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.
Code Change: 2018 IPC Section 312.10.2
Revised text for the 2021 IPC as follows:
312.10.2 Testing.
Reduced pressure principle, double check, pressure vacuum breaker, reduced pressure detector fire protection, double check detector fire protection, and spill-resistant vacuum breaker backflow preventer assemblies and hose connection backflow preventers shall be tested at the time of installation, immediately after repairs or relocation and at least annually. The testing procedure shall be performed in accordance with one of the following standards: ASSE 5013, ASSE 5015, ASSE 5020, ASSE 5047, ASSE 5048, ASSE 5052, ASSE 5056, CSA B64.10 or CSA B64.10.1. Test gauges shall comply with ASSE 1064.
Also, an addition to Chapter 15 was made to include the newly referenced standard: ASSE 1064—2006 (R2011): Performance Requirements for Backflow Prevention Assembly Field Test Kits
Proponent’s reason statement: “Gauges that comply with ASSE 1064 are specifically designed for testing backflow devices describing the proper accuracy (linearity and repeatability) and precision, while compensating for varying operating conditions, EMI/FRI [RFI] exposure, ambient temperatures, etc. Further, the gauges are required to be NIST-traceable, calibrated periodically, and are designed to be used in tandem with the current referenced standards in this section.”
My comments: This standard includes requirements for testing the backflow preventer testing equipment to assure that there is consistency between all test equipment. There are requirements for these gauges to be traceable by the National Institute for Standards and Technology (NIST) — the ones that use digital readout gauges. The EMI (electromagnetic interference) and RFI (radio frequency interference) protection is to ensure that radio interference does not affect the gauge readouts.
In tests that I have conducted using digital readout devices in the past, when I was in one part of a building and a colleague was in another part of the building and we were communicating by two-way radio for opening valve or operating fixtures, the digital temperatures or pressures readout and recording devices would spike when we keyed up the radio. We then tested this with a series of keyed mics with a Morse code to confirm the radios were affecting the readout when the mics were keyed.
This showed up on the printout of the graph of the pressure and temperature readings as tall spikes on the printout, so we were able to key up the mic when a burner would come on and a brief spike would show up on the graph. Then the temperatures would start to gradually rise shortly thereafter after the burner came on and heat was added to the system.
This PFI test assures that the gauges are not affected by radio frequencies or close proximity to electromagnetic fields. Using a gauge with RFI and EMI protection or immunity can assure accurate readings. With respect to digital readout and recording gauges, there is a difference between RFI “protection’’ vs. RFI “immunity”.
Digital gauges that are provided with RFI protection means that the unit’s displayed readings can show some fluctuation when subjected to a keyed radio, or radio frequency interferences but the device is “protected” against damage and loss of accuracy under such radio interference conditions and the gauge will return to a normal reading when the RFI field is removed. RFI immunity means that the gauge has full RFI protection and the display will not fluctuate when subjected to RFI fields.
Code Changes: 2018 IPC Section 403.1.1
Add new text for the 2021 IPC as follows: 403.1.1 Fixture calculations.
To determine the occupant load of each sex, the total occupant load shall be divided in half. To determine the required number of fixtures, the fixture ratio or ratios for each fixture type shall be applied to the occupant load of each sex in accordance with Table 403.1. Fractional numbers resulting from applying the fixture ratios of Table 403.1 shall be rounded up to the next whole number. For calculations involving multiple occupancies, such fractional numbers for each occupancy shall first be summed and then rounded up to the next whole number.
Exceptions: The total occupant load shall not be required to be divided in half where approved statistical data indicates a distribution of the sexes of other than 50 percent of each sex.
Where multi-user facilities are designed to serve all genders, the minimum fixture count shall be calculated 100 percent, based on total occupant load. In such multi-user user facilities, each fixture type shall be in accordance with ICC A117.1 and each urinal that is provided shall be located in a stall.
Proponent’s reason statement: “This proposal will permit designers to design gender-specific facilities using either the men or women category. The proposal will also bridge the gap of designing for facilities that elect to install all-inclusive bathroom/restrooms.”
Code Changes: 2018 IPC Section 403.1.1
Revise text for the 2021 IPC as follows: 403.1.1 Fixture calculations.
