Listed and labeled: Code compliance and third party product certifications
Getting past the ‘bouncer’ is only half the battle
Have you ever had this experience?
You are standing in line at a new fancy nightclub when that really cool friend of yours, who is already inside, says, “Hey, he’s cool. I can vouch for him. Let him in.” And then you’re allowed to go to the front of the line, bypass the extremely large and musclebound bouncer, and get right into what is likely to be the greatest night or your life, while the rest of the people in line look on in jealousy.
If you are anything like me, then no, you have not.
This has never happened to you, but you’ve seen it happen on television and movies and it seems like it would be awesome. But what does this have to do with plumbing and plumbing codes? Well, in a way, there is a method for plumbing products to jump to front of the line and get past the massive bouncer and straight into the “Moving Water Party.” Sure, that sounds like the worst party in history, but that is not the point. The point is that third-party product certification bodies are that cool friend who vouches for products and ensures they satisfy standards, meet code requirements, and help gain acceptance by the authority having jurisdiction.
I would be really surprised if someone could open the plumbing code to a random page and not quickly find a provision that requires something to be “listed and labeled.” Throughout the code, the plumbing products used in plumbing applications, such as piping and fixtures, are almost always required to be listed and labeled for their intended use. So, what does it really mean for a product to be listed and labeled? So what? This is where third-party certification agencies come in.
Third-party certification agencies play an important role in confirming that products meet the required product standards and they offer a quick way for installers and inspectors to see that a product is acceptable to use and that it is code compliant. Before they hit the market, product manufacturers send their products to a recognized lab for testing. Some certifiers have their own labs, while other certifiers examine the lab results from independent, accredited labs and decide whether or not to certify that product based on the lab results. While in the lab, products are tested vigorously to see if they perform the function for which they are intended and if they do so reliably.
But testing products is only one part of the equation. Certifiers are not only interested in the testing of the products themselves, but also in the manufacturer. At IAPMO R&T for example, the manufacturing facility is inspected and a review of the manufacturer’s quality assurance policies and procedures, compliance records, and calibration records is performed by a trained inspector. The inspection report and the test data are then sent to IAPMO’s Product Certification Committee for a final decision on certification. If certification is granted, there is an ongoing process of periodic inspections and an annual review of the file to ensure the manufacturer is still in compliance with the terms of which certification was originally granted. As long as the manufacturer stays in compliance and the product still lives up to the original testing, the third-party certifying agency will continue to list it (the “listed” part of the “listed and labeled” requirements).
All of this leads up to what the manufacturer really wants — the ability to label (here is the “labeled” part) its product with the certifying body’s mark of conformity. Each third-party certification agency, such as IAPMO R&T, ICC Evaluation Services, Underwriter’s Laboratories, Canadian Standards Association, and others, each has its own distinct marks of conformity. Think of this mark as the stamp you get on your hand when you get into the club (or in my case, Chuck E. Cheese’s), that allows you to forgo the long line, and the scary guy in the tight t-shirt, and get right in. This stamp will also allow you to step outside and get back in without having to get back in the line that stretches down the block.
Having a third-party certification agency’s mark of conformity on a product helps that product to move through the marketplace. Without this mark from a recognized third-party product certification agency, the code compliance of that product would have to be proven every time someone wanted to install it. Imagine how difficult that would make it for manufacturers to ever come out with new products and for installers to use them.
From an installer’s perspective, there are benefits to using products that are third-party certified. If customer service and being able to stand behind the work you do is important, using listed and labeled products provides an added level of confidence that the materials and fixtures you use meet the standards. This is important because, as we all know, if a pipe breaks when it shouldn’t, the installer or contractor gets blamed. If you try to explain that the workmanship was sound but the product failed, you run the risk of being accused of cutting corners and using cheap materials. Although it is not a guarantee, using products that carry a mark of conformity can help avoid those troubles.
In addition, when the products are tested in the lab, the technicians performing the test do not just test for reliability, they test to make sure that each product conforms to all applicable standards. After all, it would not be any good to have a faucet that can be turned on and off a million times if there is a non-compliant or illegal amount of lead present. Using products that have been certified, listed, and labeled greatly reduces any such guesswork.
Perhaps the greatest benefit in terms of real world time and money is knowing that products bearing a mark of conformity can be readily used without much concern about whether or not it will be accepted and allowed during the inspection process. Inspectors will be looking for those marks of conformity and, if they do not see them, can fail the inspection and demand they be removed.
Regardless of the size of the job, this gets very expensive and very time consuming. Even if you are confident about the product, trying to convince the authority having jurisdiction can be an arduous task that eats up a lot of valuable time. In the end, you still run the risk of having to tear everything out, finding, and purchasing new materials and/or fixtures, and then redoing the same work again. In this case, the inspector is the bouncer and he has an important job to do. The mark of conformity is the stamp on the hand the product got when its cool friend, the third-party product certification body, said, “Hey, he’s cool. I can vouch for him. Let him in.” Once the bouncer sees that stamp on your hand, you’re in. The same holds true for the inspector. Once he sees that mark of conformity on that fixture, PVC piping, pump, fitting, or any other product, he has confidence the product meets all minimum standards for code-compliant operation.
This is especially important given the growing need for the reduction in water use and the increase in water re-use. As new technology hits the market to meet these needs, no one wants these products to be rejected just because they haven’t been seen before. We offer a lot of training to educate inspectors and others in the plumbing industry about new and emerging technologies, but when it comes to everyday, on-the-job reality, it is the mark of conformity that is going to enable that technology to be installed and accepted without much hesitation.
Although the verbiage is very simple, there is a lot that goes into and that is implied by the phrase “listed and labeled” when it appears in the code. Third-party product certification agencies play an important role in streamlining the construction process. They provide that fast way into the nightclub, past the line and the bouncer, so you can get into the party of the century and dance the night away in what is undoubtedly the best night of your life.
At least that’s what I assume happens. As I said, I didn’t get in.