With the first in-person code hearing since the start of the COVID-19 pandemic, there was a question of how many people would show up for the ICC meeting. Walking in on the first morning, it was shocking to see a full room. ICC requested attendees be fully vaccinated or wear masks if not fully vaccinated. On the first day, it appeared about 10% of the crowd was wearing masks. That’s not including the ICC staff, where every staff member was required to wear a mask. By the second day, the mask-wearing more than doubled, though still a minority of people present.

Public comments to the International Plumbing Code were the third group to be considered. There was very little controversy for the Pool and spa Code and the Fuel Gas Code. The first plumbing code change was regarding updating the fixture unit values for residential and single-user toilet rooms. The change was based on a study by Tom Konen, P.E., who has since passed away. As the proponent of the code change, I was asked to submit a public comment. The Plumbing Code Committee rejected the change, stating they did not like the wording in the proposal but liked the concept.

The public comment modified text in the change based on the committee’s request. After presenting the comment, a colleague from the National Association of Home Builders (NAHB) testified in support of the change. No one spoke in opposition to the comment or overall code change. Normally, when there is no opposition, a code change is accepted during the voting. Because the committee voted to disapprove the code change, the first vote at the hearing was to overturn the committee’s recommendation. Hence, if you supported the public comment, the first vote was to oppose the committee’s recommendation.


You are first voting no, to eventually vote yes to approve. This often confuses the ICC voting membership.


The vote was 63 to 62 for the committee’s recommendation to disapprove the first code change. That was rather perplexing since no one spoke in opposition to the concept. Everyone who spoke supported the change in fixture unit values.

However, since the members simply vote yay or nay, you have no idea why the code change was not accepted. This is one of the strange occurrences at the ICC hearings. No reason has to be given by the voting members as to why they are opposing a change. Once the vote is taken, the action is final. The modification proposed in the public comment simply dies, with no reason given.


The debate over flow

During the first hearings this past spring, there was a difference created regarding the flow rate of a showerhead. The Plumbing Code Committee approved a change to lower the showerhead flow rate to 2.0 gpm. The second part of the change was to the plumbing section of the Residential Code. The Residential Plumbing Committee rejected the change, leaving the showerhead flow rate at 2.5 gpm.

There were public comments submitted to both code changes. The public comment to the plumbing code change was to disapprove the change, resulting in the flow rate remaining 2.5 gpm. The public comment to the Residential Code was to overturn the committee and lower the flow rate to 2.0 gpm.

One would think the two codes should be consistent regarding showerhead flow rate. The first change considered was to the Plumbing Code. There was extensive testimony, both for and against, lowering the flow rate to 2.0 gpm. Those opposed to the change argued that the user should have options. The claim was that lowering the flow rate is green and should only be located in an optional reach code. Those in support pointed out water savings, overwhelming acceptance of 2.0 gpm showerheads, and the need for the code to regulate flow rates.

The vote for the Plumbing Code supported the code committee, thus approving the lower shower head flow rate of 2.0 gpm. The very next vote was to the Residential Code. However, the outcome of that vote was to support the committee’s recommendation to reject the code change. Thus, if the membership vote is upheld, the two codes would have different requirements for showerheads.

Additional code changes

A code change of interest to the plumbing engineering community was an allowance not requiring a tenant shutoff valve on the water distribution system when the building is four or more stories in height. This change was in response to the new requirement in the 2021 IPC that mandates a tenant shutoff valve that isolates all of the water in a tenant space. This requirement added extensive cost in the design of water distribution systems in taller buildings that are piped vertically.

The committee disapproved the code change, stating that requiring a tenant shutoff valve for buildings three stories or less in height was arbitrary. The public comment responded, indicating that when a building is four stories or more, plumbing engineers switch from horizontal water piping to vertical piping. The requirement for a tenant shutoff valve basically prevents vertical piping arrangements. Because the code change was disapproved, it required two-thirds approval at the hearing to move forward. The code change did receive a two-thirds majority for the modified text, removing the requirement for a tenant shutoff valve in buildings four or more stories in height.

There was a series of code changes addressing adult changing stations. The primary changes were to the Building Code to mandate adult changing stations for certain buildings. The change to the Plumbing Code supplemented the Building Code requirements by listing the allowance of adult changing stations when they are not required. The change would permit adult changing stations to be installed in multiple occupant toilet rooms or bathrooms as well as in a separate room, such as a nurse’s room in a school. Without such an allowance, the location of any adult changing station would be limited by the Building Code to being in single-occupant toilet rooms or family assist toilet rooms.

The committee originally rejected the code change since they did not believe a floor drain should be required for the room. They also did not like the text describing a separate room allowance. The public comment responded by removing the requirement for a floor drain and revising the text identifying a separate room allowance.

During the testimony, one architect objected to the change because there is no standard identifying the size, shape and configuration of an adult changing station. While that is true, there was no reference in the code change to requirements for an adult changing station. The change merely identified where they may be located. Hence, the opposition's testimony was misplaced. Furthermore, the testifier supported the Building Code changes adding requirements for adult changing stations. The membership voted to support the committee’s recommendation to reject the code change.

As reported in last month’s column, it was hoped there would be an announcement at the ICC Annual Meeting regarding major changes to the code change process. That announcement never came. However, colleagues at ICC informed me that a major announcement will be made within the next few months. I’ll keep you posted.


The views expressed here are strictly those of the author and do not necessarily represent PM Engineer or BNP Media.