Julius Ballanco: The cured-in-place debate
Legionella also a key discussion topic at IAPMO hearings.
When you serve on the IAPMO Plumbing Technical Committee, you try to predict what subject matter will be the hot topic for the hearings.
Having reviewed all the changes, there didn’t seem to be any subject matter that stood out as a controversial issue. Of course, once the meeting starts, things can change quickly. That’s what occurred in Denver last month.
One of the hottest issues discussed was cured-in-place piping systems. The Uniform Plumbing Code currently identifies cured-in-place piping systems as trenchless technology. The technology is only permitted for rehabilitating existing sewer systems. The code further prohibits the use of this technology to repair or rehabilitate cast-iron soil pipe.
There were four major issues presented by the cured-in-place piping industry. They first wanted to remove the restriction on using the technology only for cast-iron soil pipe. The next change would convert the term “trenchless technology” to “cured-in-place piping systems.” This was followed by a proposal to allow small-bore vacuum excavation saddle tees for cleanouts. Finally, three new standards were proposed for cured-in-place piping systems.
The lineup of speakers on these issues surprised many of the Technical Committee members. All three changes had previously been recommended for rejection. The testimony on rehabilitating cast-iron soil pipe pitted two industries against one another. The cast-iron soil pipe industry kept reading sections from the standards that prohibit cast iron from being repaired. The cured-in-place industry kept pointing out that the cast-iron pipe is not repaired; a new pipe is formed inside the cast-iron pipe.
While it appeared to be a matter of semantics, the cast-iron industry continued to push for maintaining the current restrictions. The TC eventually voted to reject the change, referencing the concerns of the cast-iron industry.
When the name change was discussed, TC members brought up the concern that removing trenchless technology would imply that burst-in-place technology would become prohibited since it doesn’t fall into the category of cured-in-place. There was no real response to that issue. As a result, the TC rejected the change.
After an hour of testimony on the first two issues, the third issue on small-bore vacuum excavation saddle tees resulted in disagreement between the various cured-in-place representatives. Some supported this technology, others claimed it was proprietary. The TC raised the issue of directional fittings for using the technology for a cleanout. The proponents indicated that contractors have been able to direct the snake in the direction of flow using these connections. One TC member read the code requirement for directional fittings on cleanout extensions. This killed the concept since the proponent admitted that the connection was not directional. The TC rejected the change based on the lack of directional fittings.
The final issue was held to the end of the hearing. The testimony on the proposed change, once again, started with disagreement between the various cured-in-place representatives with some claiming that the proposal would result in mandating a proprietary system. The others responded that anyone could sign up to use the proprietary system.
When it looked like the discussion was going to extend for another hour, the TC changed the motion to approve the three new standards as optional standards for use for trenchless technology. The modification would accept the standards, which were all considered good standards, while not mandating any of them. After this motion and reasoning was presented, the cured-in-place representatives were dumbfounded. They weren’t sure what happened, and they didn’t know if they should continue to testify. The modification actually satisfied both sides.
It was suggested that they should stop testifying since there was nothing new to discuss. Once they sat down, the TC approved the modification.
Another major issue discussed was the three proposals to add a new appendix on Legionella. The Legionella Task Group, which I chaired, submitted two changes on the new appendix. The one favored by the Task Group included a section on documents required to be submitted, and commissioning of a new or renovated system. The other change removed those two sections, but included the remainder of the requirements.
The third change, submitted by a member of the Task Group, added a section on disinfection, listing various methods identified as a means of reducing or killing Legionella bacteria, according to the proponent. The change also removed the documents and commissioning requirements.
Labor representatives moved to hear the third change first. Then they proposed a modification to add an abbreviated section on document submittal. The document submittal language was taken from the first change with the removal of the laundry list of documents required to be submitted.
There was extensive discussion on the need for the new appendix, thus accepting any one of the three changes. However, there were others who thought the addition of the appendix was unnecessary and not technically accurate. Some of the opposition voiced concerns regarding the definitions that were included with the appendix. There was sentiment that other terms should be used throughout the appendix.
The opposition soon realized that the majority of the TC wanted the new appendix; it was just a matter of which change to accept. With the strong support from labor for the third change, this was voted for approval by the TC. The other two changes were rejected, stating a preference for change number three.
While some questioned the need for the disinfection methods listed in the third change, everyone considered the addition of the appendix a major victory for the plumbing industry and the Uniform Plumbing Code. The new table within the appendix will list Legionella growth potential and scald potential temperatures.
Following the meeting in Denver, the TC is required to complete an electronic ballot. The electronic vote requires a 2/3 majority for each motion made during the Denver meeting. The results will not be available until sometime in June.
Next month, I’ll continue to cover the other issues and code changes addressed in the plumbing and mechanical codes.