May 2024 Professional Engineer’s Perspective: Duplicating Standards Is Not Good for the Industry

“Innovation distinguishes between a leader and a follower.” – Steve Jobs

It is no secret that I prefer the ANSI-accredited process when it comes to codes and standards development. Over the last couple years, I published two articles about why: The ANSI-accredited development process produces a better product because final decisions are made by the consensus body in accordance with the ANSI Essential Requirements for due process. Due process means that any party (organization, company, government agency, individual, etc.) with a direct and material interest has a right to participate by expressing a position and its basis, having that position considered, and having the right to appeal any decision. Due process allows for equity and fairness. As I detailed in those articles, I prefer the ANSI-accredited process as used by IAPMO to develop the Uniform Codes. When due process is followed as part of an ANSI-accredited codes and standards development, it is good for the industry, public health, safety, and welfare. (The two articles can be found on ASPE Pipeline and uniformcodes.org.)

Unfortunately, I recently learned of the misapplication of the ANSI Essential Requirements by the International Code Council (ICC) for strictly competitive reasons. While (as mentioned in my previous article), ICC follows a Governmental Process for their I-Codes, where only governmental members are afforded a vote, they also create some standards via an ANSI-accredited process. Unfortunately, they seem to be ignoring some ANSI Essential Requirements in the process for at least one of these standards. Furthermore, I have also learned that ICC has filed Notice of Intent for three additional standards that conflict with existing ANSI-accredited standards, further suggesting that ICC refuses to participate in the betterment of the industry but rather creates confusion for competitive reasons, which jeopardizes health and safety. It is also unfortunate that ICC has taken advantage of a pandemic (Covid-19), as they have used “post-covid” as justification to duplicate existing national standards.

ANSI Essential Requirements and Duplication

ANSI has essential requirements for their due process (with my emphasis on the expanded items), which are listed below:

  • Openness
  • Lack of dominance
  • Balance
  • Coordination and harmonization: “Good faith efforts shall be made to resolve potential conflicts between and among existing American National Standards and candidate American National Standards.”
  • Notification of standards development
  • Consideration of views and objections: “Prompt consideration shall be given to the written views and objections of all participants, including those commenting on the PINS announcement or public comment listing in Standards Action.”
  • Consensus vote
  • Appeals
  • Written procedures
  • Compliance with normative American National Standards policies and administrative procedures

Reading through the list, I want to focus on a specific item: standards should NOT duplicate similar work. The reason for this is that the codes and standards development should not be competitive because in the United States, codes and standards development is largely due to volunteers. (Although paid staff for codes and standards developers help facilitate the process, they are not allowed to vote or overtly influence final outcomes of the process.) Having different organizations working on the same task leads to industry fragmentation, which leads to both confusion (“which standard should I follow?”) and delay (“which standard should volunteers work on and resources go to?”). Standards development should not be competitive. This is why preventing duplication is a central component of ANSI Essential Requirements.

IAPMO Water Demand Calculator Timeline

In regards to right-sizing, let’s look at some important milestones of how the IAPMO Water Demand Calculator (WDC) became part of IAPMO’s ANSI-approved code:

  • In 2013, IAPMO initiated a memorandum of understanding (MOU) with ASPE and the Water Quality Research Foundation (WQRF) to form a special task force to revise the methodology for properly estimating premise plumbing water supply demands in response to the increased use of water-conserving plumbing fixtures, fixture fittings, and appliances, and the subsequent decreased demand for water in single- and multifamily residences. The task force eventually also included the University of Cincinnati (UC).
  • The WDC was first introduced in 2015 as a proposal (Item 350) to the 2018 Uniform Plumbing Code (UPC)​ by the IAPMO Pipe Sizing Task Group​.
  • The WDC was first incorporated into the 2018 Uniform Plumbing Code as Appendix M.
  • The WDC was incorporated in accordance with the ANSI-accredited development process.​
  • The WDC was introduced into the Water Efficiency and Sanitation Standard (We-Stand) in 2017.
  • Task force members Professor Steven Buchberger, Timothy Wolfe, PE, Dan Cole, and Toritseju Omaghomi were awarded the ASPE Award for Scientific Achievement in 2018 at the ASPE Convention & Expo in Atlanta for their work.
  • In 2021, IAPMO initiated the first annual Water Demand Calculator Virtual Summit, which highlighted benefits of the WDC, including studies showing construction cost reductions and water and energy savings by using the WDC in lieu of Hunter’s curve. Additionally, example projects from California to New York were highlighted showing the universality of the WDC.
  • Following the Annual Water Demand Calculator Virtual Summit, IAPMO expanded the task force into a task group and began to develop a Water Demand Calculator for commercial buildings.

