Last month, ICC completed the technical code changes to the 2024 Edition of the International Plumbing Code (IPC), International Mechanical Code (IMC) and International Fuel Gas Code (IFGC). Yes, you read that correctly — the 2024 editions of these codes.
Your first thought might be, “This is 2021, how can we be done with the 2024 codes?” A more important thought is many states and local jurisdictions will take anywhere from one to three years to adopt the new code. If you are in a state like my home state of Indiana, it could take up to 10 years to adopt the new code.
The problem is by the time we get to 2024, the 2024 codes will not be new. The codes will be three years old — already out of date. In our fast-moving world, codes are moving slower.
What is disappointing is that the ICC process and deadlines result in many new standards not being accepted for three to six years. Many new product standards nearing completion will not be accepted in the 2024 ICC codes. When those standards miss the September 2021 deadline for being available, the first code they could appear in is the 2027 editions of the ICC Codes. That’s a delay of six years.
From a manufacturer’s perspective, that is six years of not being able to tell the plumbing and mechanical engineering community that they have an acceptable material, or product, listed in the IPC or IMC. That means that the manufacturer and the engineer can only use the product when approved as an alternative material. The other option to the manufacturer is to petition the states with a product approval process for acceptance of the new standard. It should be noted, however, that there are very few states with product approval processes.
IAPMO has a two-year code change process. There is still another year to complete a new standard and have the standard accepted in the Uniform Plumbing Code (UPC) or Uniform Mechanical Code (UMC). With a second year in the code change cycle, corrections can be made and reviewed by the same code committee. With ICC, you only get one shot before the code committee. Plus, the code committee changes every cycle. The second shot at ICC is before the entire membership. If you fail before the code committee, you have to convince two-thirds of the ICC voting membership to support your position or standard. That is a huge hurdle to overcome, and one that rarely occurs.
When ICC started in the early 1990s, the first code developed was the IPC. Promises were made that the code change process would be the “end all, be all.” ICC would be the most up-to-date set of codes because they are continuously updated. After the 1995 first International Plumbing Code was published, there were two code change cycles before the second publication in 1997. Bravo! The code was updated on an annual basis.
By the publication of the 2000 edition, three years later, there were only two code change cycles in the three-year period of time. That evolved to today, with a single code change cycle in a three-year period of time to update the technical contents of the code. Plus, that code change cycle occurs in the year that the previous editions of the code are published. The 2021 codes are currently being promoted by ICC as the latest and greatest. Yet, we are finalizing the technical content of the next edition in the same year. Does this make sense?
ICC will state there are two code change cycles. However, next year’s cycle is somewhat of a joke for the plumbing, mechanical and fuel gas codes since the only updates are to the existing standards in the code and the administrative chapter (Chapter 1), which is rarely adopted in its entirety.
If we go back to the legacy model codes, BOCA, ICBO and SBCCI, each organization had a code change cycle on an annual basis. Then there was movement to two code change cycles every three years, with the third year being the printing year.
This problem with ICC is not new. They have been discussing it and debating it for years. They have had numerous committees and think tank gatherings to try and solve the problem. The only formal change to take place so far has been to switch the International Energy Conservation Code from a governmentally developed code to a consensus code. In a way, they copied the IAPMO model, which switched the plumbing and mechanical codes to consensus code back in the 1990s.
The question is, “Should other ICC Codes be switched to the consensus process?” The plumbing, mechanical and fuel gas codes are prime for being developed through the consensus process. However, the ICC has many other codes that would fit into the consensus process, such as the Swimming Pool and Spa Code, Private Sewage Disposal Code, the Wildland-Urban Interface Code and the Zoning Code. These could be added to the Energy Conservation Code and Green Code as consensus documents.
But switching to the consensus process for some of the codes does not solve all of the problems with the ICC code change process. What needs to happen is a second shot at the code committees during the three-year cycle. Whether ICC converts to a two-year cycle, like IAPMO, or simply adds a second code change cycle — either would be an improvement, one that is necessary.
ICC needs to return to its roots when the first code was published in 1995. They need to find a better way of maintaining their codes to be as up-to-date as possible.
Because of publishing deadlines, I cannot report on the happenings at the ICC Annual Conference in Pittsburgh. At their annual meeting, ICC is supposed to announce its latest findings on the code change process. Will there be a change? Maybe. Will it be a significant change? Most of my colleagues do not believe that is possible. We can only hope that ICC sees the light.
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The views expressed here are strictly those of the author and do not necessarily represent PM Engineer or BNP Media.