Paul Cabot Administrator National Fuel Gas Ms. Gabriella Davis Recording Secretary, IAPMO Standards Council International Association of Plumbing and Mechanical Officials (IAPMO) IAPMO Group World Headquarters 4755 E. Philadelphia St Ontario, CA 91761 October 3, 2014 Subject: BSR Uniform Mechanical Code, 2015 Edition: Appeal on Proposal #333 Ms. Davis, In accordance with IAPMO Regulations Governing Committee Projects, Section 1.6, I am appealing the approval of BSR Uniform Mechanical Code, 2015 Edition. In accordance with subsection 1-6.3, I am providing the following details: Appellant: Specific Items: Paul Cabot Administrator National Fuel Gas Code American Gas Association 400 N Capitol St, NW Washington, DC 20001 Committee acceptance of public comment on proposal #333 regarding Section 1308.5.10.1 [UMC ROC pages 378 see attached]. Appeal Grounds: The UMC TC accepted public comment on UMC item #333 which results in creating a conflict between the code requirements of ANSI Z223.1/NFPA 54, National Fuel Gas Code, and the UMC. The conflict between ANSI Standards violates the goal of the American National Standards Institute to promote a cohesive family of American Standards. More importantly, conflicts will impact the willingness of ANSI Standard Developer Organizations (SDOs) to provide extracts from their ANSI Standards and lessen their full participation in the UMC code development process. The participation of SDOs is crucial for ensuring that the UMC stays current on the latest life safety code requirements occurring within the various industries covered by the UMC. Without such regular updates, the UMC will be less adoptable. American Gas Association 400 N. Capitol St., NW Washington, DC 20001 202.824.7312 pcabot@aga.org
Relief Requested: Two areas of relief: Publication of the 2015 UMC with Section 1308.5.10.1 as shown in Proposal #333 not modified by the public comment. Revision of the IAPMO Operating Procedures to provide protection of extracted materials provided by ANSI SDOs to ensure that the neither the committee nor the membership can alter such material. Please let me know if an appeal hearing will be necessary or if you need any additional clarification from me. Regards, Paul Cabot Administrator National Fuel Gas Code Attachment: UMC ROC page 378
1312.4 Appliance Shutoff Valves and Connections. Appliances connected to a piping system shall have an accessible, approved manual shutoff valve with a nondisplaceable valve member, or a listed gas convenience outlet. Appliance shutoff valves and convenience outlets shall serve a single appliance and shall be installed within 6 feet (1829 mm) of the appliance it serves. Where a connector is used, the valve shall be installed upstream of the connector. A union or flanged connection shall be provided downstream from this the valve to permit removal of appliance controls. Shutoff valves serving decorative gas appliances shall be permitted to be installed in fireplaces where listed for such use. [NFPA 54:9.6.4, 9.6.4.1] (remaining text unchanged) 1312.5 Quick-Disconnect Devices. Quick-disconnect devices used to connect appliances to the building piping shall be listed to CSA Z21.41. Where installed indoors, an approved manual shutoff valve with a nondisplaceable valve member shall be installed upstream of the quick-disconnect device. [NFPA 54:9.6.5] 1314.0 Safety Shutoff Devices for Unlisted LP-Gas Appliance Used Indoors. 1314.1 General. Unlisted gas utilization appliances for use with undiluted liquefied petroleum gases and installed indoors, except attended laboratory equipment, shall be equipped with safety shutoff devices of the complete shutoff type. [NFPA 54:9.1.4] 1316.4 New Branches. Where new branches are installed from the point of delivery to new appliances, the newly installed branches shall be required to be pressure-tested. Connections between the new piping and the existing piping shall be tested with a noncorrosive leak-detecting fluid or approved leak-detecting methods. [NFPA 54:8.1.1.4] 1316.8.4 Designed for (less than) Operating Pressures. Where the piping system is connected to appliances, equipment, or equipment components designed for operating pressures of less than the test pressure, such appliances, equipment, or equipment components shall be isolated from the piping system by disconnecting them and capping the outlets. [NFPA 54:8.1.3.4] SUBSTANTIATION: 1. Sections 1301.3, 1308.5.3.4, 1308.5.10.1, 1308.5.10.4, 1308.5.11.3, 1308.7, 1308.7.2, 1308.7.5.1, 1308.7.5.4, 1308.8, 1310.1, 1311.1.1, 1311.1.6, 1311.1.6.1, 1311.1.7.2, 1311.5, 1311.8.1, 1311.8.1.1, 1311.10.1.1, 1311.14.4, 1312.4, 1312.5, 1314.1, 1316.4, and 1316.8.4 are being revised to correlate with NFPA 54-2012. 2. Section 1308.5.11.2 is being revised to correlate with NFPA 54-2012. The standard AWS B2.4 is being deleted as this standard is not in the extraction and does not pertain to heat-fusion or welding of joints, it pertains to the qualifications of the welder. 