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Code Update

Why are there plumbing product standards?

By Ron George, CIPE, CPD
President, Ron George Design & Consulting Services

Imagine yourself in Baltimore, Maryland, at 10:48 in the morning of Sunday, February 7, 1904, standing in front of the John E. Hurst & Company building on the south side of German (now Redwood) Street between Hopkins Place and Liberty Street. One of the most important lessons about standardization was about to occur. It was the great Philadelphia fire and conflagration of 1904. There had been other big fires in the past, but none of them was quite like the 1904 fire, because of the high winds and the many wooden structures that had been built so closely together.

The scope, magnitude and rapid spread of this fire led the Baltimore Fire Department to very quickly call for assistance from a number of cities and states. Response was excellent, given the circumstances, but operations became difficult because of the different sizes and shapes of firehose couplings, some of which simply would not fit any hydrants or other fire departments' hose threads. The fire departments also learned how quickly a conflagration could spread through combustible buildings in a downtown district that featured many close combustible exposures.

According to newspaper reports, an alarm went immediately from the automatic box attached to the outside wall of the building. This brought response from Baltimore's Engine 15, a steam pumper and hose wagon (both pulled by two-horse hitches), Truck Company 2, the Fire Insurance Patrol and District Chief Levin H. Burkhardt. Responding firefighters started attacking the basement fire, but within seven minutes it spread rapidly up through an unenclosed well-hole in the six-story brick building, bursting explosively from the top floor and involving nearby buildings that had unprotected window openings. For the next 30 hours, this conflagration burned completely out of control, destroying 155 acres (80 city blocks) and 2,500 buildings, putting 50,000 people out of work and causing an estimated financial loss of $50 million (in 1904 dollars).

As the fire progressed through the city, desperate calls for assistance were sent to Washington, Philadelphia, New York and other municipalities. Each of those cities sent horse-drawn apparatus on railroad freight cars. Apparatus and manpower from Philadelphia and Wilmington, Delaware, arrived in about two hours after being called. The New York train made a record run in a little over four hours. Washington, which first heard about the fire at 11:40 a.m., sent two engine companies, Nos. 3 and 6, by a special Baltimore and Ohio train that arrived about 1:30 in the afternoon. (Running time of this train was reported as 38 minutes, just two minutes slower than the record train run for this distance.)

Later, Washington sent Engines 2 and 8 and additional manpower, which totaled 75 men, including Chief Engineer William T. Belt. Other cities sending apparatus and manpower included Chester, York, Altoona, Harrisburg, and Phoenixville, Pennsylvania; Annapolis, Sparrows Point, Relay and St. Denis, Maryland and Atlantic City, New Jersey. Total manpower at the fire included 1,700 firefighters, 400 of whom were unattached volunteers.

When they first arrived, out-of-town fire companies were delayed in attacking the fire, partly because of the general confusion, and also because firehose couplings came in many shapes and sizes and many would not fit the hydrants. About 40 fire companies went to the dock area and were able to draft from the waterfront. Other fire companies drafted water from barrels and wooden horse troughs set against open hydrants.

What stunned the fire departments and others who saw the fire was the rapid spread from building to building and the intense heat development, even within fire-resistive structures. Weather conditions were normal, with low winter temperatures, but there was a strong wind (between 20 and 30 mph). The fire started in the heart of the business section and, because of wind direction and general lack of exposure protection, it spread easily from building to building.

Hose streams from fire apparatus were practically useless against the intense heat. An NFPA report issued a few months later included this statement:

"In contradiction to ordinary fires in individual buildings which usually spread vertically from floor to floor, this conflagration was essentially a horizontal fire as regards its attack and progress in each building. As a rule, every story was ignited simultaneously through the exterior windows and the fire swept across the building and out at the opposite side. Under these circumstances, the protection of floor openings will avail but little if the windows are unprotected.Ó

In a desperate attempt to halt the violent spread of the fire, city officials authorized the dynamiting of structures. Two fire officers were designated by the mayor to select buildings that were to be demolished. Local building contractors were selected to carry out the demolition. Explosive charges were placed inside buildings, at the base of supporting columns and detonated by an electric "hot box." These tactics, however, did not stop the spread of the conflagration, since even the largest charges of explosives failed to flatten or crumble a building. The heat of the fire was estimated at 2,200 to 2,500 degrees Fahrenheit, and a shower of hot embers and radiant heat contributed to its spread.

