IPC Code Changes, Part 3

A continued summary of significant revisions of the International Plumbing Code.

This is the continuation of a series of columns covering only the code changes that were approved as submitted from 2018 to the 2021 International Plumbing Code (IPC) change hearings. There were many code change proposals and two rounds of code hearings for the 2018 IPC. The following is a summary of the significant code changes that were approved during the International Code Council hearings in Columbus, Ohio, and Richmond, Va. 

These code changes will appear in the 2021 edition of the International Plumbing Code, which will soon be published and available for jurisdictions to consider for adoption. Because it is possible for modifications to the proposed text be made from the floor during the code hearing process, and where there were multiple code changes to the same section which will require ICC staff to develop the final text for a given code section incorporating all the changes, I recommend you refer to the 2021 IPC for the final version of any code changes reported on hereinafter. 

Proposed additions are underlined and deletions are struck through. They are followed by the proponents’ published reason statements, along with any of my comments as noted.

The following 2018 International Plumbing Code sections were added or modified for publication in the 2021 edition of the IPC.

Code Change: 2018 IPC Section 405.4.3, Bidet Water Temperature

Revise as follows:

408.3 Bidet water temperature. 

The discharge water temperature from a bidet fitting shall be limited to not greater than 110°F (43°C) by a water-temperature-limiting device conforming to ASSE 1070/ASME A112.1070/CSA B125.70 or CSA B125.3.

Proponent’s reason statement: In June 2017, the Canadian Standards Association’s CSA B125 Committee completed the project that removed the automatic compensating valve requirements from CSA B125.3 standard. The reason for this was the publication of harmonized ASSE 1070/ASME A112.1070/CSA B125.70 standard. 

Code Change: 2018 IPC Section 410.1, Drinking Fountain, Approval

Revise as follows:

410.1 Approval. 

Drinking fountains shall conform to ASME A112.19.1/CSA B45.2 or ASME A112.19.2/CSA B45.1, or ASME A112.19.3/CSA B45.4 and water coolers shall conform to ASHRAE 18. Drinking fountains, water coolers and water dispensers shall conform to NSF 61, Section 9. Electrically operated, refrigerated drinking water coolers and water dispensers shall be listed and labeled in accordance with UL 399.

Proponent’s reason statement: The current standards reference ceramic, enameled cast iron and enameled steel plumbing fixtures. The additional standard addresses stainless-steel plumbing fixtures. The stainless-steel plumbing fixture standard is already referenced in the IPC for other fixtures.

This proposal was submitted by the ICC Plumbing/Mechanical/Gas Code Action Committee (PMG CAC). The PMG CAC was established by the ICC board of directors to pursue opportunities to improve and enhance the international codes or portions thereof that were under the purview of the PMG CAC. 

In 2017, the PMG CAC held one face-to-face meeting and 11 conference call meetings. Numerous interested parties including me, attended the committee meeting and conference calls and offered their input. 

Code Change: IBC Section 202, 1109.5, 2902.7, High-Low Drinking Fountains, Definition and Substitution 

This was a two-part code change, heard by the Plumbing Code Committee and the Building Code Committee. 

Revise as follows:

2018 to 2021 International Building Code

Part 1. Add new definition as follows:

WATER DISPENSER.A plumbing fixture that is manually controlled by the user for the purpose of dispensing potable drinking water into a receptacle such as a cup, glass or bottle. Such fixture is connected to the potable water distribution system of the premises. This definition includes a freestanding apparatus for the same purpose that is not connected to the potable water distribution system and that is supplied with potable water from a container, bottle or reservoir.

Part 2. Revise as follows:

1109.5 Drinking High and low drinking fountains. 

Where drinking fountains are provided on an exterior site, on a floor or within a secured area, the drinking fountains shall be provided in accordance with Sections 1109.5.1 and 1109.5.2.

1109.5.1 Minimum number. 

Not fewer than two drinking fountains shall be provided. One drinking fountain shall comply with the requirements for people who use a wheelchair and one drinking fountain shall comply with the requirements for standing persons.

