The three-year revision cycle of the 2021 plumbing codes are well underway. All proposals have been presented to the committees of the International Association of Plumbing and Mechanical Code Officials (IAPMO) for the Unform Plumbing Code (UPC) and the International Code Council for the International Plumbing Code (IPC). Now that the debate is underway for the 2024 code cycle, let’s review a couple product requirements in accordance with the 2021 UPC. At this time, several authorities having jurisdiction (AHJs), including states, counties and cities, are beginning to adopt the 2021 versions of the codes. In this article, we will review some the UPC requirements for two product types, a residential and commercial water softener, and a filtered water dispenser that includes a hot and cold water option along with a sparkling or still water option.

Water softener UPC compliance
Chapter 6 of the UPC includes many of the requirements for water treatment equipment. A good place to start when determining code compliance of water treatment equipment is Section 611.0 Drinking Water Treatment Units. In the 2021 version of the UPC, Section 611.1 refers to Table 611.1 for several of the product standards required for drinking water treatment units. Reviewing Table 611.1, it illustrates that residential water softeners need to comply with NSF 44 and commercial water softeners need to comply with ASSE 1087. We now need to refer to Section 3 of the UPC to understand what is meant by “needs to comply” with NSF 44 and ASSE 1087. Paraphrasing Section 301.2 of the UPC, it states that devices shall be listed (third-party certified) by a listing agency (accredited conformity assessment body) as complying with the applicable standard listed in the code. Therefore, a residential water softener needs to be certified by an ANSI-accredited certification body for compliance to NSF 44 and a commercial water softener needs to be certified by an ANSI-accredited certification body for compliance to ASSE 1087.

Now that we understand the product performance standard(s) required for UPC compliance, we also need to check other sections of the plumbing code to identify any additional code requirements, many of which include proper installation of the water treatment device. For residential or commercial water softeners, the following UPC sections also apply.

301.2.1 Marking. This section requires products to be marked with the accredited certification body’s product certification logo. There are many product literature and labeling requirements in NSF 44 and ASSE 1087 that must be included on or with the product, but this section of the code is specific to the certification agency’s mark being on the product. Some examples include: IAPMO Research and Testing authorizes its registered UPC shield on certified products; NSF International authorizes its registered Blue Mark on certified products and WQA authorizes its registered Gold Seal on certified products.

310.2 Drainage and Vent Piping. This section informs the installer that they cannot drill or tap the building or home drainage system when connecting the water softener drain line. In the cross-connection control section of the code, it explains that the drain connection must be made with a proper air gap connection. Proper air gap connections are also included in the installation manual for many water softeners.

603.3.1 Air Gap. When connecting residential or commercial water softener drain lines, an air gap is required. The minimum air gap to afford back-flow protection shall be in accordance with Table 603.3.1. This section of the code provides the specific details of the required air gap size depending on the drain pipe diameter.

603.5.18 Pure Water Process Systems. Commercial water softeners used to supply 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. RPs are commonly used to prevent process water from reversing flow going back into the potable water supply.

604.1 Pipe, Tube, and Fittings. When installing a water softener, the pipe, tubing, fittings, solvent cement, thread sealants, solders and flux used 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.

604.2 Lead Content. The UPC and now the US EPA requires that all products and components used in potable water systems to comply with 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 surface. 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. Although not a UPC requirement in the 2021 edition, companies should consider obtaining lead-free product certification on water treatment products to comply with the new US EPA lead-free rule that was recently published. Also, there are state laws that have required low lead product certification for several years, such as California’s AB1953.

611.2 Air Gap Discharge. This section is somewhat similar to section 603.3.1 but it specifically lists product standards that apply to air gap devices that may be used to connect a water softener drain line to the building drainage system. 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 (ROs), or IAPMO PS 65 (PS 65 can be used for water softener air gap devices).

611.4 Sizing of Residential Softeners. The UPC provides requirements for sizing a residential water softener in Table 611.4. This table references the connection size of the softener control valve based on the number of bathrooms in the household. For homes with over four bathrooms and commercial installations, the installer will need to use Appendix A or Appendix C along with IAPMO’s WeStand code for proper sizing of the water softener. In a future article, IAPMO will have one of its licensed plumbers write an article on how to use Appendix A, Appendix C and WeStand for sizing a water softener. It is important to understand if the local jurisdiction has adopted the WeStand Code prior to using it for sizing. IAPMO also offers sizing training seminars to assist with using these appendices for proper sizing.

Summary of UPC requirements for water softeners
1. Residential softeners are required to be certified to NSF 44.
2. Commercial softeners are required to be certified to ASSE 1087.
3. Make sure the product label includes the certification agency’s mark of conformity.
4. Installation requires a proper air gap connection or certified air gap device when connecting to the buildings drainage system.
5. Connection plumbing and fittings to the softener are required to be certified to NSF 61 or NSF 14.
6. For commercial process water installations, an RP is required for cross connection control.
7. The softener, the piping and the fittings need to be certified as lead-free to comply with the plumbing code and US EPA’s recent lead-free rule.
8. The softener needs to be sized correctly prior to installation.

