Chapter One
Let's Talk About the Plumbing Code

Everyone who designs or installs plumbing systems knows how important it is to follow the plumbing code exactly. Even a small mistake can keep a plan or job from being approved, causing expensive delays. However, there’s no step-by-step explanation to guide you through following the plumbing code.

Back when I was a plumbing contractor, I had the experience of having my work turned down by the authorities. Probably, if you’ve been in the business for any length of time, you too have had a job held up by a plumbing inspector for some minor discrepancy that you felt didn’t amount to much. No matter what your viewpoint, the plumbing code is a fact of life that every plumbing professional has to deal with. My purpose in writing this book is to make it as simple and painless as possible for you to keep up with the code. Whether you’re a plumbing engineer, designer, contractor or a plumber, I believe you’ll find the information you’re looking for right here.

Every plumbing professional is expected to know the code. You’re not going to get paid until the plumbing you’ve designed or installed passes inspection. So, you must know the code and follow it to the letter. But trying to learn plumbing from a code book can be like finding your way through a maze of blind alleys. Plumbing codes are complex regulations that were written for enforcement purposes, not as a guidebook for plumbers. Yet, lack of knowledge and failure to understand minimum code requirements have left many a would-be plumbing professional discouraged, confused and frustrated.

This book will help you understand the important design and installation principles you need to do professional-quality plumbing jobs. What you learn here should be applicable nearly anywhere in the U.S., regardless of the code used in your particular area. Reading and understanding what is written here should be much easier than reading and understanding the code. However, this book doesn’t claim to be the plumbing code. You’ll still need to refer to your local code from time to time. But this book can be very handy as an answer book for code problems. For example, if you’re having a hard time figuring out the rules for a certain type of vent, go to the chapter or section in this book on vents. You’ll find a clearer explanation than you’ll find in the code, and probably a drawing or two. You’ll get a background in what the code demands, so you can save time and avoid expensive mistakes.

A Word About the Code Itself
The plumbing code I’m referring to in this book is the current version of the International Plumbing Code (IPC). You’ll need a copy of whichever version of this code that’s being enforced in the community where you do business. Some building and zoning departments sell the code they enforce. Bookstores specializing in construction books definitely sell the IPC. If you have trouble finding it, write or call these publishers to find out if they sell the IPC. Here are their addresses:

(ICBO) International Conference of Building Officials
5360 Workman Mill Road
Whittier, CA 90601-2298
(800) 284-4406
www.icbo.org

(BOCA) Building Officials and Code Administrators International, Inc.
4051 West Flossmoor Road
Country Club Hills, IL 60478-5795
(800) 214-4321
www.bocai.org

(SBCCI) Southern Building Code Congress International, Inc.
900 Montclair Road
Birmingham, AL 35213-1206
(800) 442-6337
www.sbcci.org

(ICC) International Code Council, Inc.
5203 Leesburg Pike, Suite 600
Falls Church, VA 22041-3401
(703) 931-4533
www.iccsafe.org

Don’t be concerned if your local plumbing code isn’t the IPC. The IPC is designed to be compatible with the Uniform Plumbing Code (UPC), the Standard Plumbing Code (SPC) and the National Plumbing Code (BOCA). The good news is that the IPC is now available for adoption and use internationally. And it may eventually be the only plumbing code available for state and local areas to adopt. Most communities don’t have the resources and time to create their own plumbing code from scratch. So they adopt one of the model codes published by one of the national code-writing organizations mentioned above. But before a community adopts a code, the local jurisdiction may change selected sections, delete others, or even add material that they think is necessary to meet their particular needs. But once adopted, the code (with changes) becomes a regulation that’s enforced like a law. That code remains in effect as adopted until it’s amended or replaced by the adoption of another code.

