shall be installed every place and not defined under private or private use. Number 1 could be a little confusing. The last sentence says "(for fixtures dimension requirements only)." It does not say fixtures and dimensions, nor is there a comma after the word "fixtures." So, what is the intent? Let's give this statement the benefit of the doubt and say it means fixtures and dimensions, even though you could have a pretty good case that it means the dimensions of fixtures. Assuming you must use a faucet approved by 521 C.M.R., we refer to Section 30.9.6 Faucets, "Faucets shall be operable with one hand and shall not require tight grasping, pinching, or twisting of the wrist. Lever-operated, push type, touch type, or electronically controlled mechanisms are acceptable designs. If self-closing valves are used the faucet shall remain open for at least 10 seconds." So, a metering type faucet is allowed under 521 C.M.R., and you can easily satisfy both codes. I don't think there is a faucet made that you need two hands to operate.
The faucet that is not mentioned in 521 is a linkage type, which is probably not handicap accessible. These faucets have foot, knee, or arm paddles linked to the faucet and are mostly used on clinic or lab sinks. They are rarely if ever used on a lavatory.
It is a misconception that you must use lever-operated faucets with wrist blade handles on a handicap lavatory. The key is to use a faucet that will satisfy both codes. Most, if not all, metering faucets are handicap approved. The faucet must remain open for at least 10 seconds, according to 521, whereas the plumbing code requires a maximum of 0.25 gallons, again unless you use an electronic type faucet. Although not a scientific study, I tested a metering faucet. Holding the faucet open for 10 seconds allowed it to discharge 26 oz., just under the required or maximum of 32 oz., or 0.25 gallons, as per the plumbing code.
In my opinion, there is no mystery about metering faucets; they are required. The intent of both codes is safety, ease of operation for all, and water and energy conservation. There is a proposed code revision that would allow an exception for metering faucets. We will discuss that when the revisions are passed; I'm still waiting. Remember, if you get stuck on a code issue, think it over, get someone else's opinion, use common sense, and above all, try to determine what the overall intent of the code is in relation to consumer safety, use and other codes that may have similar regulations.