The process to develop the 2012 International Codes is in full swing.

Due to a change in the International Code Council (ICC) procedures, there will only be one code change cycle every three years for each edition of the code. That means that every code change that will impact the 2012 codes has already been submitted.

Sprinkler and Plumbing Changes

Not surprisingly, homebuilders have a code change submitted to remove the mandatory requirements for residential sprinklers. There really is no justification for such a change, other than that 3,000 fire deaths a year is an acceptable number for affordable housing. Of course, the code change leaves off the first part of that statement and just uses the “affordable housing” mantra.

Many expect this code change to be approved by the Residential Code Change Committee, which is dominated by NAHB representatives. It would take a clean sweep of the non-NAHB representatives to defeat the code change. That doesn’t seem likely, but stranger things have happened.

The interesting aspect of this code change is that, if the Committee approves it at the Final Hearing, it would only take a 50% vote to defeat the code change. At last year’s meeting, it took a two-thirds vote to pass the code change.

If the Committee recommends denial of the code change, it would require two-thirds of the ICC membership to have it approved at the Final Hearing. That seems very unlikely. So, perhaps the Committee will see the errors of their ways from last cycle and vote to reject the change this year.

On the plumbing side, once again there are changes impacting many areas of the code. One of the changes to Chapter 3 proposes to delete the table regarding listing requirements. Currently, the International Plumbing Code (IPC) only requires certain products to be listed, while other products only have to be tested to initially qualify. The difference is in the cost of maintaining the annual listing to the manufacturer.

In eliminating the listing table, the proposed change would require all plumbing products to be listed. This is currently what is required in the Uniform Plumbing Code.

A very interesting code change will impact the testing required for sanitary and storm drainage systems. Basically, the change would require the drainage system to be pressure tested to the maximum pressure that may be anticipated with the drainage pipe plugged at the lowest level. This change would have a significant impact on almost all storm drainage systems. It would also impact sanitary drainage systems that have no connections on lower floors.

Currently the code requires sanitary and storm drainage systems be tested to a 10-foot head pressure. The proposed requirements would increase this pressure significantly for many systems.

My first thought was how this change would impact the Willis Tower (formerly known as the Sears Tower) in Chicago. The storm drainage pipe from the roof descends 1,450 feet. Filling the pipe to the roof to test for leaks results in a pressure of 627 psi at the base. There aren’t any DWV piping systems that can withstand that pressure. I wouldn’t want to be around when they conduct a test like that.

While there may be merit to testing certain systems to a higher pressure, assuming a blockage is not an appropriate justification for testing.

Fixtures and Hot Water Distribution

Every code change cycle there are proposals to the fixture requirements. This cycle one of the changes will attempt to modify the ratio for the number of fixtures. Similar changes have been attempted in the past. It is always a question of having the technical data to support the change.

Another change proposes to eliminate the requirement for customer facilities when there is an area less than 300 square feet. This makes perfect sense since most of these types of facilities are take-out places. You cannot get many customers into 300 square feet.

A change that I really like would allow single-occupant toilet rooms in small locations to all be identified with the family assist sign, often miscalled the “unisex facility” sign. The idea is to allow either a man or a woman to use the toilet room when it is unoccupied.

There still would be a minimum of two toilet rooms required; it would simply allow for better use of the facilities. If you think about it, this is how we use the facilities on an airplane. There isn’t one room reserved for women and another for men.

Drinking fountains for small spaces will be discussed again. Currently, the IPC requires a drinking fountain in every small mercantile or business occupancy, regardless of building or space size. When there is a strip center, every unit would require a drinking fountain. This change would allow bottled water or a drink dispenser to count for a drinking fountain in these small spaces.

There is a change regarding the protective covers for traps and water risers on accessible plumbing fixtures. The change would require these protective covers to meet the ASME standard. The standard is not yet complete, but should be available before the final hearing. It should be noted that there are no requirements for flame spread and smoke developed rating of these protective covers.

A proposed change to the bathtub section would clarify that a bathtub must have an overflow. The IPC is not clear as to whether this is required. However, the referenced standards require an overflow.

I submitted a change regarding the thickness of a shower pan. The IPC requires a shower pan to be a minimum of 40 mil. However, the code references a performance standard for testing these membranes. I proposed deleting the minimum thickness and relying solely on the standard.

Another shower and bathtub change would limit the amount of water to a shower based on area. Only 2-1/2 gpm of water would be permitted for a shower or bathtub, up to an area of 2600 square inches. This change is intended to combat the inappropriate use of dual showerheads. Some showers have added more than two showerheads in an effort to defeat the Federal water conservation requirements. This would close a loophole used by many.

The design of hot water distribution systems may be impacted by a number of changes. One change proposes to limit the temperature of hot water distributed throughout a building to 120°F. The water heater could be set higher. However, a thermostatic mixing valve would have to be located downstream of the water heater to limit the temperature.

A change to the energy code would require all hot water below grade to be insulated. Finally, a proposed change would require hot water recirculation when the length of the hot water pipe exceeds 40 feet.

ASPE once again submitted a code change on single stack venting systems and siphonic roof drainage systems. Both changes were defeated at the final hearing last cycle by late night shenanigans.

The grey water appendix in the IPC is proposed to be moved to the body of the code. While this is a good idea, the appendix is in dire need of updating. The IPC grey water requirements need to be completely updated. There also needs to be a section on reclaimed water. To accomplish these changes requires more than the simple move of an updated appendix.

The plumbing code change hearing begins on Wednesday, Nov. 4, 2009, in Baltimore. The code changes can be downloaded for review at I hope to see some of you at the code hearings.