To determine the occupant load of each sex, the total occupant load shall be divided in half. To determine the required number of fixtures, the fixture ratio or ratios for each fixture type shall be applied to the occupant load of each sex in accordance with Table 403.1. Fractional numbers resulting from applying the fixture ratios of Table 403.1 shall be rounded up to the next whole number. For calculations involving multiple occupancies, such fractional numbers for each occupancy shall first be summed and then rounded up to the next whole number.
Exceptions: The total occupant load shall not be required to be divided in half where approved statistical data indicates a distribution of the sexes of other than 50 percent of each sex.
Distribution of the sexes is not required where single-user water closets and bathing room fixtures are provided in accordance with Section 403.1.2.
403.1.2 Single-user toilet facility and bathing room fixtures.
The plumbing fixtures located in single-user toilet facilities and bathing rooms, including family or assisted use toilet and bathing rooms that are required by Section 1109.2.1 of the International Building Code, shall contribute toward the total number of required plumbing fixtures for a building or tenant space. Single-user toilet facilities and bathing rooms, and family or assisted-use toilet rooms and bathing rooms shall be identified for use by either sex.
The total number of fixtures shall be permitted to be based on the required number of separate facilities or based on the aggregate of any combination of single-user or separate facilities.
403.2 Separate facilities.
Where plumbing fixtures are required, separate facilities shall be provided for each sex.
Exceptions: Separate facilities shall not be required for dwelling units and sleeping units.
Separate facilities shall not be required in structures or tenant spaces with a total occupant load, including both employees and customers, of 15 or fewer.
Separate facilities shall not be required in mercantile occupancies in which the maximum occupant load is 100 or fewer.
Separate facilities shall not be required in business occupancies in which the maximum occupant load is 25 or fewer.
Separate facilities shall not be required to be designated by sex where single-user toilets rooms are provided in accordance with Section 403.1.2.
Separate facilities shall not be required where rooms having both water closets and lavatory fixtures are designed for use by both sexes and privacy for water closets are installed in accordance with Section 405.3.4.
Proponent’s reason statement: “As part of the changes to the 2018 code, provisions were added to allow single-user toileting features to be counted toward the total number of fixtures required, despite their designation by sex or family. This change is proposed to clarify how toilet rooms that are configured in such a manner to allow use by either sex can also be used.
Many communities have been asking to use these provisions in advance of full adoption of the 2018 codes because of their need to address significant issues of gender and equality for access.
The codes only require the installation of family or assisted-use facilities in a limited number of occupancies. With this change, the codes will allow the design of facilities that are available to those needing assistance by other assistants that are of an opposite gender without causing any discomfort by anyone.”
My comments: There were multiple code changes to these sections which will require ICC staff to revise the numbering of these exceptions in the final text that incorporates all the changes made during the code hearings.
Code Changes: 2018 IPC Section 403.1.2
Revise as follows: 403.1.2 Single-user toilet facility and bathing room fixtures.
The plumbing fixtures located in single-user toilet facilities and bathing rooms, including family or assisted use toilet and bathing rooms that are required by Section 1109.2.1 of the International Building Code, shall contribute toward the total number of required plumbing fixtures for a building or tenant space. Single-user toilet facilities and bathing rooms, and family or assisted-use toilet rooms and bathing rooms shall be identified as being available for use by either all persons regardless of their sex.
Proponent’s reason statement: “This proposal merely clarifies some of the ambiguous language in a previous change adopted by the membership in the last code cycle. Pursuant to P40-15, Public Comment 2, Section 403.1.2 of the International Plumbing Code was revised to state that ‘toilet and bathroom facilities be identified for use by either sex.’
The membership’s stated reason for adopting Public Comment 2 was two-fold. First, the change allowed designers to adopt single-occupant toilet rooms, rather than grouped facilities. Second, and more importantly, the membership adopted this change to alleviate some of the issues transgender individuals face.
Under the design scheme approved by P40-15, Public Comment 2, the same numbers of fixtures are provided, and waiting time is reduced by allowing either sex to use the toilet room. However, despite the membership’s intention to alleviate some of the problems transgender people face, the adopted language ‘for use by either sex’ remains vague and subject to competing interpretations.
For example, a designer might interpret ‘identified for use by either sex’ to mean that single-user, family or assisted-use toilet facilities could be identified for use by men, or could be identified for use by women, but not necessarily be identified for use by both men and women.