Every three years the code or its revisions are re-published as a recommendation and made available to the various building departments. Each local area then decides if it will adopt the revisions as regulations for their particular community. Most adopt the revisions routinely, but again, some make changes. And even if you know which code your community follows, it’s not safe to assume it has adopted the most recent version. Many jurisdictions, especially smaller ones, are still enforcing older versions of the code. You can see why it’s essential that you have a copy of the code that’s current in the city or county you work in.

Let’s say you’ve been doing quality plumbing work for 10 years and finally have your master’s license on your office wall. Your head is bursting with knowledge about the plumbing code. Still expect that you’re going to have an occasional dispute with your plumbing inspector. Perhaps a word of advice is in order here. I’ve been on your side. I was a plumbing contractor for 14 years. I’ve also worked on the inspector’s side for 15 years and have probably heard most of the arguments. Take it from me — you’re not going to win many direct confrontations with an inspector.

If a dispute is minor, it’s best to modify your work according to the inspector’s wish. He can make your life pretty unpleasant on this and/or future jobs, as he has the power of the building department behind him to enforce the code. Most inspectors would, of course, prefer to have your voluntary cooperation. It’s wise to adopt a positive attitude in your relationships with the building department. When taking out a permit, if there’s a question about how to do a particular installation, ask for an interpretation from the plumbing chief, the plans examiner or the field inspector. They can tell you what type of installation they’ll accept. This helps keep disputes to a minimum.

You’ll always have one thing in your favor. The inspector didn’t write the code and can only enforce the code as it’s written. He can require anything the code demands, but that’s all! If he insists on something that you feel isn’t a code requirement, you can challenge him. Obviously you’ll need a copy of the current code to do this. Ask the inspector, diplomatically, to cite the specific section involved so you can understand your error. Although he may get a little upset, he should comply. Then, in your code book, read the targeted section. If you still feel the code doesn’t support the inspector’s view, you’re in a better position to try to win him over.

Remember that inspectors make their living by knowing the code. Although they can be wrong, they don’t like to admit it. If the two of you can’t come to an agreement on what’s required, and if you can’t persuade him to change his mind, there’s a good appeal process available. We’ll discuss it later in this chapter.

Plumbing inspectors know they can only enforce what the code requires. The national code-writing organization did leave some room for interpretation. This gives code officials room to negotiate, if it seems in the best interest of all concerned. Section 104.2 of the IPC says, in part:

The code official shall have authority as necessary in the interest of public health, safety and general welfare to adopt and promulgate rules and regulations to interpret and implement the provisions of this code to secure the intent thereof and to designate requirements applicable because of local climate or other conditions.

Simply put, this means that the building department has enormous discretionary power to interpret the code.

Sometimes you may face such a tough code issue that there’s no way to work it out with an inspector. Before you start appeal procedures, request a meeting with the Chief Plumbing Inspector. Offer to meet when the field inspector can be present. Prepare your case very carefully. Try to show that the code doesn’t really make it clear what you’re being asked to do. Have a good alternate plan ready and see if you can negotiate a settlement. If your plan doesn’t adversely affect public health, safety and general welfare, it’s likely that you’ll get a satisfactory agreement.

Before you go to this trouble, be certain that it wouldn’t be cheaper and easier to just let it go and do what the inspector wants, right or wrong. In any dispute, there’s the possibility you could lose. Then you’ve spent the time and money, and you still have to make the change. Plus, you know the inspector’s going to bring his magnifying glass when he comes to inspect your next job.

Obviously, you shouldn’t expect a dispute to be waived by a code official if it’s a serious violation of the code. Code protection is too valuable to mess with. All code officials realize the importance of the code they administer, and they’re not going to stray much from it.

Basic Principles of the Plumbing Code
Plumbing codes are written and enforced to protect the health of the people who use plumbing systems. Every code requirement listed can be traced directly to basic principles. They’re the foundation the plumbing code is based on. Many of these principles go back to the Hoover Code (1924) that is the basis for most model codes used today. These principles are time-tested and clearly show the need for designing and installing a safe and sanitary plumbing system. Some details of plumbing construction may vary, but the basic sanitary and safety principles are the same everywhere. Here are the basic concepts the plumbing code is built on.