Typical of newspaper descriptions of this famous conflagration is the paragraph below, taken from the Leslie's Weekly Newspaper February 18, 1904, issue.

"...The night was black with the smoke and red with the flames as far as the eye could see. The furious gale tossed millions of great flaming cinders into the air. The panorama changed rapidly. Suddenly a great office structure would become brilliant, the light glaring through the windows as though every electric bulb and every gas jet in the building had been lighted at once. Then the dense, billowing veils of black smoke would hide it for a minute. Shortly a crashing sound would rise clear and distinct above the clamor and din and roar that were everywhere; and great leaping 'flags of flame' would burst through the veil of the smoke, and float exultantly, it seemed, from the very top of the vast kettle of fire. In a few minutes more the building would be dark, and you would know that only the crumbling skeleton of it remained. You had seen a 'fireproof' building burned out in half an hour! Then a new flame in a new quarter would arrest your attention, or the terrific heat would drive you from your post. The conflagration finally, died to controllable size when it reached Jones Falls, a 50-foot Wide canal, in eastern Baltimore. Here about forty Pieces of apparatus finally made an effective stop. One of the amazing features of this conflagration was that no one was killed, although forty firemen were injured. Much hose and minor pieces of fire equipment were damaged but only one piece of apparatus was lost, Engine 15's pumper."

The Baltimore conflagration focused national attention on the need for standardized firehose couplings and screw threads and provided a renewed emphasis on standardization in general. The National Bureau of Standards (now known as the National Institute of Standards and Technologies or NIST) had been established a couple of years prior to the fire to standardize units of measurement for commerce and industry. At the time of the fire, the National Bureau of Standards (NBS) had been working on standardizing the measurement for a U.S. gallon for uniformity of weights and measures, and they were working on units of measurement for electricity and calibrating electrical metering devices for the new and emerging electrical power generation industry. Members of the NBS collected more than 600 sizes and variations of fire-hose couplings in an investigation and, after the Baltimore fire, the NBS participated in the selection and development of a national standard for firehose threads. Since then many standards-writing organizations have been established, including the following organizations that are developing standards for plumbing products:

The American Society of Sanitary Engineering (ASSE)
The American Society of Mechanical Engineers (ASME)
The American Society of Testing & Materials (ASTM)
The National Sanitation Foundation (NSF)
The Canadian Standards Association (CSA)
The International Association of Plumbing & Mechanical Officials (IAPMO)

The American Society of Plumbing Engineers recently started developing plumbing system design standards. These standards are limited to system designs and do not address product standards.

I have been vey active with the American Society of Sanitary Engineering, serving on dozens of plumbing product standard working groups, as a member of the ASSE Seal control board and as a member of the main plumbing product standard committee. For about the last ten years, I have attended many plumbing product standards meetings for the above organizations, mostly paying my own way. I have found that there is basically very little input at these meetings from design professionals and people who are not manufacturers or manufacturer's representatives. Typically, design engineers, design professionals and members of the public do not get paid or reimbursed for expenses to attend the standard development meetings, so it is understandable to see mostly manufacturers in attendance

I have often been the lone non-manufacturing person on a working group. There are code consultants, lab representatives, manufacturers and, occasionally, a retired engineer that do a great job of keeping the consensus standard development process working. However, none of these standards are worth the paper they are printed on if they are not submitted to and accepted by the local or model code that is enforced by a given jurisdiction.

Within the townships, villages, cities, counties, states or governmental jurisdictions throughout the United States and Canada there exist two model plumbing codes and a wide range of local or regional plumbing codes. Some codes have been developed locally over the years, with local code change processes, by cities such as Chicago and Boston and by states, such as Illinois or Wisconsin. Other states and jurisdictions have elected to follow the easier and less expensive process of adopting model codes instead of spending the money to develop and maintain their own codes.