In summary, IAPMO began organizing industry efforts around right-sizing back in 2013 as part of not just an ANSI-approved plumbing code (the UPC), but also an ANSI-approved standard (WE-Stand).

ICC 815: An Unnecessary Effort

In 2022, almost a decade after IAPMO had started the research work for estimating more accurate peak flow rates and almost half a decade after the WDC had already been adopted as part of an ANSI-approved code and standard, ICC initiated a new standard project with ANSI titled BSR/ICC 815-202x: Standard for Sizing Water Distribution, Sanitary Drainage, and Vent Piping Systems with the following description:

“A new standard would provide a complete plumbing system design method for sizing indoor water, sanitary drainage, and vent piping for residential, mixed-use, and institutional occupancies based on the water use of plumbing fixtures and appliances that are manufactured today, technical advances in estimating water usage patterns, and the impact of the Covid-19 pandemic as more people work from home. Pipe sizing provisions in current codes and standards are predominantly based on outdated water usage patterns and do not address post-Covid 19 societal changes.”

From an engineering standpoint this description of need makes no sense. Post-pandemic, we now have had a return to “normal,” so the entire purpose seems to be in question, also leading me to wonder if ICC understands basic engineering principles: It seems to conflate volume of water used to an instantaneous peak flow rate. By the time ICC had filed this PINS (project initiation notification system), IAPMO had already developed a solution for residential occupancies and had already started working on commercial occupancies as part of an ANSI-accredited code process.

Duplication for Competitive Reasons Adds Confusion to Industry

These actions lead me to believe that the only reason ICC wishes to develop this standard is because of competitive reasons. Why not just work with IAPMO on the Water Demand Calculator? Why create something completely separate from the work IAPMO is doing? Perverting the ANSI process for competitive reasons should be concerning for the entire industry: It should not be tolerated.

I’m not the only one to notice. As my colleague Ron George indicated in a recent industry publication:

“IAPMO has been working on researching and developing a water demand calculator that reduces the old, outdated Hunter’s curves, which were developed from research done by Dr. Roy B. Hunter of the National Bureau of Standards, now called the National Institute of Standards and Technology. Hunter’s research was conducted about 82 years ago. Since that time, there have been many mandatory and voluntary reductions in fixture flow rates. The ICC [815] standard appears to be duplicating the IAPMO effort.”

Mr. George is correct here; the ICC is duplicating an effort that IAPMO has already made. Worse, the only reason ICC seems to be doing this is because of competitive reasons: With the WDC being adopted in UPC and IPC jurisdictions among state-developed codes, it clearly has become a popular tool for plumbing design professionals and contractors across the country.

ICC 815: Preventing Industry Participation

I have learned that ICC is requiring their volunteers to sign a non-disclosure agreement (NDA) to participate in their processes, such as for ICC 815. An NDA should not be a prerequisite to participate in an open consensus process for the formulation of an industry standard, especially one that obviously duplicates other efforts. Volunteers should be able to participate, collaborate, and share of information without fear of a lawsuit by ICC.