• Potable water: Every structure equipped with plumbing fixtures and intended for human use must be supplied with a source of potable water. The water supply must be protected against unsafe water sources and must not be subject to backflow.
  

• Adequate water: The plumbing system must provide enough potable water to allow the plumbing fixtures, devices and accessories to function properly without undue noise under normal intended use.
  

• Hot water: In occupied structures, hot water must be supplied to all plumbing fixtures and equipment intended for bathing, washing, culinary use, cleansing, laundry or building maintenance.
  

• Water conservation: Water must be conserved while maintaining proper performance and cleaning of plumbing fixtures.
  

• Water heater safety devices: All storage water heater devices must be designed and installed to guard against overheating or explosion.
  

• Public sewer: In places where a public sewer is available, it must connect to every building (intended for human use) that plumbing fixtures are installed in.
  

• Minimum plumbing fixtures required: Plumbing fixtures must be provided for the type of occupancy of a building and in the minimum number required by the code. For example, every single-family dwelling unit must have at least one water closet, one lavatory, one bathtub or shower, one kitchen sink and one clothes washer connection.
  

• Drainage systems: A drainage system must be designed and installed to keep solid deposits from clogging and fouling piping. Adequate cleanouts must be provided and located so all parts of the system can be readily cleaned.
  

• Material durability: Plumbing fixtures must be manufactured of approved materials, with smooth impervious surfaces, free from defects and concealed fouling surfaces. All porcelain surfaces must be acid-resistant and bear the manufacturer’s name. Piping materials must be durable and free from defects. They must be designed and constructed to provide satisfactory service for a reasonable life expectancy. The manufacturer’s mark and quality of material must be visible.
  

• Plumbing fixture traps: Fixtures connected directly to a building drainage system must be equipped with a liquid seal trap.
  

• Protecting trap seals: All drainage systems must be designed to provide enough air in the pipes to prevent siphonage, aspiration or back pressure from destroying trap seals under ordinary use and conditions.
  

• Vent terminals: All open vent pipes must be installed to extend outdoors and terminate to the open air.
  

• Testing a plumbing system: A plumbing system must be tested in accordance with code requirements so that all leaks and defects in the installation or materials are found.
  

• Excluding certain substances harmful to a building drainage or sewage system: Any substance that will clog plumbing pipes, produce explosive mixtures, damage drainage systems, or interfere with the normal operation of sewage treatment processes must be excluded from a building drainage system.
  

• Prevent contamination: Proper protection must be provided against sewage backflow, flooding, fouling and stoppage to prevent the contamination of water, sterile goods, distillation, processing, cooling or storage of foods or ice.
  

• Light and ventilation: Washrooms and toilet rooms must be properly lighted and ventilated.
  

• Private sewage disposal system: When a public sewer isn’t available, sewage from a building must be provided for by an approved private sewage treatment and disposal system.
  

• Prevent sewer backflow: A plumbing drainage system subject to sewage backflow must be protected by approved means to prevent overflow into a building.
  

• Plumbing system maintenance: All plumbing systems, materials and accessories, both existing and new, must be maintained in a safe and serviceable condition.
  

• Fixtures must be accessible: Plumbing fixtures must be installed to allow easy access for their intended use and cleaning the fixtures and the areas around them.
  

• Structural safety: When installing or repairing any part of a plumbing system, building code requirements must be followed to preserve the strength of structural members and to prevent damage to all surfaces.
  

• Protect ground and surface water: Sewage or other waste from a plumbing system must not be discharged into the ground or into any waterway unless it has been treated by an approved form of treatment.

