By Thomas Palkon

Revisions to the newly published 2021 plumbing codes have officially begun. As mentioned in the previous article, submittals to propose changes to the 2024 Uniform Plumbing Code (UPC) were due on January 4 and submittals to propose changes to the 2024 International Plumbing Code (IPC) were due January 11. The next step in the process will be for the International Association of Plumbing and Mechanical Officials (IAPMO) and the International Code Council (ICC) to publish the proposed changes and hold the first set of meetings to debate and take the initial vote on the proposals. While we wait for the UPC and IPC code proposals to be published, let’s take a deeper dive into 2021 UPC. Several jurisdictions should begin adopting the 2021 version of the UPC this year, so let’s take a closer look at the requirements that affect the water treatment industry.

2021 UPC – Water treatment devices
The following sections of the UPC pertain to specific requirements that may affect water treatment product compliance to the code. In this article, we have pulled the code language directly from the UPC and provide an explanation of how this section may be applicable to water treatment equipment. The focus will be on the drinking water treatment system, not the plumbing materials used to supply the system or connect to the drain. We will address installation and sizing in a future article.

Chapter 3 – General regulations
Section 301.2 Minimum Standards. Pipe, pipe fittings, traps, fixtures, material, and devices used in a plumbing system shall be listed (third-party certified) by a listing agency (accredited conformity assessment body) as complying with the approved applicable recognized standards referenced in this code, and shall be free from defects. Unless otherwise provided for in this code, materials, fixtures, or devices used or entering into the construction of plumbing systems, or parts thereof shall be submitted to the authority having jurisdiction for approval prior to being installed. This section of the UPC states that if a product standard is specified in the code, testing and certification of the product must be conducted in accordance with the referenced standard and carried out be an accredited certification agency. As an example, this section requires residential water softeners to be tested and certified to NSF/ANSI 44 and commercial softeners to be tested and certified to ASSE 1087 by an accredited certification agency. In the US, there are several certification agencies that conduct testing and certification to these standards, such as IAPMO, NSF International (NSF) and the Water Quality Association (WQA).

301.2.1 Marking. Each length of pipe and each pipe fitting, trap, fixture, material, and device used in a plumbing system shall have cast, stamped, or indelibly marked on it any markings required by the applicable referenced standards and listing agency, and the manufacturer’s mark or name, which shall readily identify the manufacturer to the end user of the product. Where required by the approved standard that applies, the product shall be marked with the weight and the quality of the product. Materials and devices used or entering into the construction of plumbing and drainage systems, or parts thereof shall be marked and identified in a manner satisfactory to the Authority Having Jurisdiction. Such marking shall be done by the manufacturer. Field markings shall not be acceptable. This section of the code requires tested and certified products to be marked or labeled by the manufacturer with the certification agency’s logo and the applicable standard. Many of the drinking water treatment standards have specific marking and labeling requirements that must be followed for the product to be certified, however the certification agency also requires marking the product with their registered certification logo. Most certification agencies publish their marking guidelines so that companies understand the options and requirements for use of the certification mark.

301.2.2 Standards. Standards listed or referred to in this chapter or other chapters cover materials that will conform to the requirements of this code, where used in accordance with the limitations imposed in this or other chapters thereof and their listing. Where a standard covers materials of various grades, weights, quality, or configurations, the portion of the listed standard that is applicable shall be used. Design and materials for special conditions or materials not provided for herein shall be permitted to be used by special permission of the Authority Having Jurisdiction after the Authority Having Jurisdiction has been satisfied as to their adequacy. A list of plumbing standards that appear in specific sections of this code is referenced in Table 1701.1. Standards referenced in Table 1701.1 shall be applied as indicated in the applicable referenced section. A list of additional approved standards, publications, practices, and guides that are not referenced in specific sections of this code appear in Table 1701.2. An IAPMO Installation Standard is referenced in Appendix I for the convenience of the users of this code. It is not considered as a part of this code unless formally adopted as such by the Authority Having Jurisdiction. This section explains that Table 1701.1 and Table 1701.2 provide a list of all the product standards covered in the UPC. Table 1701.1 includes all the standards that are also referenced in specific sections of the UPC. For example, ASSE 1087 is listed in Table 1701.1 because it is also referenced in Section 611.1. Table 1701.2 includes approved standards for products that do not include additional code language in other sections. When looking for a product standard covered in the UPC that relates to a specific drinking water treatment product, these two tables provide an excellent resource, as they include all the product standards referenced in the UPC.