It’s also important to note that jurisdictions include amendments to the model plumbing codes, so it’s important to understand the code requirements per the jurisdiction the product is being installed. This article outlines the main code requirements for installing a water softener, but companies should work with local plumbing inspectors for all the requirements for legal installations, such as licensing laws, unique backflow protection requirements, isolation valves, etc.

Filtered water dispenser with hot, cold, still and sparking options
Now let’s review a slightly more complicated water treatment product in terms of UPC compliance, a filtered water dispenser that has hot, cold, still and sparkling options. Since this product includes a water filter, it’s best to start in Section 611.0. Table 611.1 lists a couple standards for residential and commercial water filters. For residential filtration products the contaminant reduction claims are used to determine the standard used for testing. For filters that make aesthetic claims, such as chlorine or iron reduction, the product would be tested to NSF 42 and filters that make health claims, such as lead or arsenic, NSF 53 is used for testing. People outside the water treatment industry are often confused as to why there are two similar standards for water filters. It’s important to understand that the filters marketed claims determine which standard shall be used. For commercial products testing to ASSE 1087 is required; however, for commercial modular products, they need certification to ASSE 1087 and NSF 42 or NSF 53. NSF 330 defines commercial modular products as, “A system consisting of multiple components attached to a manifold, produced specifically for food service applications, installed by an authorized plumber or authorized agent of the manufacturer, and not intended for use in residential applications.”

Now that we have a basic understanding of the filtration performance standard(s) requirements, let us review other sections of the UPC to determine the additional code requirements.

Section 301.2 – like water softeners water dispensers need to include the accredited certification agency’s registered product certification mark on the product.

Section 417.6 Low-Pressure Water Dispenser. Beverage faucets shall comply with ASME A112.18.1/CSA B125.1. Products that include a separate tap/faucet used for dispensing the water will need to be certified to ASME A112.18.1/CSAB125.1. This standard covers a variety of plumbing fixtures and fittings, including all faucets that dispense water for cooking and drinking.

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. Systems that dispense hot water require certification to ASSE 1023 and electrical certification to UL 499. ASSE 1023 has recently been revised to also cover cold water dispensers.

Filtered water dispensers do not typically connect to the building drainage system like water softeners or ROs so we do not have to worry about proper air gap drain connections or other backflow prevention measures. If the system includes a sparking water option, it needs to comply with Section 603.5.12 of the UPC.

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/sparkling option continue to increase in popularity in the US. If your water treatment device includes an option to dispense carbonated water, it will need to be tested and certified to ASSE 1022. There are also commercially available ASSE 1022-certified backflow preventers that can be included with the water treatment system for compliance to the code during installation.

Like water softener installations, all piping and fittings used for installation need to comply with NSF 61 or NSF 14. Also, certification to the US EPA lead-free rule is applicable for filtered water dispensing devices and the connection tubing and fittings. Most companies demonstrate compliance with a listing to NSF 372 from an accredited certification agency.

Summary of UPC requirements for a filtered water dispenser with hot, cold, still and sparkling options.
1. Residential systems are required to be certified to NSF 42 or NSF 53.
2. Commercial systems are required to be certified to ASSE 1087.
3. Commercial modular systems are required to be certified to ASSE 1087 and NSF 42 or NSF 53.
4. Make sure the product label includes the certification agency’s mark of conformity.
5. Installation requires a proper air gap connection or certified air gap device when connecting to the buildings drainage system.
6. Connection plumbing and fittings to the device are required to be certified to NSF 61 or NSF 14.
7. For systems with a separate faucet, the faucet requires certification to ASME A112.18.1/CSA B125.1.
8. Hot water dispensers require ASSE 1023 certification and electrical certification to UL 499.
9. Sparking options require certification to ASSE 1022 or installation of an ASSE 1022-certified backflow prevention device with the system.
10. The system, the piping and the fittings need to be certified as lead free to comply with the UPC and US EPA’s recent lead-free rule.

Again, it’s important to note that oftentimes, jurisdictions include amendments to the model plumbing codes, so it’s important to understand the specific code requirements per the jurisdiction the product is being installed. This section attempts to outline the main code requirements for installing a residential or commercial water dispenser with hot, cold, still and sparking options but companies should work with local plumbing inspectors for a complete understanding of all the requirements for legal installations, such as licensing laws, unique backflow protection requirements, etc. This article has been written for information and guidance but should not be used to defend compliance with the UPC.

About the author
Thomas Palkon is the Executive Vice President and Chief Technical Services Officer for the IAPMO Group and ASSE International Executive Director. Palkon joined IAPMO in 2014. He has over 25 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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