ICC Final Action This Month
From Sept. 17 through Sept. 23, the International Code Council (ICC) will hold their final code change hearing for the development of the 2009 International Codes. The final vote is cast by the public official members of ICC.
The ICC process requires the submittal of public comments objecting to the initial decisions made by the code change committees at the first hearings. This setup is done to minimize the number of code changes that will be considered at the final hearing. However, it did not slow down the number of comments - as more than 50 have been submitted.
Considerable Discussion ForthcomingWhile the biggest change facing the membership is residential sprinklers, there are many other plumbing changes that will be decided at the meeting. It is anticipated that there will be considerable discussion on the fixture requirements. Representatives from the Virginia Plumbing and Mechanical Inspectors Association have proposed a number of changes that will impact the design of toilet rooms. Two of those changes will double the number of water closets required in small assembly and mercantile buildings, such as coffee shops, neighborhood restaurants and convenience stores.
The problem with the proposed change is that there is no data to justify the doubling of water closets in smaller assembly and mercantile buildings. The reason for the change is basically that the proponent considers it a good idea. One could propose tripling or quadrupling the number of fixtures required using the same reasoning. What appears to be missed is that the original IPC table is based on studies of toilet room use.
The same Virginia group submitted another change on door locking that received the greatest number of public comments. The change would prohibit a toilet room door from having a lock. The proponent had a noble idea that the intent of the code is to provide unrestricted use of toilet rooms. However, in the world of post 9/11, they forgot about security concerns.
Many business buildings lock the toilet rooms, but provide keys to anyone requesting the use of the toilet room. Outside facilities in parks, playgrounds and seaside resorts are locked during hours of nonuse to prevent vandalism and vagrants. These practices would be prohibited under the proposed change.
There are a few changes dealing with the minimum number of drinking fountains required. Currently, the IPC allows up to 50% of the required drinking fountains to be substituted with bottled water. Previously, the IPC allowed all of the drinking fountains to be substituted with bottled water. One change will revert back to the previous language.
The issue always whirls around whether the bottled water will remain in the building after the inspector is gone. The concept was to have at least half the required number of drinking fountains. Where this creates hardships is with strip-type mercantile and business buildings. Which individual tenant needs the drinking fountain? Or do all tenant spaces require drinking fountains? Another change would address the individual tenant spaces by not requiring drinking fountains when the occupant load is less than 50.
What would an ICC code hearing be without some discussion on water heater relief valve discharge? You would think that something this simple would not generate any discussion. But, once again, there will be debate on where you can terminate a relief valve. What most find extremely amusing is that water heater relief valve discharge pipes are beat to death, yet the mechanical code has no similar discussions for boiler relief valve discharge pipes.
The Virginia inspectors have challenged two of the American Society of Plumbing Engineers code changes. The first is the single stack venting system, also known as the Philadelphia single- stack. The Virginia public comment is one filled with nickel and dime nonsense. They start off by saying that there are already enough venting options. Based on that statement, we might as well stop researching plumbing systems and stop changing the code. Everything is fine, why add a new system? A rather absurd comment to make regarding any code change.
It is interesting that, throughout the comment, they never mention that a single-stack vent system doesn’t work. They are simply playing word games.
It is dangerous when an inspector group tries to be grammar experts, especially when dealing with a very technical system that has the support of the premier engineering society in the plumbing industry. The same ASPE change has already been accepted by IAPMO and PHCC in their codes.
The Standards PoliceThe other code change that Virginia opposes is the inclusion of siphonic roof drainage systems. This would include the reference to ASPE 45, the design standard for siphonic roof drainage systems.
Part of their justification for opposing the change is that the standards police don’t like ASPE 45. This has been one of the problems with ICC. They have standards police hidden away in a dark room casting decisions on national consensus standards that no one can challenge. Many times they are dead wrong. But for the diehards, that doesn’t matter. If the standards police rule, it must be right.
With regard to ASPE 45, one of the comments from the standards police is that the standard doesn’t prescribe a reporting format for test results. Duh! It is a design standard; there are no tests results. But the standards police have ruled.
If the ICC is to move forward in plumbing, they will need to drastically revise how they review standards. Having witnessed the numerous errors made in evaluating standards, the method is broken and needs fixing. There should be an open process where standards organizations can respond to the ICC standards police before ICC publishes a condemning incorrect note to a code change.
Two changes will deal with membranes that can be substituted for traps. The IPC has always required a trap. Newer products are being introduced that use a membrane to replace a trap. One change seeks to approve such a design, another seeks to specifically ban the use of membranes as trap substitutes.
Caught in the middle of the trap vs. membrane debate is a change to recognize the new standard for floor drain trap seal protection devices. These devices use a membrane to prevent evaporation of the trap seal. A comment from the Virginia inspector indicates that the acceptance of the new standard will allow membranes to replace traps. This is a convoluted comment since the standard specifically requires a trap.
The plumbing hearings will be on Monday and Tuesday, Sept. 22-23, 2008. If you can’t be present in Minneapolis, you can watch the simulcast on the ICC Web site. Check it out at www.iccsafe.org. This will give you the experience of attending the hearing and seeing what is discussed in the development of the International Plumbing Code.