Exceptions:

1. A single drinking fountain with two separate spouts that complies with the requirements for people who use a wheelchair and standing persons shall be permitted to be substituted for two separate drinking fountains.

2. Where drinking fountains are primarily for children's use, drinking fountains for people using wheelchairs shall be permitted to comply with the children's provisions in ICC A117.1 and drinking fountains for standing children shall be permitted to provide the spout at 30 inches (762 mm) minimum above the floor.

1109.5.2 More than the minimum number. 

Where more than the minimum number of drinking fountains specified in Section 1109.5.1 is provided, 50 percent of the total number of drinking fountains provided shall comply with the requirements for persons who use a wheelchair and 50 percent of the total number of drinking fountains provided shall comply with the requirements for standing persons.

Exceptions:

1. Where 50 percent of the drinking fountains yields a fraction, 50 percent shall be permitted to be rounded up or down, provided that the total number of drinking fountains complying with this section equals 100 percent of the drinking fountains.

2. Where drinking fountains are primarily for children’s use, drinking fountains for people using wheelchairs shall be permitted to comply with the children’s provisions in ICC A117.1 and drinking fountains for standing children shall be permitted to provide the spout at 30 inches (762 mm) minimum above the floor.

IBC 2902.6 Small occupancies. 

Drinking fountains shall not be required for an occupant load of 15 or fewer.

Part 2. Add new text as follows:

2902.7 Substitution.

Where restaurants provide drinking water in a container free of charge, drinking fountains shall not be required in those restaurants. In other occupancies where more than two drinking fountains are required, water dispensers shall be permitted to be substituted for not more than 50 percent of the required number of drinking fountains.

Proponent’s reason statement: It is important for both the building official and the plumbing inspector to fully understand the requirements for drinking fountains, including when they can be eliminated, switched out and when high/low drinking fountains are required. Currently, only a portion of the information is available in the IPC and IBC.

The IPC does not have language addressing two important points needed for accessible drinking fountains: 

• The IPC doesn’t include the requirements found in the IBC that are based on where the fountain is being provided — per floor, per secure area or outside.

• The IPC doesn’t address high/low requirements for three or more drinking fountains.

This proposal adds the relevant sections currently found in IBC to IPC. The changes to the language are editorial for coordination only. Current IPC Section 410.3 has additional words at the beginning, which are not in the IBC and are not correct. Accessibility provisions apply to drinking fountains where provided, not only where required.

There also appears to be a conflict between the IPC allowing half of the drinking fountains to be switched out starting at two drinking fountains, and the accessibility requirement requiring at least two. Adding “two or more” to the IPC Section 410.4 will eliminate that conflict. This information should be repeated in IBC Chapter 29, along with the information that small occupancies do not have to have drinking fountains.

There is another change proposal to change the definition in the IPC for water dispensers. This proposal is totally separate, but it is the intent for the revised definition to be in the IBC if that change is successful. This is a coordination/clarification of existing requirements in the IBC and the IPC.

My comments: In Part 1 of this code change, the intent is for the text in the IPC for the definition of “water dispenser” and Section 410.4 to be copied verbatim into the IBC as a new definition and new Section 2902.7. The Code Correlation Committee will decide, prior to publication of the 2021 codes, whether a scoping designation will be applied to this new definition in Part 1 and the new Part 2 code language in section 2902.7 in the IBC. The title change of IBC Section 1109.5 was only editorial.

Code Change: IPC Section 410.4, Drinking Fountain, Substitution 

Revise as follows:

410.4 Substitution. 

Where restaurants provide drinking water in a container free of charge, drinking fountains shall not be required in those restaurants. In other occupancies where three or more drinking fountains are required, water dispensers shall be permitted to be substituted for not more than 50 percent of the required number of drinking fountains.

410.3 High and low drinking fountains. 

Where drinking fountains are required, not fewer than two drinking fountains shall be provided. One drinking fountain shall comply with the requirements for people who use a wheelchair and one drinking fountain shall comply with the requirements for standing persons.

