Julius Ballanco: Are composting toilets plumbing?
Plus many other proposed code changes!
At the IAPMO Plumbing Technical Committee meeting in Denver, Colorado, there were many changes proposed to add requirements from the IAPMO WE-Stand to the appendix of the Uniform Plumbing Code.
You would think that adding requirements from one document to another would be automatic. However, that is rarely the case. The Plumbing TC often has a different opinion regarding water conservation provisions than the WE-Stand Committee.
There were three code changes dealing with composting toilets. The question that arises for these code changes is, “Are composting toilets plumbing?”
When you hear the word “toilet,” you immediately think plumbing. However, a TC member pointed out that composting toilets do not fit within the UPC definition of plumbing system, nor do composting toilets fall within the definition of plumbing fixture. The scope of the code clearly states that it regulates plumbing systems. If composting toilets cannot fit within the definition of plumbing systems, requirements cannot technically be added to the code to regulate such installations.
The TC rejected all three code changes on composting toilets, based on the scope of the code. A change to the scope would be necessary before the UPC could include requirements on composting toilets.
Composting toilet requirements remain a part of the WE-Stand document. The requirements for composting toilets are quite good, and still can be used by engineers. The reference would be to the standard, rather than the UPC.
There were three new ASSE standards on water heaters proposed to be added to the code. As chair of two of the ASSE working groups on water heater standards, I submitted the public comment to add the standards. As proponents, I introduced the standards and the requirements, then sat and allowed the TC and others to discuss the changes.
The three standards are ASSE 1082, ASSE 1084 and ASSE 1085. The simplest water heater standard to accept was ASSE 1085, which regulates water heaters for emergency fixtures. ASSE 1085 limits the outlet temperature to a maximum of 100° F, with the temperature typically in the range of 85° F. The change, which was accepted, will allow either an ASSE 1071 thermostatic mixing valve or an ASSE 1085 water heater for emergency showers, eyewash and facewash fixtures.
ASSE 1082 and ASSE 1084 received considerably more discussion. ASSE 1082 is listed as being equivalent to an ASSE 1017 thermostatic mixing valve, while ASSE 1084 is listed as being equivalent to an ASSE 1070 valve. However, the ASSE working group went further with ASSE 1084, adding requirements consistent with both ASSE 1017 and ASSE 1070. What that means is an ASSE 1084 water heater has temperature control similar to a thermostatic mixing valve, and also has end-point protection by reducing the flow when the temperature exceeds 120° F. The end-point protection from excessive hot water temperatures is all that is required in ASSE 1070.
The TC accepted ASSE 1084. Rather than rejecting ASSE 1082 completely, the TC added the standard as a referenced standard that can be used by the approval of the authority having jurisdiction. If you can keep all of the numbers and comparisons straight, you can understand the action taken by the TC.
Hybrid urinal name change?
There was a proposal to change the name of “hybrid urinal” to “urinals with drain cleansing action.” These are nonwater urinals that can periodically clean the trap area with a flush of water. A part of the change included an exemption for urinals with drain cleansing action from having an upstream fixture using water, as well as, a water supply rough-in for a possible future change of the fixture.
The name change was not controversial with the TC. However, the exemption from an upstream water-using fixture and a roughed-in water supply was not well-received. The TC modified the change to strike the exemption. They added another change to the definition, identifying a urinal with drain-cleansing action as first being identified as a nonwater urinal. By modifying the definition, the UPC was made clear that an upstream fixture and water rough-in will always be required for this style of urinals.
A change was submitted by a plumbing engineer proposing to lower the drainage pipe size for public lavatories. Originally, the change was rejected by the TC because of the need for additional clarity in the requirements. The public comment simplified the requirement by allowing a maximum of 8 public lavatories to connect to a 1 1/2-inch drain. The proponent pointed out that, with a flow rate of 0.5 gpm from a public lavatory faucet, a 2-inch drain would result in additional stoppages because of inadequate flow in the piping. This change is consistent with the reevaluation of drainage pipe sizing with reduced water usage.
There was a proposal to extend the distance from trap to vent, based on the research done at National Bureau of Standards. The supporting documentation provides exceptional information on the work by Dr. Roy Hunter and John French regarding trap siphonage. Even with the supporting documentation, the TC rejected the code change.
I submitted two of the code changes to the storm drainage system requirements. The first change would prohibit the secondary roof drainage opening to be located under the primary roof drain strainer. The reason for prohibiting the secondary drain from being located under the primary roof drain strainer is to coordinate the UPC with the building code and ASCE 7. Both the Building Code and ASCE 7 identify a blockage of the primary drain as being at the strainer. Thus, if the secondary drain is located under the primary drain strainer, the secondary drain would not be considered an emergency or secondary drain by the building code or ASCE 7.
During the discussion, some TC members indicated that they would prefer to require a minimum separation between the primary and secondary drain. While the roof drain standard allows a combined primary and secondary drain, some thought that such a drain should not be permitted. Although the code change had nothing to do with prohibiting a combined drain, the TC voted to reject the public comment.
The other storm drainage code change would allow the design of the storm drainage system to be in accordance with the methodology published by the ASPE Research Foundation. Rather than mandating, the sizing method was identified as an alternative sizing method.
The TC indicated that the ASPE sizing method is already permitted under the engineered design section. As a result, they didn’t see a need to add the sizing method to the UPC. The public comment was rejected.
The Report on Comments to the UPC is scheduled to be published on the IAPMO website at the end of August. The final discussion on the proposed changes will take place at the IAPMO annual conference in Reno, Nevada, the last week of September.