IAPMO Defends Its Code Development Process

Dear Julius Ballanco:
As IAPMO’s Standards Council Secretary, I wish to convey IAPMO’s concern with your August PM Engineer column entitled “One Step Forward, Two Steps Back”. Our concern results not from the expression of your personal opinions with regard to the code changes you advocate, but rather, we are profoundly disappointed that you have chosen to criticize the ANSI consensus process itself, which IAPMO champions. Moreover, in the course of your criticism of the process itself, several misstatements of fact were made which we desire to correct.

First and foremost, your article criticizes the central premise of the IAPMO Code Development Process, which is that all Committee actions require consensus to be established by not less than a two-thirds majority of voting committee members on a written ballot.

Although you imply that a simple majority vote would be preferred and assert that a two-thirds majority requirement is a “unique twist in the procedures,” the ANSI Essential Requirements specifically prohibit achieving consensus by simple majority and defines consensus as “substantial agreement has been reached by directly and materially affected interests. This signifies the concurrence of more than a simple majority but not necessarily unanimity.”

Thus, any developer who desires to develop an American National Standard must achieve consensus by more than a simple majority, and IAPMO’s Regulations contain the most widely accepted method of achieving consensus, which is a requirement that at least two-thirds of the voting Committee members agree upon an action. While this approach may be frustrating to the advocate of a position which is able to achieve a simple majority but not two-thirds, it is nonetheless a central premise of the ANSI consensus process and one which IAPMO embraces.

Your article does correctly note the existence of “checks and balances” in the IAPMO code development process through the inclusion of a formal appeals process, which is another hallmark of the ANSI consensus process. However, it is not correct to state that “All the items that were reversed by the TC are automatically appealed to the Standards Council.” Please permit me to explain.

As a member of the Plumbing Technical Committee, you are aware that we are in the final stages of the development of the 2009 edition of the Uniform Plumbing Code. At the Association Technical Meeting Convention, which will take place on Sept. 30 and Oct. 1 in Atlanta, the IAPMO membership will have the opportunity to address the actions taken by the committee as published in the Report on Proposals and Report on Comments.

If the membership votes to take an action different than that of the Technical Committee, then the Technical Committee must vote on whether they agree with the proposed change of the membership. This vote takes place via written ballot following the conclusion of the Convention.

If the Technical Committee agrees with the membership, then the membership’s language is considered a recommendation of the TC in favor of the amendments. Conversely, if the Technical Committee does not agree with the membership, then and only then, is an automatic appeal placed on the agenda of the Standards Council and any party may advocate their position either in writing or in person before the Council. All appeals will be heard by the Council when they meet on Nov. 13 – 14, 2008, at The IAPMO Group World Headquarters in Ontario, CA.

I would very much appreciate your willingness to publish this letter in order to ensure that there is no misunderstanding with regard to IAPMO’s code development process.

Thank you,
Gabriella Davis
Secretary, IAPMO Standards Council
Ontario, CA

Gravity Tanks as Organic Design

Recently I came across an older article by Mark Bromann (March 2007) about wooden gravity tanks in PM Engineer that I really enjoyed. I've always thought that if these structures were out in the countryside with barns and silos they would be better appreciated as the beautiful examples of form-following-function design that they are.

One subtle touch I've always enjoyed is the way the spacing of the steel hoops reflects the water pressure inside the tank-proportional to its depth. Now that's Organic Design!

Thanks for the article. It will be sad to see these things slowly disappear in years to come, but I'm glad others are aware of their virtues.

Gus Dudley