More Analysis of Proposed ICC Code Changes
Last month I provided a brief overview of some of the code changes that will be considered at the International Code Council Hearing in Baltimore the first week of November. Due to space constraints, I could not address all of the pertinent code changes to the plumbing and mechanical engineering community. So here is the rest of the story.
Several for Fixtures and Hot WaterA series of changes will impact showers, bathtubs, and hot water temperatures. In an effort to conserve water, a change proposes to limit the flow rate into a shower to 2.5 gpm for every 2,600 square inches. One of the immediate effects of this change would be the elimination of multiple shower heads. The intent of the water conservation requirements always has been to limit each shower user to a flow of 2.5 gpm.
Should a bathtub have an overflow? This question arose regarding the International Plumbing Code (IPC) and the International Residential Code (IRC). The IRC clearly states that an overflow is required, while the IPC references a standard that identifies the location of an overflow without mandating the overflow. A proposed change would require an overflow in both codes.
Hot water temperature would have to be regulated through a master thermostatic mixing valve in one proposed change. The change would mandate thermostatic mixing valves for all hot water that supplies bathing or washing and set a maximum temperature of 120°F.
The other series of changes to hot water deal with recirculation. Currently, the IPC requires hot water recirculation, or temperature maintenance, when the piping exceeds 100 feet from the source of hot water. One change proposes to lower this to 40 feet, the other to 50 feet.
Two From ASPEASPE submitted changes, two of which have appeared in the past. One change would add requirements for single stack venting. This venting method is currently listed in the Uniform Plumbing Code and the National Standard Plumbing Code. This is an area where the International Plumbing Code has not kept up with the other codes. While the Committee approved the change during the last cycle, a one-man crusade kept the change from gaining final approval. Perhaps this cycle, the ICC membership will see the error in their ways.
The other ASPE code change of note is the addition of ASPE 45, which regulates the design of siphonic roof drainage systems. Unfortunately, this standard is difficult to understand for the non-engineer or designer. However, it is necessary to add this standard so the code enforcement community has a tool to use for approving siphonic roof drainage systems.
Reclaimed WaterOne of the areas lacking in the IPC is a reclaimed water section. The only provisions in the IPC appear in an appendix on greywater that is very limited and contains inadequate requirements for reclaimed water systems. Furthermore, it only addresses greywater. Missing are full reclaimed water systems using black water, groundwater or rainwater. The appendix also only permits irrigation by subsurface means. There are no provisions for the spraying of reclaimed water for landscaping.
A proposed code change would strike the appendix and move it into the body of the code as Chapter 13. While noble in its attempt, it would legitimize a poorly worded appendix that probably should simply be deleted.
One of the more comical requirements in the appendix is the dyeing of greywater with food-grade vegetable dye that is blue or green in color. All of the modern day requirements for pipe and system identification are missing. It simply relies on dye, a practice that was abandoned years ago.
What the IPC needs is a well-written new chapter on reclaimed water. Such a chapter could include the necessary health and safety requirements for any reclaimed water section. You can’t simply take greywater, throw in some chloride and hope that the system is safe.
Anytime you hear the words “reclaimed water” you should be scared. If done incorrectly, we introduce unsafe water into the building. The entire premise of the plumbing industry is to protect the health of the nation. That has been done by the use of clean water. We need to continue to use clean water - whether it is reclaimed, from a well or from the public supply.
Any reclaimed water system chapter needs to address the requirements for treatment, water quality, periodic testing, pipe identification, and periodic inspection. There must also be requirements to prevent any inadvertent use of the reclaimed water.
The ICC is creating a committee to develop these requirements for plumbing systems. Any reclaimed water requirements are better placed with this committee than with a poorly written code change.
Piping & VentingThere are very few code changes of any significance to the Fuel Gas Code. One that will impact design professionals is a change to the gas piping manifold location, typically used when CSST is installed. Currently, the code allows the shut off valve on the manifold to serve as the appliance shut off valve if the manifold is located within 50 feet of the appliance.
The change would also require the appliance to be on the same floor level as the manifold. This doesn’t make much sense when you locate a manifold on a basement level and there are appliances on the first level. If the valves are clearly identified, who cares what level the manifold is on?
In the Mechanical Code (IMC), there is a change to delete the hydronic piping requirements and replace them with a reference to ASME B31.9. This standard regulates piping requirements for building service piping. It would appear that the better change would be to reference ASME B31.9, while leaving intact the current piping requirements. This would allow the option for choosing a piping material listed in either the IMC or ASME standard.
In the venting section, there is a proposal to add the new ASSE 1049 standard, which regulates AAVs for chemical waste systems. This change would be a major help in the design of laboratory waste systems.
The plumbing code change hearings begin on Nov. 4, 2009, in Baltimore. They are followed by the mechanical and fuel gas code change hearings. The code changes can be downloaded for review at www.iccsafe.org. I hope to see some of you at the hearings.