The one cry we hear from building owners is, “There are never enough shutoff valves where you need them.”
What that directly translates to is, “We had a problem with a water leak and it would have been nice to have had the shutoff right next to the leak so we could isolate the system.”
Plumbing engineers add shutoff valves where required by code and where they appear logical to install. Engineers are known for specifying more valves than are required by code. However, those valves are easily justified.
Without fail, when there is a major leak in a building, the valve is not located adjacent to the leak. The correct shutoff valve has to be located to isolate that section of the water distribution system. Of course, the time required to find the shutoff valve results in additional water leading to additional damage.
The complaint of not enough shutoff valves is also heard by the plumbing inspectors. When there is a problem, quite often the plumbing inspector gets called in. The building owner will normally complain that the code should have required more shutoff valves.
During the current ICC code change cycle to develop the 2021 International Plumbing Code, one plumbing inspector submitted a code change to require a shutoff valve to isolate a tenant’s water supply. His logical thinking was that it wouldn’t be that difficult to add one more valve in each tenant space to make it easy to isolate the water supply. At first glance, it may not appear all that difficult to do.
This inspector is a good friend. At the first hearing, we spoke about his code change to add a valve for each tenant space. I let him know that I didn’t like the change, but I wouldn’t testify against it. I said there would probably be plenty of testimony against the code change. He said that he didn’t expect the Plumbing Code Committee to approve his change.
Fast forward to the discussion on the code change. Lo and behold, the Plumbing Code Committee voted to recommend approval of the change. With this unexpected result, the phone calls and the emails started to fly regarding how bad this code change was.
Two people submitted public comments, including myself. Both public comments offered a modification to reduce the pain of accepting the code change. My public comment would exclude the requirement for a main tenant shutoff valve provided each fixture had a shutoff valve. That seemed like a reasonable compromise.
As I explained to my colleague, when we have buildings four or more stories in height, we tend to switch from horizontal piping to vertical piping. We call this high-rise plumbing design, but it starts in buildings that may not qualify as a high-rise building. What it means are multiple risers throughout the building.
If there are four toilet rooms in a tenant space, there will be four separate risers to connect to the plumbing fixtures. If the toilet rooms back up to the neighboring tenant, which often is the case, we feed the water supply to both tenants from a single water pipe.
By requiring a main tenant shutoff valve, you can no longer pipe vertically or back to back. There would have to be a separate water line that serves all the fixtures in a tenant space.
When this code change was addressed at the final action hearing, the ICC membership heard of the hardship regarding vertical or high-piping installations. They also heard about the inability to install back-to-back fixture arrangements in separate tenant spaces.
The problem with the public comment was that it required a two-thirds affirmative vote to be approved. When the vote was taken for each proposed modification, a two-thirds majority was not obtained. The only remaining recourse was to make a motion to deny the entire change. At the ICC code hearings, a motion to deny is always in order.
The motion to deny passed by a slim three-vote margin. However, that is not the final action. Because the vote changed the Plumbing Code Committee’s recommendation, the code change was up for online voting by the ICC membership.
The online voting reversed the action taken at the final ICC hearing. The motion to deny did not receive a simple majority. That means the Plumbing Code Committee’s action for approval is the end result. Thus, the 2021 ICC International Plumbing Code will require a main shutoff valve for each tenant space.
This single code change just significantly increased the cost of installing a plumbing system. Under the new provision, high-rise plumbing design as we know it will not be permitted. Each tenant space will need to be piped independently from adjacent tenant spaces. If there is a central hot water supply, there will be a requirement for two main tenant shutoff valves — one for the cold and one for the hot. Downstream of these valves, all the piping will supply only that tenant space.
For many years, ICC has been promoting themselves against IAPMO as having a plumbing code that allows lower-cost plumbing installations. The claim, whether true or not, is that a plumbing system installed in accordance with the International Plumbing Code is less expensive than a plumbing system installed in accordance with the Uniform Plumbing Code.
That has all shifted with one simple code change. By requiring each tenant space to have a main shutoff valve, the ICC International Plumbing Code 2021 will require a far more expensive plumbing installation than the Uniform Plumbing Code. All of a sudden, the mantra used by ICC will come back to haunt them when its plumbing code results in a more expensive installation.
We may see a switch to the Uniform Plumbing Code by various states for economic reasons. Wouldn’t that be different?
Sometimes code changes that seem like a good idea, yet provide no increase in protection of public health and safety, are better off not being proposed. The plumbing code is a document for protecting public health and safety, not for providing an expensive convenience to a building owner. The problem for ICC is that it will have to wait three years to correct this major blunder.
This article was originally titled “Valves, valves and more valves” in the March 2019 print edition of PM Engineer.