Inspectors in each jurisdiction are required to enforce the plumbing code; they must follow the text in the code. After a jurisdiction adopts a plumbing code as part of their local ordinances it becomes an extension of the laws of the jurisdiction. , If the code covers the subject in detail and with mandatory language, the inspector's job is easy. If a code uses vague and non-mandatory language or permits inspector interpretations, it can create confusion, for engineers, contractors and manufacturers and enforcement between jurisdictions will be inconsistent and unequal.

The people on the standards working groups or task groups strive to develop language that will provide a minimum level of health, safety and performance requirements for a given product. The procedures for developing standards require the chairman to address every negative comment on a given ballot. I find it awkward and frustrating when the chairman of such a group is employed by the manufacturer requesting that the standard be written. It seems that, in these cases, the comments on negative ballots are always deemed "non-persuasive," because they could affect that manufacturer's ability to pass the test or because the cost of manufacturing a better product would be greater.

In a recent standard committee, the chairman, who was a paid representative of the manufacturer that was requesting the standard, drafted an outline standard with tests that were so easy that, if the device was not even installed on the test stand during the test, it could pass the test. I sent in a negative ballot, pointing out this deficiency and suggesting a series of tests that were realistic and in line with the intended application for the product. The response to my comment was simply "non-persuasive;" there was no other explanation. I'm pretty sure that, if the consultant were not working for the manufacturer, he would have agreed with me. But, on this day, my negative comments didn't persuade the chairman, because the tests I proposed would have probably made it harder for his client's product to pass the test. I felt like the guy in the fable who said "I don't see the emperor's new clothes." I have experienced this same attitude in another plumbing product working group where the chairman was working on behalf of a manufacturer and trying to push a product through the process as fast as possible so they could start making widgets.

Having being involved in plumbing product standards development for about ten years now, I see a need to have a staff person for the standards organization, or someone other than the manufacturer requesting the standard, to serve as chairman of the standard working group or task force. At a recent standards committee meeting in Cincinnati, Ohio, this issue came up, and a representative from a testing laboratory volunteered to take on the chairman's position. I feel that this was a good thing for the industry. I hope to see more non-manufacturers serving as chairman.

I have seen a lot of new technology being developed for products that do not meet the basic intent and health and safety principles in the model plumbing codes. The manufacturers of these new products are pushing forward with the development of standards, with their consultants leading the charge through the standard development process. They will most likely get their standards developed and bring them to the model codes for acceptance. The real test is whether the standard for the new product is something that the model codes will accept.

When a new standard for a new product is proposed for acceptance in the codes there are only two minutes of testimony and one minute of rebuttal testimony allowed at the plumbing code hearings; this can be a problem. That is not very much time to explain how a new widget works, and it is not enough time to allow an opponent to discuss the potential and inherent problems with a new product. Because some code committee members are only concerned with whether the standard was developed in a consensus process they may approve a standard even though they have not read and understood it. Committee members not only need to understand a standard; they also need to step back and look at the health and safety aspects.

Many problems face a manufacturer who wishes to introduce a new or improved product without a product standard. Most code officials do not have the facilities for testing products, nor do they always have the funds to have them tested by independent laboratories. Some jurisdictions will accept the product if it has been tested by two or three recognized laboratories. Some will accept the test of individual laboratories to which manufacturers send their products. If there is no standard, some will not accept the product without years of tested proof.

The nature of some new products is such that only time testing under many environmental conditions can prove adequate capabilities. Consequently, the introduction of a new or improved product can become a very time consuming and expensive proposition, because the manufacturer must send personal representatives to each locality to convey information of the product's characteristics and capabilities for performing its intended function. Introducing a new product in this country is very expensive these days. If a standard does not exist, if testing is not performed or if a sales engineer is not out promoting a product, the manufacturer may be limited in production or may have to develop many special models acceptable to various local jurisdictions; this results in increased cost to the manufacturer and, ultimately, to the consumer. The development of consensus standards assists the approval process for inspection authorities that are responsible for reliability and safety in plumbing systems. This is why we have plumbing product standards.

Ron George specializes in plumbing, piping, fire protection and hvac design. He also provides  plumbing/mechanical code and product standard consulting services and forensic investigations of mechanical system failures.