Plumbing Code Terminology
Fortunately, most words in the plumbing code mean just what they would in everyday conversation. If you can’t understand the meaning of a code term, look it up in a good up-to-date dictionary. But sometimes the English language doesn’t quite express the meaning the plumbing code wants. So the plumbing code has assigned special meanings to key terms. To eliminate misunderstandings, the authors of the code include definitions of these terms. Let’s look at some examples.

The words shall and may appear in every plumbing code. We have no problem understanding these words in daily conversation. But in the plumbing code, they have a specialized meaning. Shall means you must. It demands that you comply. Take the example of preventing cross-connection in a potable water supply system. The code says, “Cross-connections between a private water supply and a potable public supply shall be prohibited.” That means you don’t have a choice. As used in the code, may is a permissive term. It means allowable or optional, but not required. Here’s an example: “Two fixtures set back-to-back may be served by a single vertical drainage pipe.” So, a single vertical pipe is permitted with a back-to-back fixture arrangement, but not required. Other options that meet code specifications are acceptable.

Two other commonly misused and misunderstood code terms are building drain and building sewer. Many professionals assume that both terms refer to the same part of the drainage system. Not so. Here’s the code definition of these terms.

A building drain is the lowest horizontal collection system which receives the discharge from other drainage pipes within the walls of a building and extends 30 inches beyond the building outer wall.

The code defines a building sewer as:

that part of the horizontal piping of a drainage system which extends from the end of the building drain (30 inches beyond the outer wall of the building) and conveys the liquid waste to an approved point of disposal.

Before you read the rest of this book, you may find it helpful to look at the glossary at the end of the book. It’ll be a handy reference for you because it includes code definitions, plus some useful definitions that I’ve added. There are also plenty of illustrations to help you understand the definitions. If you’re new to plumbing work, I don’t recommend that you try to memorize these terms now. But whether you’re a veteran or a novice in the field, the glossary will aid your understanding.

Getting to Know the Administrative Process
The first chapter of the plumbing code tells you who your administrators are. The plumbing department administrators of a local building and zoning department (if large enough) are the chief plumbing inspector, the plans examiner(s) and field inspector(s). Small communities may have one or two inspectors doing it all. They interpret and enforce the plumbing code, approve construction plans and inspect plumbing installations.

The administrative authority that has jurisdiction will create the department of plumbing inspection. The executive code official in charge is known as the chief plumbing inspector. He’s appointed by the administrative authority of the jurisdiction and can’t be removed from office except for cause and after full opportunity to be heard on specific and relevant charges. He’s usually there until he retires, so get to know him and (if possible) even to like him.

The chief plumbing inspector:

• appoints assistants he decides are necessary to carry out the functions of the plumbing department

• adopts and publicizes rules and regulations

• decides code intent

• interprets and implements the code

• receives applications and issues permits

• examines any premises considered unsafe, unsanitary, dangerous or in any way hazardous

• issues all necessary notices or orders to ensure compliance with the code

Approval of Special Plumbing Systems
Sometimes plumbing installations can’t meet the provisions of the code exactly. This happens quite frequently where island sinks and combination waste and vent systems are used. Before installing such a system, if it’s not clearly spelled out in the code, check with the chief plumbing inspector. He has the authority to approve changes and modifications in the plumbing code. The details of such changes in a plumbing system will be recorded and filed with the plumbing department.

Can I Use That Material?
New materials and installation designs for plumbing systems are frequently introduced. You must submit such materials or installation methods to the chief plumbing inspector. He may grant approval when he’s satisfied that a proposed design is satisfactory and complies with the intent of plumbing code provisions. When there’s not enough evidence that a certain new product or method of construction complies with the plumbing code, the chief plumbing inspector can require you to see that tests are made to prove the manufacturer’s claims. These tests must be made at no expense to the plumbing department. If there aren’t any recognized and accepted test methods, the chief plumbing inspector must approve the testing procedure you use. All tests for alternate materials or methods of installation must be done by an approved agency. The plumbing department must retain all test results for the period specified for public records.