Exceptions:

1. A single drinking fountain with two separate spouts that complies with the requirements for people who use a wheelchair and standing persons shall be permitted to be substituted for two separate drinking fountains.

2. Where drinking fountains are primarily for children's use, the drinking fountains for people using wheelchairs shall be permitted to comply with the children's provisions in ICC A117.1 and drinking fountains for standing children shall be permitted to provide the spout at 30 inches (762 mm) minimum above the floor.

Proponent’s reason statement: IPC 410.4 allows up to 50 percent of required drinking fountains to be substituted with water dispensers, which could be water bottle fillers or bottled water. This change attempts to remove a “gotcha” situation — using the tradeoff for where only two drinking fountains would be required without considering the requirements for high/low drinking fountains. Allowing for such a tradeoff conflicts with high/low requirements in the IPC 410.3 and IBC Section 1109.5.

My comments: A few decades ago, I worked for architectural and engineering firm SSOE in Troy, Mich. They held an Americans with Disabilities Act Awareness Seminar for their employees. I attended and during the seminar, the instructor brought in a few wheelchairs. During a break, we went to the parking lot in wheelchairs and navigated our way back into the building from the parking lot. We went to the restrooms, to our desks, to the drinking fountain and back to the conference room. 

This seminar and some recent life events significantly raised my awareness of accessibility issues. I became more aware of the importance of door swing directions and clearances, drinking fountain height and clearance below the drinking fountain, door closer force, door threshold heights, and the height of fixtures, light switches, cabinet handles, cabinet surfaces, etc. I became aware of cabinet clearances, door clearances, wall layouts, knee clearances, toilet seat height for transfer to/from a wheelchair, location of flush valves and handles, faucet types and handles, handicapped showers, etc.

I have noticed handicapped showers in my travels in hotel rooms with a fold-down bench on one end of a shower stall and the shower controls on the opposite end. The controls were too far away from the seat for someone sitting on the bench to reach. There are so-called handicapped showers with handicapped ratings printed on their literature, with a hand-held shower and hose mounted on a vertical sliding rail that allows the hand-held shower to be locked into a high or low position. 

With this type of shower, a person in a wheelchair can only tug on the hand-held shower hose when it is locked into the top location and cannot reach, remove or use the hand-held showerhead. The proper installation of a wheelchair-accessible shower would have the controls and the hand-held shower mounted at the ADA-accessible height. (See ADA requirements sidebar[1].) In that accessible control area, there would be a diverter valve for changing from a fixed shower head mounted up high and a hand-held shower with a mounting hook located in the accessible control area.

Recently, I had a family member who is a college student and would often accompany me on forensic investigations of plumbing systems. He was attending school at Michigan Technological University, where he was involved in a skiing accident December 2018 and broke his back. He is now a paraplegic and will be using a wheelchair. 

In March 2019, he travelled with us to the ISH show in Germany. We also visited France, Austria, Lichtenstein and Switzerland. We discovered the difference between a country with accessibility laws versus countries that only provide accessibility if it is convenient. Our family has become keenly aware of accessibility requirements and we have grown to appreciate what the ADA legislation has done for persons with disabilities and what the building codes have done by incorporating the ADA guidelines into enforceable code language. 

The code section allowing substitutions of drinking fountains with bottled water dispensers was added a couple of code cycles ago to allow a building owner to add bottled water dispensers in lieu of plumbed drinking fountains. This exception allows a building owner to substitute bottled water dispensers for plumbed drinking fountains. 

The plumbed drinking fountains will always be there; a bottled water dispenser contract typically has a duration of a month to a year. After a bottled water contract expires, a building owner can cancel the contract after he gets his occupancy permit and there will be no drinking water for building occupants and no mechanism or way for a code official to re-enter the building to enforce the need for additional drinking fountains.

We will continue next month with the rest of the code changes from the 2018 to 2021 code.

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