Other Duplication Efforts by ICC

ICC does not stop with the duplication of the IAPMO Water Demand Calculator but has also recently filed notices of intent for several standards, again taking advantage of an unfortunate event for competitive reasons. In January, ICC filed NOIs for the following proposed standards.

NOTE: The fact that NFPA, ASHRAE, ASPE, and IAPMO each have their contributions to the standards reduces, if not obliterates, much of the arguments as presented.

  1. BSR/ICC 1670-202x: Standard for Plumbing Systems in Hospitals and Healthcare Buildings. This standard will duplicate NFPA 99, ASHRAE 188, ASPE 82 (ANSI candidate standard), and the Uniform Plumbing Code (Chapter 13) as the appropriate plumbing provisions are already addressed in these national standards/codes.
  2. BSR/ICC 1600-202x: Professional Qualifications Standard for Onsite Direct Potable Water Reuse Systems. This standard duplicates ASSE professional qualification standards 10000, 21000, and 22000, as water reuse systems and green applications are addressed in these ANSI standards.
  3. BSR/ICC 1675-202x: Standard for Plumbing Systems in Tall Buildings. This will duplicate ASHRAE 188 and ANSI-candidate IAPMO Z1399.
  4. BSR/ICC/THIA 1215-202x: Design, Construction, and Regulation of Tiny Houses. This standard duplicates existing ASTM activities. ASTM Tiny Houses E06.26 has six approved standards already in progress that include terminology, foundations, tiny houses on wheels (chassis), certification-administrative provisions, plan review, inspection, and third-party requirements, tiny house communities, and micro-grid utilities. Though this is off-topic from plumbing, it is an example of how ICC in general fails to work with the industry.
  5. BSR/ICC 825-202x: Private Sewage Disposal Systems. This duplicates the Uniform Plumbing Code (Appendix H, Private Sewage Disposal Systems), which has existed in the UPC for decades. Even the titles are the same, and yet ICC continued with this project. It is clear that the intention of ICC is to replace their non-ANSI-accredited (IPSDC) with the proposed ANSI ICC 825, neglecting the ANSI Essential Requirements.

ICC is fragmenting our industry to work on a duplicated effort, which does not help the industry. As plumbing design professionals, we need to care about how codes and standards are developed, as it impacts public health and safety, which is the central tenet of engineering ethics. Code and standards organizations should act in such a way that models the best behavior, not the worst. Not following ANSI Essential Requirements leads to a focus on competition, not science, and a focus on competition can lead to attempts to eliminate the spark of innovation for political advantage. We, not to mention the public at large, deserve better than this, especially because plumbing is one of the bedrocks of modern civilization. I hope ICC, if not ANSI, recognizes this and works to place the effort of right-sizing with the leaders of this effort: IAPMO, ASPE, ASHRAE, ASTM, and others. If not, this should not be considered an ANSI standard.

It is time to end this completive effort and to join in the common good of a single plumbing code that serves the public good. We have a single electrical code, developed by NFPA in conjunction with IEEE (Institute of Electrical and Electronics Engineers). Why should we have competing model plumbing codes? The plumbing codes should be developed based on science and engineering principles in an open ANSI process. It should not be a completion between model codes or developers.

About the Author

David D. Dexter, FNSPE, FASPE, CPD, CPI, LEED BD+C, PE, is a registered Professional Engineer, Certified Plumbing Inspector, and Certified Plans Examiner with more than 40 years of experience in the installation and design of plumbing systems. He specializes in plumbing, fire protection, and HVAC design as well as forensics related to mechanical system failures. Dave serves as Chair of ASPE’s Main Design Standards Committee, Chair of the Bylaws Committee, Co-Chair of the College of Fellows Selection Committee, and Co-Chair of the Professional Engineer Working Group. He also was the 2008–2009 President of the Engineering Foundation of Ohio, 2010–2011 President of the Ohio Society of Professional Engineers, and 2012–2014 Central Region Director for the National Society of Professional Engineers.

The opinions expressed in this article are those of the author and not the American Society of Plumbing Engineers.

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