Don’t reuse any materials, equipment, or devices in a plumbing system unless they’ve been reconditioned, properly tested and approved by the plumbing department. A good rule to follow is to buy all your materials, equipment and devices from your local supplier. It will more than likely stock only materials approved for the area where you do business.

How Do I Make Appeals?
If you feel you’re right and the inspector is wrong, how can you get your work approved? You have the right to appeal an inspector’s decision, as Section 109.1 says:

Any person shall have the right to appeal a decision of the code official to the board of appeals. An application for appeal shall be based on a claim that the true intent of this code or the rules legally adopted thereunder have been incorrectly interpreted, the provisions of this code do not fully apply, or an equally good or better form of construction is proposed. The application shall be filed on a form obtained from the code official within 20 days after the notice was served.

The board of appeals is made up of five persons appointed by the chief appointing authority. Each member is appointed to a staggered five-year term. This way, four members of the board are always experienced with board procedures. Each board member must have the following professional disciplines:

1. One member must be a registered architect or a person having 10 years’ experience as a builder or superintendent of building construction.
   

2. One member must be a registered mechanical and plumbing engineer, or a mechanical and plumbing contractor with at least 10 years’ experience.
   

3. One member must be a registered structural engineer.
   

4. A fourth member must be an electrical engineer, or an electrical contractor with at least 10 years’ experience.
   

5. The final member must be a fire protection engineer, or a fire protection contractor having at least 10 years’ experience.

A member of the board of appeals must not hear an appeal if that member has any interest in that particular case. There are two appointed alternate members who must be called by the board chairman if a member is absent or disqualified. Alternate members must meet the same requirements as regular board members. They serve for five years, or until a successor has been appointed. The board members must annually select someone to serve as board chairman.

By a vote of three members, the board may approve, change or reverse a plumbing official’s decision. Once the board of appeals has resolved the problem, the plumbing official must then take immediate action in accordance with its decision.

If you have a minor dispute that’s easily correctable, you’re better off to simply make the correction and not confront the inspector. Suppose he says, “That sink arm (sink drain) is 2 inches over the limit set by code. I want it shortened to meet code requirements.” I’d strongly recommend that you cut off the 2 inches, rather than argue with an inspector you may be working with for years to come. The main criterion for deciding whether to appeal is if the matter is in “the gray area” of code requirements. Or, if an inspector’s changes could cost you big bucks, consider taking it to the board. They’ll listen carefully to both sides and make a judgment call. Hopefully, if the call is in your favor, there should be no hard feelings between you and the inspector, because you won fair and square.

Let me share with you my first and only experience before the board of appeals during my plumbing contracting days. This was when cast iron was used in drainage, waste and vent systems. At that time, the code required buildings three stories or higher to use only extra-heavy cast iron pipe and fittings. My plumbers installed, tested and inspected all the below-ground plumbing using the required extra-heavy material. About that time a new material called “centrifugally-spun service weight” appeared on the market. It was advertised as being superior to extra-heavy pipe and fittings. And the material was stocked by my local supplier who told me it was approved for use in multi-story buildings. Without checking with the plumbing department (my big mistake!), I used it for the job. My plumbers had installed it through the fifth floor before the next inspection was called.

When the plumbing chief in Dade County came out and made the inspection, he looked over the work and signed it off as being okay. About three hours later he returned to the job and turned it down. When my foreman called and told me what had happened, I almost had a heart attack. I could see my business going down the drain if I had to tear out all that material and replace it with extra-heavy cast iron pipe. I began to do a little detective work. I discovered that my plumbing department had already approved this new material and planned to incorporate it into the plumbing code as an amendment, two months down the road. I tried discussing this with the chief inspector but got nowhere. He did recommend that I take it to the board of appeals though (I guess he didn’t want to stick his neck out). So I did.