310.2 Drainage and Vent Piping. No drainage or vent piping shall be drilled and tapped for the purpose of making connections thereto, and no cast-iron soil pipe shall be threaded. This section is most relevant for residential RO systems. It is common for manufacturers to include drain and supply saddle valves. The UPC prohibits the use of drain connections that require the installer to drill into the drain line to connect the RO reject line. Code-compliant installation for RO drain lines requires the use of a certified drain adapter fitting and an air gap or air gap device.

Chapter 4 – Plumbing Fixtures and Fixture Fittings
408.0 Showers.
408.1 Application. Manufactured shower receptors and shower bases shall comply with ASME A112.19.1 / CSA B45.2, ASME A112.19.2 / CSA B45.1, ASME A112.19.3 / CSAB45.4, CSA B45.12/ IAPMO Z402, or CSA B45.5 / IAPMO Z124. Prefabricated shower enclosures shall comply with IAPMO IGC 154. Shower filters that are integrated into a shower head are required to comply with ASME A1121 / CSA B45.2. Many shower filters companies list their product to NSF/ANSI 177 to demonstrate the products’ ability to reduce chlorine; however for code compliance, the filter and shower head also need testing and certification to ASME A1121/CSA B45.2.

408.2 Water Consumption. Showerheads shall have a maximum flow rate of not more than 2.5 gpm at 80 psi (9.5 L/m at 552 kPa). Shower filters that are incorporated into a shower head shall not have a flowrate of more than 2.5 gpm to comply with the UPC. As a side note, however, the state of California requires shower flowrates of not more than 1.8 gpm.

417.6 Low-Pressure Water Dispenser. Beverage faucets shall comply with ASME A112.18.1 / CSA B125.1. Low-pressure water dispensers that dispense electrically heated water and have a reservoir vented to the atmosphere shall comply with ASSE 1023. Electric devices that heat water shall comply with UL 499. Recently revised, ASSE 1023 now covers hot and cold water dispensers, with or without water filters, which is also covered by this section of the UPC. Hot water dispensers with or without water filters require testing and certification to ASSE 1023. Manufacturers of hot and cold water coolers should review ASSE 1023; if their product is plumbed in to a supply line, certification to ASSE 1023 is required.

Chapter 6 – Water Supply and Distribution
603.0 Cross-Connection Control.
603.1 General. Cross-connection control shall be provided in accordance with the provisions of this chapter. No person shall install a water-operated equipment or mechanism, or use a water-treating chemical or substance, where it is found that such equipment, mechanism, chemical, or substance causes pollution or contamination of the domestic water supply. Such equipment or mechanism shall be permitted where equipped with an approved backflow prevention device or assembly. The UPC includes detailed requirements on backflow protection. The cross-connection control sections are relevant for water softeners, RO systems and other products, such as POE backwashing filters that have a drain connection. The simplest and one of the most effective cross-connection control techniques is the use of an air gap. When connecting a water softener drain line or backwashing filter drain line, the use of an air gap is required to comply with the UPC.

603.3.1 Air Gap. The minimum air gap to afford back-flow protection shall be in accordance with Table 603.3.1. An air gap is a physical gap in space between the drain line of water treatment device or an RO reject line. Several companies have also developed air gap devices that simplify the installation of a water treatment system’s drain line and the waste piping. A physical air gap or an approved air gap device are required to comply with the UPC when connecting drain lines.

603.4.6 Integral Backflow Preventers. Fixtures, appliances, or appurtenances with integral backflow preventers or integral air gaps manufactured as a unit shall be installed in accordance with their listing requirements and the manufacturer’s installation instructions. An example of an integral backflow preventer is an air gap faucet that is used with POU RO systems. The use of an air gap faucet that has been tested and certified to NSF/ANSI 58 is a simple way to comply with the cross-connection requirement of the UPC. When connecting the drain line to the plumbing below the sink, however, do NOT drill into the drain line and use a drain saddle. A certified drain fitting must be used and there are many available options that include push-fit fittings for quick and simple installations.

603.5.12 Beverage Dispensers. Potable water supply to beverage dispensers carbonated beverage dispensers, or coffee machines shall be protected by an air gap or a vented backflow preventer that complies with ASSE 1022. For carbonated beverage dispensers, piping material installed downstream of the backflow preventer shall not be affected by carbon dioxide gas. Water treatment devices that include a carbonation option continue to increase in popularity in the US. If a water treatment device includes an option to dispense carbonated water, it will need to be tested and certified to ASSE 1022. There are, however, commercially available ASSE 1022-certified backflow preventers that can be used with the water treatment system for compliance to the code.

