Do Code Definitions Matter?
You bet your bilateral symmetry they do
In just about every code there is an entire chapter dedicate solely to definitions. Does anyone really pay attention to it or do they skip over it like a lot of people do with the Administration chapter? My guess is that for a lot of people, the plumbing code starts with Chapter 3 General Regulations. The administration chapter may often not apply since many jurisdictions have their own systems and regulations in place for setting fees and how the office will operate. So, it would make sense to skip that chapter and some jurisdictions go as far as to amend it out of the code.
Chapter 2 likely also gets overlooked because its title and content seem so basic that it becomes easy to downplay its importance. As the staff liaison for IAPMO’s Education and Training Committee, I can tell you that even in a room full of code experts there is disagreement in how important definitions are to cover. Some are adamant that the definitions in Chapter 2 are among the most important elements of the code. Others feel simply that definitions are necessary, but of fairly little consequence. As someone who approaches the code from the perspective of “how are we going to teach this?” rather than trying to weigh in on technical importance, I have had the opportunity to make some objective observations over the years.
The Case of Horizontal Wet Venting
A few years ago, horizontal wet venting was allowed by the Uniform Plumbing Code for the first time. This hit those who used the code hard and the introduction of this language proved to be much more controversial than expected. Although horizontal wet venting had been used in parts of the country for decades without a problem, many UPC users were concerned about whether these systems would actually work or would create other problems. The uproar led to the creation of an ad hoc committee to reexamine the language, a Tentative Interim Amendment, dedicated training at three consecutive IAPMO conferences, several full-capacity webinars, online training courses, and the mass consumption of over-the-counter antacids. Even code experts on the Education and Training and UPC Workshop committees could not agree what was acceptable and whether the systems would work.
Why was this concept so hard to comprehend and accept? To be fair, some issues were related to the natural tendency to fear the unknown. Others had a difficult time determining where the vertical wet vent ended and the horizontal wet vent started. As I worked with my committees and watched them struggle to get on the same page about what the code intended regarding this topic almost to the point of throwing things across the room, I began to notice something interesting. The concerns most of the individuals against horizontal wet venting had stemmed from a misunderstanding of how a “bathroom group” was defined.
In the code, a bathroom group is defined as, “A group of fixtures consisting of a water closet, one or two lavatories, and either a bathtub, a combination bath/shower, or a shower and may include a urinal or bidet and an emergency floor drain.” It turned out, that many people also include toilet rooms without a tub or shower in their personal concept of a bathroom. If one is thinking of horizontal wet venting what many people refer to as a powder room or the typical public restroom that may have banks of toilets and urinals, but lack an actual bathing facility, then it becomes easier to see where their concern might come from. In this case, something as simple as a misunderstood definition was a large factor into why the new language regarding horizontal wet venting met with such harsh criticism. People were attempting to apply the new language to a flawed conception of what the language was intended to regulate.
As a side note, the TIA that resulted from all of the controversy clarified the definition of “bathroom group” and created a new definition for bathrooms.” By way of the TIA, bathroom groups were defined as “Any combination of fixtures, not to exceed one water closet, two lavatories, either one bathtub or one combination bath/shower, and one shower, and may include a bidet and an emergency floor drain.” The definition for “bathroom” states: “A room equipped with a shower, bathtub, or combination bath/shower.”
At IAPMO, I work with three different committees that focus on creating educational offerings for the industry. There is not a single meeting I have with these incredibly knowledgeable people throughout the year where someone does not complain about this definition. Why? They believe that the definition of readily accessible is simply too subjective and to say something is readily accessible is comparable to saying that I am “kinda handsome.” It really depends on someone’s personal idea of what is or is not handsome, and if your idea of handsome is Brad Pitt, then handsome I am not.
They feel that readily accessible is the same way. The code defines it as: “Having a direct access without the necessity of removing a panel, door, or similar obstruction.” The definition does its best to define it a concrete way, but the argument I frequently hear is this: Does “having a direct access” mean the same to 6-foot 4-inch, 55-year-old inspector as it does to a 5-foot 7- inch, 26-year-old-installer? In the tight spaces where we see water heaters and other appliances sometimes installed, the argument could be made that to the large inspector, with some wear and tear on his body from a lifetime in trade, many installations would not seem to have a direct access.
Some readers might already have sniffed out the flaw in this argument. In this case, the real issue that is being argued does not really have much to do with being “readily accessible”. The real concern being expressed is clearance and ease of access. Any installation that allows for access without the need to remove anything or move something out of the way complies with the definition and any related provisions. If there are any provisions that impact that installation that deal with clearance, those need to be met and enforced. If the installation meets all the relevant code requirements it must be considered in compliance with the code, even if it is not necessarily easy or comfortable to get to.
It is impossible to know how many arguments between contractors and inspectors have taken place over years due to a misinterpretation of the definition. What does seem certain is that there will continue to be arguments between these two groups regarding installations that are required to be installed so that they are “readily accessible.” The individuals on both sides of the argument better be prepared to make a compelling case that their interpretation of the definition is correct.
As the 2015 code cycle arrives, code users will be bombarded with changes to the code that they are now going to need to understand and apply. Among these code changes are the addition of new definitions. In the upcoming release of the 2015 UPC, there are indeed some new definitions that code users will want to ensure that they know and understand.
Several terms have been added with formal definitions that were used in previous versions, but never actually defined. In particular, “Accepted Engineering Practice” is new, although it have used in numerous sections throughout the UPC in the past. The new definition defines this term as “That which conforms to technical or scientific-based principles, tests, or standards that are accepted by the engineering profession.” In the past, provisions requiring an installation to be designed and installed according to accepted engineering practices were very difficult to enforce due to the fact that what constituted accepted engineering practices was never defined. This new definition assists the code user in applying and enforcing this term, and is consistent with terminology used in other industry standards.
This definition clearly defines the parameters required to substantiate a plumbing system will meet the minimum requirements accepted by known practices. These requirements are no longer ambiguous and will require the designer to prove that the proper engineering practices have been met with quantifiable and proven results. This may include references to established design principles and other testing data. American Society of Plumbing Engineers publishes design handbooks that are generally accepted by the industry.
To attempt the answer the original question of this article, “Are definitions important?” the message would be that they are incredibly important and sometimes even critical. In fact, as this article was being written, I had to take a call from a committee member and instructor, where he indicated that a client we will be doing training for would like to do a full day on just covering the definitions in Chapter 2. Perhaps, not everyone may agree about the importance of definitions, but someone out there must recognize it.