3. Section 1308.7.5.3 is being deleted as this information is duplicated in Section 1308.7.5.4 COMMITTEE ACTION: Accept as Submitted A PUBLIC COMMENT(S) WAS SUBMITTED FOR REVIEW AND CONSIDERATION. PUBLIC COMMENT: SUBMITTER: Curtis Dady, Viega, LLC RECOMMENDATION: Request to accept the code change proposal as modified by this public comment. 1308.5.10.1 Pipe Joints. Pipe joints shall be threaded, flanged, brazed, or welded, or made by press-connect fittings in accordance with CSA LC 4. Where nonferrous pipe is brazed, the brazing materials shall have a melting point in excess of 1000 F (538 C). Brazing alloys shall not contain more than 0.05 percent phosphorus. [NFPA 54:5.6.8.1] SUBSTANTIATION: Table 1701.1 lists CSA LC4-2007 (Press-Connect Copper and Copper Alloy Fittings for Use in Fuel Gas Distribution Systems) (Same as CSA 6.3.2). Furthermore, CSA LC4 is referenced in Section 1308.5.10.2 (Tubing Joints). The scope (Section 1.1) of CSA LC4 has been revised to include steel and stainless steel materials, as well as pipe 378
Curtis Dady Technical Manager Ms. Gabriella Davis Recording Secretary, IAPMO Standards, Council International Assoc. of Plumbing and Mechanical Officials IAPMO Group World Headquarters 4755 E. Philadelphia St. Ontario, CA 91716 October 30, 2014 Subject: BSR Uniform Mechanical Code, 2015 Edition: Appeal No. 11-15 to UMC Item #333 Submitted: Curtis Dady Viega, LLC 301 N. Main, 9 th Floor Wichita, KS 67202 Statement: Opposition to Appeal No. 11-15 Grounds: The appeal makes a good point regarding conflicts between code requirements. However we firmly believe these points listed below indicate a need and justification for modification to the otherwise extracted NFPA 54 verbiage: The vote for acceptance of this Public Comment was overwhelmingly in favor with 19 approving and only 1 vote of disapproval to the TCC correlated verbiage between the UPC Item #301and UMC Item #333. *Note that UPC Item #301includes the same verbiage for the same section of that code and UPC Item #301is not under appeal. If this appeal (11-15) is successful then the two sections will not correlate. The 2015 NFPA 54 does already include the updated version (v. 2012) of CSA LC4 in the Chapter 2 Referenced Publications section. Section 5.6.8.1 Pipe Joints has not yet been updated to match the scope of the current (2012) standard version. This is due to the timing described in the next bullet point. This inclusion of the 2012 version does give evidence that the 2018 version of NFPA 54 will be updated so that the body of the code will match the scope of the current standard version. The updated version of CSA LC4 (2012) was finally published in January of 2013. Proposals to the 2015 NFPA 54 were due by June of 2012 so this precluded making a proposal to section 5.6.8.1. SDO s have a later due date to submit updates to standards already included in the code. CSA did submit and the updated version is included. The proposed verbiage poses no risk for making a substantive change to what will happen in the next code cycle of NFPA 54. The proposed verbiage is a direct addition to the Pipe Joints Page 1
section of that which is already existing in the Tubing Joints section, i.e., or made by pressconnect fittings in accordance with CSA LC-4. Is there a precedent related to never modifying extracted language? The appeal does not mention a divergence from the past, i.e., that the existing code does not include extracted language that has been modified. We believe that the existing code does include changes to extracted language when necessary to improve the code. Most AHJ s are accepting that press-connect fittings listed to ANSI LC-4/CSA 6.32 are code compliant, but not all. It is too common across the country for contractors to be happily installing press-connect fittings for fuel gas distribution systems then switch into an adjacent AHJ where the inspector red tags the installation. Even though the product is listed to a standard that is referenced in the code, and even though there is a separate listing confirming compliance to the adopted code of that AHJ, the inspectors are sometimes confused because it is not spelled out in the section they are looking to for guidance. Best case is that the code official finally makes the connection and approves, during which time the contractor frets over the economic loss of having to redo the installation. But in some instances the code official will not relent and there is one current action that will pose a severe hardship for many if a favorable resolution is not reached. Having the codes up to date with the standards eliminates this type of conflict. Recommendation: Uphold the existing action and maintain the verbiage included in UMC Preprint section 1308.5.10.1. Regard, Curtis Dady Technical Manager, Viega, LLC Attachment: UMC ROC Item #333 *Just excerpt of relevant section UPC ROC Item #301 Page 2
Page 3
Page 4