In those days, the board of appeals had nine members appointed by the board of county commissioners. The members were construction trade professionals, as is required for the present board, but only one was a plumbing contractor. I presented my case as a plumbing contractor, explaining that the material in question was approved but would not be officially acknowledged for another two months. I explained that the lost labor and material to replace all the installed material could put me out of business. The board considered the evidence and made an exception in my case. They ruled against the plumbing chief and in my favor. The plumbing chief didn’t testify against me, which was good. I know that I was one of the lucky ones.

Several years later I closed my business and went to work for that same plumbing department. Of course, the same plumbing chief who turned down my job was now my boss. I worked as a field inspector for several weeks and then there was a vacancy in the plumbing plans examiner’s office. The chief bypassed several senior field inspectors and promoted me to this position — a position I held for 15 years. I later became the assistant plumbing chief. The chief and I became very good friends and stayed in touch through the years. So when circumstances warrant, it’s okay to go over the head of an inspector!

What About Permits?
IPC Section 106 gives the scoop on when a permit is or isn’t required. Section 106.1 says an owner, authorized agent or plumbing contractor must get a permit from the plumbing department to install, alter, repair, replace or remodel any plumbing system which is regulated by the code. Section 106.2 says you don’t have to get a permit to simply repair leaks in a plumbing system, clean out obstructions in sewer lines or waste pipes, or to repair faucets or valves. You also don’t have to get a permit to remove one water closet and reset another on the same waste opening.

However, once you get a permit, you must begin work within 180 days from the date the permit was issued to you. If you start work on a building and for some reason you have to stop or temporarily abandon the job, you must start again within 180 days of your last inspection. If you wait more than 180 days, you’ll have to get a new permit, which will cost one-half the price of the original permit. If the reason for your delay is satisfactory, you may ask for an extension. The plumbing chief may extend the permit for a period of 180 days, but you can never get more than one extension. Don’t ever make false statements or misrepresent the facts to get an extension. You may get your permit revoked entirely. Also if you begin work on a job before you get a proper permit, it could cost you the regular fee, plus 100 percent more of that fee as a penalty. It’s not worth it.

The city or county you do a job in will set permit fees. These fees, along with other building department fees, are calculated to pay most, if not all, of the costs of the building and zoning department. Your building department is self-supporting and requires little or no money from local taxpayers.

Finally, in all your contract work, it’s extremely important that you have correct and current state and local licenses.

Required Inspections and Testing
A plumbing permit always requires an inspection. It may be a single inspection for replacing a plumbing fixture. Or it may be for a new building requiring several different inspections. For most residential and small commercial buildings, there are three required inspections. These are set in IPC Section 107.1.

The permit holder is responsible for notifying the plumbing official about the required inspections as construction progresses. The plumbing inspector has to sign off on the portion of a plumbing system that he approves. If he finds something unsatisfactory, he’ll red tag the job and notify the permit holder what he must do to correct the violation.

Here’s the order in which new work inspections are made:

1. Ground roughing-in inspection is made after you install and properly bed piping in open trenches, but before you backfill the trench.
   

2. Roughed-in inspection for pipes above ground must be made after the roof and framing of the building are completed. All plumbing piping must be in place. For this inspection, you must prepare bathtubs and showers before the wall and ceiling membranes are installed.
   

3. Final inspection comes after you’ve installed all plumbing fixtures, appliances, equipment and devices and connected them to the plumbing system. Once the building passes this inspection, it’s ready for a certificate of occupancy.

According to IPC Section 107.3.1, new plumbing systems and existing systems that have been changed, extended or repaired must be tested to find possible leaks and defects. As permit holder, you must furnish all equipment, materials and labor required for testing a plumbing system. Of course, if your work doesn’t pass inspection, you must make the corrections and call for a reinspection. Some building departments charge an additional fee for reinspections.

As far as you’re concerned, a building is ready for a certificate of occupancy when the final inspection is made and approved. And you can be proud of the code-perfect plumbing facilities you’ve installed.