by Jim Kendzel, ASA Director of Codes and Standards
We are in the midst of a new code development cycle and ASA is actively engaged in submitting and commenting on proposed changes to the codes impacting our members and the entire PHCP and PVF supply chains. This article is intended to help our members gain a better understanding of how the process works and gain an appreciation for how ASA is engaged in that process in service to its members.
State and local authorities turn to the use of model codes in setting regulations that have a direct impact on ASA members from the products they produce and distribute in the marketplace, as well as the buildings they use to store those products. There are two key bodies in the U.S. that develop model codes, the International Code Council (ICC) and the International Association of Plumbing and Mechanical Officials (IAPMO). These organizations develop model codes covering: buildings, plumbing, mechanical, fire safety and “green” codes. In addition, other standards bodies such as the National Fire Protection Association (NFPA) and ASHRAE develop standards and model codes that are often referenced or directly embedded in the model codes developed by ICC and IAPMO.
Model codes developed by both ICC and IAPMO are published for use by state and local authorities to adopt in their jurisdictions. Typically, a state or local jurisdiction will review the two sources of model codes and make a determination which model codes best fit their needs and then adopt those model codes in to regulation.
The main benefit of using these model codes is to provide a level of consistency in regulations across the U.S., as opposed to each state and local jurisdiction developing code regulations from scratch. Of course, each jurisdiction has the ability to modify the model codes based on their local needs, so it is also critical for ASA to monitor state and local adoption of model codes to be sure that any potential modifications do not have a negative impact on our members.
The model codes are developed using a consensus process bringing together a diverse group of stakeholders including producers, wholesaler/distributors, contractors, architects and regulatory agencies. Representatives from each of these stakeholder groups are selected to serve on balanced technical committees having the responsibility of voting on proposed changes to the model codes. In addition, the development process allows for public input along the way where those having an interest can supply proposed changes along with comments on proposals being submitted to the technical committees.
Model codes are revised every three years to ensure the code requirements are kept up to date to new technology and public health/safety priorities. Both model code-developing organizations use a similar code development process with the following key steps:
1st Public Comment Period – interested parties submit proposed changes to the model codes.
Technical Committee Review and Public Hearing – the technical committee reviews the proposed changes and receives comments in favor of or in opposition to the proposed changes from the public and votes on if the proposal should be accepted or rejected. Virtual hearings and committee meetings will take place through April and early May 2021.
2nd Public Comment Period – The technical committee decisions are published and comments from the public are solicited in favor of or in opposition to the decision made by the technical committee. Opportunity is also given to modify proposals rejected by the technical committee to resolve the reason for rejection. Comments will be due by July 2, 2021.
Final Technical Committee Review and Public Hearing – Technical Committee reviews public comments received, both written and in-person, and votes to determine its final position on the proposals. The committees will meet in September 2021 to review the public comments.
Appeal – submitters of proposals have the right to formally appeal a decision made by the technical committee.
Final publication of the revised model code.
A2L refrigerants
The current model code cycle actually began in 2020 with proposals for changing the codes needing to be submitted in January 2021. ASA, through its partnership with HARDI, worked diligently in 2020 with AHRI and industry representatives in developing proposed changes to both the mechanical codes and fire codes covering A2L refrigerants. These refrigerants are considered a low greenhouse gas emitter, but also have a slight level of flammability not present in the higher greenhouse gas emitting refrigerants currently used. The proposals submitted address changes to the mechanical, building and fire codes related to refrigeration equipment and the use of A2L refrigerants, and also to the fire code related to the storage of the refrigerants, which have the most impact on our members.
The storage requirement proposal supported by HARDI, ASA and AHRI was accepted by the ICC Fire Code Action Committee, which is a committee brought together by ICC to develop and review proposals prior to formal submittal to determine if the proposal should be considered favorably by the Technical Committee. This is a good start to the potential adoption of the proposal into the code.
In early 2021, ASA created three working groups of member representatives to evaluate the proposed changes to the model codes and determine if ASA should take a position on any of the proposals during the code committee hearings.
The three working groups formed are: Plumbing Fixture and Appliance; Piping Systems; and Mechanical Systems. These three groups have been working diligently to develop ASA positions on the ICC model codes, and are in the process of evaluating the proposed changes to the IAPMO model codes.
To keep up on the progress of the 2021-2022 code development process you can go to the ASA Codes and Standards website at www.asa.net/Codes-Standards/cs-news.
When you go to the site, you will have access to all of the proposed changes, ASA positions (when they are published) and results of technical committee hearings. Also, please feel free to reach out to me at [email protected] if you have any questions on the process or positions being taken.