In response to this ambiguity, the National Center for Transgender Equality urge[d] the committee to approve this code change proposal to clarify Section 403.1.2 of the International Plumbing Code by including language that bathroom identification be ‘available for use by all persons regardless of their sex.’
This modification resolves the problem of ambiguous interpretations because it could not logically be construed that it is permissible for bathroom signage to exclude one gender over the other. In essence, this proposal more accurately reflects the membership’s intention to permit certain facilities to be identified for use by any and all persons.”
My comments: There were multiple code changes to these sections which will require ICC staff to revise the numbering of these exceptions in the final text that incorporates all of the changes made during the code hearings.
Code Changes: 2018 IPC Section 403.3.1
Revise text for the 2021 IPC as follows: 403.3.1 Access.
The route to the public toilet facilities required by Section 403.3 shall not pass through kitchens, storage rooms or closets. Access to the required facilities shall be from within the building or from the exterior of the building. Routes shall comply with the accessibility requirements of the International Building Code. The public shall have access to the required toilet facilities at all times that the building is occupied.
403.5 Drinking fountain location.
Drinking fountains shall not be required to be located in individual tenant spaces provided that public drinking fountains are located within a distance of travel of 500 feet (152 m) of the most remote location in the tenant space and not more than one story above or below the tenant space. Where the tenant space is in a covered or open mall, such distance shall not exceed 300 feet (91 m). Drinking fountains shall be located on an accessible route.
Proponents reason statement: “Accessibility is addressed in Section 404 of the IPC, which includes specifics for accessible routes connecting accessible elements — including exceptions to the vertical route between levels that may contain toilets or drinking fountains. The language is redundant in Section 403.3.1 and is not needed. The language in Section 403.5 is also not consistent with 403.3.1 and could be interpreted to prohibit any drinking fountains to be installed on floors without elevator service. This is not the intent of the accessibility provisions.”
Code Changes: 2018 IPC Section 403.3.3
Revise as follows: 403.3.3 Location of toilet facilities in occupancies other than malls.
In occupancies other than covered and open mall buildings, the required public and employee toilet facilities shall be located not more than one story above or below the space required to be provided with toilet facilities, and the path of travel to such facilities shall not exceed a distance of 500 feet (152 m).
Exceptions: The location and maximum distances of travel to required employee facilities in factory and industrial occupancies are permitted to exceed that required by this section, provided that the location and maximum distance of travel are approved.
The location and maximum distances of travel to required public and employee facilities in Group S occupancies are permitted to exceed that required by this section, provided that the location and maximum distance of travel are approved.
Proponents reason statement: “This proposal adds exception [No.] 2, which builds on the existing exception for employee toilet facilities in factory and other industrial occupancies when approved by the code official. Because these types of occupancies have extremely low occupancy rates, it is not a cost-effective use of space or resources to require the same number of independent restrooms when they will rarely be utilized.
The new exception for Group S facilities recognizes that even though there may be members of the public present in some S occupancies, the overall use of the building is similar to that of an industrial facility, where occupancy rates and dwell times are extremely low.
This proposal provides the code official the authority to increase the number of floors between restrooms from every other floor to something more appropriate in parking garages with attendants, self-storage facilities and other similar Group S buildings with low occupancy rates and dwell times.”
My comments: Duplicated companion text in the International Building Code is not shown for brevity; however, a duplicate code change was submitted to the International Building Code also.
Code Changes: 2018 International Building Code Section 1109.2.1.7
Revise as follows: IBC 1109.2.1.7 Privacy.
Doors to family or assisted-use toilet and bathing rooms shall be securable from within the room and be provided with an "occupied" indicator.
Proponents reason statement: “This code change proposal will alleviate privacy and safety concerns by requiring the occupied indicator for single-user restrooms. Without an occupied indicator, the only way for someone to see if the room is in use is to turn the handle. This causes safety and privacy concerns for the user. This can cause severe discomfort, even fear, for children or people who have suffered trauma. This proposal will proactively provide increased comfort and safety for everyone.”
My comments: This was a two-part code change with both the plumbing code and building code parts being heard by the Plumbing Code Development Committee. Although this will be printed in the International Building Code, the issue was heard by the Plumbing Code Development Committee.