603.5.18 Pure Water Process Systems. The water supply to a pure water process system, such as dialysis water systems, semiconductor washing systems, and similar process piping systems, shall be protected from back-pressure and backsiphonage by a reduced-pressure (RP) principle backflow preventer. Cross-connection control for ultrapure water systems used for dialysis, laboratories, bottled water plants or other applications require an RP backflow preventer. When using an RP, it is important to note that several states also require the RP to be tested by a licensed professional one time per year. RPs provide the necessary safety to ensure the process water will not reverse flow and enter the potable water plumbing.

604.0 Materials
604.1 Pipe, Tube, and Fittings. Pipe, tube, fittings, solvent cement, thread sealants, solders, and flux used in potable water systems intended to supply drinking water shall comply with NSF 61. Where pipe fittings and valves are made from copper alloys containing more than 15 percent zinc by weight and are used in plastic piping systems, they shall be resistant to dezincification and stress corrosion cracking in compliance with NSF 14. Although we are not covering in detail the installation of water treatment devices, the UPC requires the pipe, tubing and fittings to comply with NSF/ANSI 61 when connecting the supply line of a water treatment device. Plastic pipe and fittings shall also comply with NSF/ANSI 14. Material safety of the water treatment device itself is covered by the performance standards referenced in the code.

604.2 Lead Content. The maximum allowable lead content in pipes, pipe fittings, plumbing fittings, and fixtures intended to convey or dispense water for human consumption shall be not more than a weighted average of 0.25 percent with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures. For solder and flux, the lead content shall be not more than 0.2 percent where used in piping systems that convey or dispense water for human consumption. The UPC requires products that contact water for human consumption to comply with the Safe Drinking Water Act’s weighted averages requirements for lead content. US EPA recently announced that all drinking water treatment products will need to comply with US EPA’s lead-free law, which now includes testing and certification of the equipment. NSF/ANSI 372 is often used by companies and certification agencies to test and certify water treatment products for lead-free compliance.

611.0 Drinking Water Treatment Units
611.1 Application. Drinking water treatment units shall comply with the applicable referenced standards in Table 611.1.
611.1.1 Alkaline Water Treatment. Alkaline water treatment devices shall comply with IAPMO IGC 322.
611.1.2 Scale Reduction Devices. Scale reduction devices shall comply with IAPMO Z601.
This section of the UPC provides the specific language of the product standards listed in the code. Table 611.1 lists the product standards covering residential and commercial, POU and POE filters, residential and commercial water softeners, residential and commercial UV systems, residential and commercial RO systems and residential and commercial distillation systems. This section also specifies the standard used for certification of alkaline water treatment products and the standard used for certification of scale-reducing products.

611.2 Air Gap Discharge. Discharge from drinking water treatment units shall enter the drainage system through an air gap in accordance with Table 603.3.1 or an air gap device that complies with Table 603.2, NSF 58, or IAPMO PS 65. This section repeats some of the cross-connection control requirements specific to water treatment devices. Air gaps are required for drain connections or certified air gap devices such as an RO air gap faucet, certified to NSF/ANSI 58. This section also provides the reference standards used for air gap devices that cover water treatment equipment.

611.3 Connection Tubing. The tubing to and from drinking water treatment units shall be of a size and material as recommended by the manufacturer. This section specifies that tubing recommended by the manufacturer shall be used to install the water treatment device; however Section 604.1 also requires that the pipe, tubing and fittings be certified to NSF/ANSI 61 and NSF/ANSI 14 for plastic pipe, tubing and fittings.

611.4 Sizing of Residential Softeners. Residential-use water softeners shall be sized in accordance with Table 611.4. This table provides a sizing chart for residential water softeners. We will dedicate a future article on proper sizing of POE equipment for residential and commercial water treatment equipment. In that article, we will walk through Appendix A and Appendix C along with IAPMO’s WeStand code.

Although the water treatment industry is not heavily regulated at the federal level, plumbing codes are enforced in many state and local jurisdictions. When installing water treatment equipment, it is important to understand the plumbing code requirements to avoid red tags or fines. This article provides a review of the primary sections of the UPC that address water treatment industry products. There are numerous changes in the 2021 version of the UPC for water treatment equipment when comported to the 2018 version. Companies should review the 2021 code to determine if any additional testing and certification will be required on their products and to understand proper sizing and installation requirements. If you have specific questions, IAPMO offers a variety of options for code questions and answers. We are always happy to assist.

About the author
Thomas Palkon is the Executive Vice President and Chief Technical Services Officer for the IAPMO Group and ASSE International Executive Director. He joined IAPMO in 2014. Palkon has over 20 years of experience in the water treatment industry, with expertise in product testing, product certification, standards development, professional qualification standards development, professional certification, government affairs and international operations.


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