The first half of 2024 has been a busy time for ASA’s Codes and Standards area. This article is intended to provide an overview of those activities along with anticipated activities for the remainder of 2024.
Product standards and the impact on the market
The plumbing and PVF industries are heavily regulated through the adoption of national product standards into model codes and regulations. Product standards serve a vital role in helping to set a level playing field in the marketplace while also ensuring consistent requirements for products and consistency of those requirements throughout the U.S. It is for these reasons that ASA supports the development and use of nationally accepted product standards and actively participates in the development of those standards on behalf of ASA members.
Unfortunately, the development of national industry standards has become highly competitive and various standards bodies are constantly striving to grow their presence in given markets and expanding into new markets. The competitiveness is even steeper when the standards development body also operates a product certification program based on the standards they develop. The competitive environment is increasingly leading the development of duplicative or conflicting national standard leading to confusion in the marketplace rather that consistency. ASA has taken the position of opposing the development of any product standard that duplicates or conflicts with existing nationally accepted standards.
One area ASA has been focused on has been the development of standards impacting drinking water treatment system products. ASA members both produce and distribute these products in the marketplace. NSF International has been the leading standards developer of products impacting drinking water treatment system products, however, the American Society of Sanitary Engineering (ASSE) a division of the International Association of Plumbing and Mechanical Officials (IAPMO, had been increasingly moving into the market and, in fact, has developed some standards addressing gaps in the industry while not duplicating or conflicting with existing standards. However, they have also developed standards that have led to confusion in the marketplace.
One standard ASA has concerns with is ASSE/IAPMO 1087 - Commercial and Food Service Water Treatment Equipment Utilizing Drinking Water. ASA has taken the position that the Standard duplicates and conflicts with existing national standards and that the Standard only provides confusion in the marketplace and potential unneeded costs of product testing and certification. ASA has opposed the inclusion of the Standard into model codes and has also driven the formation of the ASSE Task Group to determine if there is value in the Standard and if not, remove the Standard from publication. The work of the Task Group has just begun so stay tuned for further updates on this issue.
ASA participation in model code development
The major model codes published in the U.S. impacting plumbing, mechanical systems, fuel gas systems and fire safety, at both the commercial and residential levels, go through a three-year revision cycle. These model codes were open for revision in January 2024 and model code hearings were held in April and May to discuss proposals submitted for updated the codes. ASA was actively present at the model code hearings taking positions on proposals determined by the ASA Codes and Standards Committee comprised of representatives from ASA member companies. The Committee asked ASA staff to take positions on 48 different proposals and the voting body at the hearings agreed with ASA on 85% of the proposals. This high level of success is due to the significant amount of experience and technical expertise that the members of the ASA Codes and Standards Committee represents.
The model codes that were under review at the hearings were the following:
International Codes Council
- International Plumbing Code
- International Private Sewage Disposal Code
- International Mechanical Code
- International Residential Code
- International Fuel Gas Code
- International Fire Code
International Association of Plumbing & Mechanical Officials
- Uniform Plumbing Code
- Uniform Mechanical Code
An overarching goal of the Codes and Standards area of ASA Advocacy is to ensure the following: 1) A fair and open marketplace; 2) Ability to manufacture and distribute products in the market that are safe and protect public health. These two goals provide the overall strategy for the ASA Codes and Standards Committee when developing positions. The following summarizes key areas that were addressed in the model code proposals through the positions taken by ASA:
- ASA opposed several newly proposed definitions related to products produced and distributed by ASA members. The main reason for opposition was to prevent potential confusion in the marketplace due to unclear or inaccurate definitions and to also prevent the inclusion of specific product requirements that should not be stated in a definition but rather addressed in the product standard(s).
- There were several proposals in plumbing and residential codes asking for the reduction in water usage in plumbing fixtures. ASA opposed all these proposals because the change in requirement would go beyond the Federal regulations. Manufacturers of plumbing fixtures voluntarily submit their products for certification to the voluntary program, WaterSense, operated by the U.S. EPA. The WaterSense requirements are typically set to ensure a 20% reduction in water use based on the current Federal Regulations. ASA supports the use of WaterSense for consumers who are looking for increased efficiency or local jurisdictions that might have a severe water shortage however, we oppose the adoption of lower water efficiency requirement, such as WaterSense, in a national model code because there is insufficient data that provides assurances that lowering the waste water flow from plumbing fixtures lower than Federal regulations will not have a negative impact of the waste flow downstream of the fixture.
- ASA opposed several proposals that, if approved, would lead to unnecessary design restrictions or provide installation requirements inconsistent with the manufacturer’s installation instructions. In general, design requirements and installation needs are addressed in the national consensus product standard and should not be addressed in model codes. ASA supports the development of minimum design requirements protecting public health and safety while allowing the flexibility for design innovation.
- Some new products were proposed to be added to the model codes and in general, ASA supports the inclusion of new products allowing our members to distribute those new products to their customers. A new section was proposed for air source heat pump water heaters. ASA opposed the proposal due to technical errors however, ASA will be represented on a Task Group formed to work on correcting those issues.
US EPA WaterSense programs, updates, specifications
Version 2.0 of US EPA WaterSense Specification for Tank Flush Toilets has been approved and will go into effect on July 1, 2025. Until then, tank-type toilets can continue to earn the WaterSense label according to the criteria included in Version 1.2 of the specification. For a detailed description of the changes to the specification you can click here. A summary of the changes is provided below:
- Including combination in-wall toilet carrier systems and wall-hung bowls within the scope of the specification.
- Elimination of the effective flush volume calculation and instead establishing the same maximum flush volume requirements of 1.28 gpf for both single-flush toilets and the full flush mode of dual flush toilets.
Future activities
The code development cycle for the model codes referenced in this article continues through 2025. ASA will be attending model code hearings in September and October of 2024 ensuring the voice of ASA members is represented in the discussions. In addition, ASA will be attending ASSE Product Standards Committee meetings being held in Portland, ME in early October.
As always, never hesitate to reach out if you have any issues or concerns related to codes and standards impacting your business. We are more than happy to help.