It was the intent of this proposal to have the added coordinated section in the IBC 2902.3.7, later scoped by Code Correlation Committee as Plumbing "[P]" because it has to do with restroom partition doors and they wanted the plumbing committee to hear this change because everything else in Chapter 29 is scoped [P] for the plumbing committee to hear address.
Code Changes: 2018 IPC Sections 404.1, 404.2, 404.3
Revise as follows: 404.1 Where required.
Accessible plumbing facilities and fixtures shall be provided in accordance with the International Building Code and ICC A117.1.
Delete without substitution:
404.2 Accessible fixture requirements.
Accessible plumbing fixtures shall be installed with the clearances, heights, spacings and arrangements in accordance with ICC A117.1.
404.3 Exposed pipes and surfaces.
Water supply and drain pipes under accessible lavatories and sinks shall be covered or otherwise configured to protect against contact. Pipe coverings shall comply with ASME A112.18.9.
Proponents reason statement: “Section 404.2 and 404.3 were added by Code Change Proposal P42 in 2012. They should be removed for multiple reasons. The reference to IBC would also get a reference to ICC A117.1 in Section 1101.2; however, if there is a concern that this may be missed by plumbing inspectors, the reference can be added in Section 404.1.
In Section 404.2, the laundry list is incomplete on what is required in the A117.1 for accessible plumbing fixtures. Since standards are only referenced to the extent the code sends you there (Section 102.8), this could be misinterpreted as intending to limit requirements that would be applicable in the standard. The requirement for pipe protection is a technical requirement for accessible lavatories, address in A117.1 Section 606.6, so it should not be repeated here.
The ASME A112.18.9 standard addresses the requirements for heat transfer, not cold, therefore it only addresses half the issue associated with water, and not all the issues associated with accidental contact. The test for hot water is substantially hotter than tempered water, which is required for public lavatories. Also, if the pipes are protected from contact by some type of shield as indicated in the photo, there is no exception for compliance with the standard, even if there is no contact with the pipes.
If ASME A112.18.9 should be referenced, this standard should be reviewed through the ICC A117.1 process for technical issues associated with accessibility requirements. It does not belong in the IPC.”
Code Changes: 2018 IPC Chapter 15
Add the following standards: A112.6.1M-1997 (R2017): Floor Affixed Supports for Off-the-Floor Plumbing Fixtures for Public Use
Code Changes: 2018 IPC Section 405.4.3
Revise and add the following fixture support standards as follows: 405.4.3 Securing wall-hung water closet bowls.
Wall-hung water closet bowls shall be supported by a concealed metal carrier that is attached to the building structural members so that strain is not transmitted to the closet fixture connector or any other part of the plumbing system. The carrier shall conform to ASME A112.6.1M or ASME A112.6.2.
Proponents reason statement: “The ASME A112.6.1 standard includes requirements for floor-affixed supports that can be used to secure off the floor water closets and urinals.”
My comments: This proposal is for the addition of a new standard that covers definitions, materials and finishes, general requirements, strength, deflection requirements and details of the various types of plumbing fixture supports. The standard is titled, ASME A112.6.1M-1997 (R2017), Floor Affixed Supports For Off-The-Floor Plumbing Fixtures For Public Use.
Code Changes: 2018 IPC Section 407.2 (New)
Revise as follows: 407.2 Bathtub waste outlets and overflows.
Bathtubs shall be equipped with a waste outlet and an overflow outlet. The outlets shall be connected to waste tubing or piping that is not less than 1 1/2 inches (38 mm) in diameter. The waste outlet shall be equipped with a water-tight stopper. Where an overflow is installed, the overflow shall be not less than 1 1/2 inches (38mm) in diameter.
Proponents reason statement: “This proposal will coordinate the IRC requirements and IPC requirements for outlets from tubs. There are many bathtub designs that do not have overflow openings and the plumbing fixture standards do not require an overflow.
This proposal was submitted by the ICC Plumbing/Mechanical/Fuel 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 attended the committee meetings and offered their input.”
My comments: The ICC Code Action Committee has been helpful with providing code changes that correlate with other codes and reviewing all of the chapters in the code to address areas of the code that needed to be addressed.
This is part 2 of a series covering significant code changes from the 2018 International Plumbing Code, which will appear in the 2021 International Plumbing Code. Over the next few months, I will continue to report on the significant changes to the IPC. Following that, I will cover the significant changes to the Uniform Plumbing Code.
