The Federal Emergency Management Agency (FEMA) issued a document in March entitled, “Building Codes Strategy.” I finally received a copy in late April. I would encourage you to download the document and read what FEMA has to say.
One of the first things I noticed is the document says very little regarding plumbing, mechanical and fuel gas codes. That is not all that surprising since we normally associate FEMA with national disasters such as floods, earthquakes, hurricanes, tornados and wildfires. These events tend to line up more with building code and fire code requirements. Although, each one of the disasters mentioned does impact plumbing and mechanical systems. Furthermore, there are requirements in the plumbing and mechanical codes to mitigate losses for these disasters.
The FEMA report identifies its mission as, “Helping people before, during and after disasters.” FEMA also identified its core values as, “compassion, fairness, integrity and respect.”
One can easily understand why FEMA would promote strong building code requirements. If buildings can withstand the effects of a disaster, there is less federal money required for disaster relief. One study that is referenced claims there will be a savings of $132 billion in losses from natural disasters from 2016 to 2040 if the updated building code is adopted and enforced.
FEMA is promoting the latest editions of the ICC International Building Code, which have greater disaster mitigation requirements. Many of the newer requirements have been added to the 2021 edition of the International Building Code and the 2024 edition, which has yet to be published. As the report indicates, only a small percentage of the country has adopted the 2021 edition of the International Building Code.
As a part of advancing building codes, FEMA also added a statement regarding the impact of climate change. Normally, the building code does not provide many regulations that will impact climate change. The climate change regulations typically appear in the mechanical code, fuel gas code and energy code, with some appearing in the plumbing code. Many of the recent changes to the refrigerant requirements in the mechanical code will significantly reduce the impact on climate change. The energy code has already mandated high-efficiency fuel-burning appliances to also help with climate change.
Even with climate change identified, the only mention of plumbing, mechanical and fuel gas codes appears in the appendix. The energy code is never mentioned. However, in looking at the plumbing code and mechanical code reference, only the International Plumbing Code and International Mechanical Code are identified. My first thought was, “Does FEMA hate IAPMO?” Ok, hate is a strong word, “Does FEMA Dislike IAPMO?”
I had to contact my colleagues at IAPMO and ask them why FEMA does not mention the Uniform Plumbing Code or Uniform Mechanical Code. They did not have a good answer. They were wondering why FEMA left them out as well.
It is well established that FEMA has a love affair with ICC. That is based on FEMA’s ability to effectuate changes to the International Building Code regarding disaster mitigation. Over the years, flood, wind, seismic, fire and structural requirements have been beefed up thanks to FEMA.
While FEMA has a love affair with ICC, it does recognize NFPA when listing building codes and fire codes. The ICC International Building Code and ICC International Fire Code are listed, followed by NFPA 1 Fire Code and NFPA 5000 Building Construction and Safety Code.
The question becomes why is FEMA ignoring IAPMO? A larger percentage of the U.S. population has their plumbing and mechanical systems regulated by the IAPMO codes. FEMA cannot merely write them off as not being important. How does this fit within one of FEMA’s core values which is “fairness?”
While researching why FEMA did not include the IAPMO Uniform Plumbing Code and IAPMO Uniform Mechanical Code in the report, I discovered that the report is being used against IAPMO. There have been rumors passed around that based on the FEMA report, if a jurisdiction does not adopt the codes listed in the report, it may not receive federal funding, including disaster relief.
I call it a rumor because that is exactly what it is. If you read between the lines, the rumor implies that you should not adopt the IAPMO codes because they are not listed in the FEMA report. This is a very underhanded means of promoting one set of codes over another.
Federal funding and disaster relief are not based on the adoption of the ICC codes or NFPA codes. Can you imagine the federal government refusing federal funding or disaster relief because a state or local jurisdiction adopted the IAPMO Uniform Plumbing Code and IAPMO Uniform Mechanical Code?
Just take the State of California, which adopts both codes statewide. Can you imagine the federal government telling California, home of Speaker of the House Nancy Pelosi, that it will not receive federal funding or disaster relief? That is how ridiculous the rumor is.
To prevent these ugly rumors from continuing, a simple fix would be for FEMA to update its report and list all of the codes available in the United States, including the IAPMO Uniform Plumbing Code and IAPMO Uniform Mechanical Code. Clearly, someone screwed up at the federal level when they ignored the inclusion of IAPMO.
This mistake by FEMA reinforces why we would never want the federal government writing construction codes. Our government is bound to get it wrong. We have a much better system in this country with model code organizations promulgating and publishing the codes for states and local jurisdictions to adopt. The model code organizations are further supported by all of the standard development organizations (SDOs) that publish the necessary standards to support the construction codes.
In the meantime, let’s hope that FEMA corrects its error quickly. As it currently reads, the FEMA report is an insult to IAPMO and all its members that develop the Uniform Plumbing Code and Uniform Mechanical Code.
The views expressed here are strictly those of the author and do not necessarily represent PM Engineer or BNP Media.
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