By R. Bruce Martin, Special to CONTRACTOR
National plumbing standards are important because they help protect public health and safety. While there is no doubt that plumbing regulations have contributed to America’s high standard of living, their problem is that they are also incredibly expensive to prepare and sometimes actually stifle innovation and technological progress.
To my knowledge, nobody has ever addressed the issue of how much each plumbing standard update costs the public. Totaling all the expenses of the various participants over the five-year standard review period — salaries, travel expenses, meeting preparation time, manufacturer lab testing as well as administrative costs, printing, etc. — suggests to me that the public’s cost is near $1 million per update. To me, that is vastly excessive.
Local code authorities in most U.S. cities and states subscribe to one of several model codes, which evaluate applicable national standards and incorporate all or part of them. Historically, the national model codes of BOCA, IAPMO, NSPC and SBCCA have dominated. More recently, the International Plumbing Code has emerged as a fifth competitor.
Except for retail, over-the-counter sales, it is very difficult to sell a product nationally without first obtaining multiple local code approvals across the country. Before local code authorities will approve a product, they almost always require that it be approved by “their” model code. Gaining code approval across this country is particularly complicated and expensive for innovations because model codes normally require independent test data that show the product meets the requirements of the applicable national standard.
Before the 1970s, the federal purchasing specification “Vitreous China Plumbing Fixtures” (WWP541b) was, effectively, the national standard for toilets. It defined every aspect of a toilet’s design — dimensions, angles and styles as well as the vitreous china material itself.
Back then, water was cheap and its availability considered inexhaustible. As a result, little consideration was given to water consumption-per-flush — then ranging between 512 to12 gal. per flush. Toilet designers simply allocated enough storage water to effectively empty the bowl’s waste.
Since the industry had significant excess capacity, pressure to keep plants full continually depressed the unit price, which became the lord of the sale. This condition still exists. As a result, the basic white gravity-fed two-piece toilet costs the wholesaler today about 50% less than it did back in 1970, on an inflation-adjusted basis.
Manufacturer’s dilemma
Low manufacturer gross margins coupled with tight federal government design specifications discouraged product innovation. In fact, until the ANSI standard replaced the government’s WWP541b as the national design specification, no established format even existed for evaluating “non-conforming” innovations.
Considering the above, it’s no surprise that few truly disruptive innovations have been successfully introduced to the U.S. plumbing market since the end of World War II. Some exceptions are:
- Porcelain steel plumbing fixtures, brought to market by Briggs, formerly an automotive supplier;
- Single-lever faucets, popularized by Delta Faucet, another former automotive supplier;
- Water supply valve stops, by Brass Craft Manufacturing, a startup;
- Fiberglass plastic fixtures, by Owens-Corning, an insulation manufacturer; and,
- Flushometer tanks, by Water Control International, which I founded.
It is interesting to note that none of these innovations came from companies previously established in the plumbing industry. Is it because of plumbing standard obstacles?
Innovator’s dilemma
For the cash-starved entrepreneur, the time and expense of gaining even a conditional nonconforming model code listing can be prohibitive. For example, the first listing for the flushometer tank took almost two years to obtain.
Because no standard existed to measure this new technology against, one of the first obstacles that we faced was finding a test protocol acceptable to a listing agency that demonstrated water closet efficacy of retrofitted combinations. Luckily, IAPMO accepted an American Standard laboratory water closet test protocol that was discovered in a Stevens Institute of Technology research journal.
A testing laboratory in Ann Arbor, Mich., then conducted the evaluation. The test series consisted of running American Standard extraction tests and cross-connection tests on six of the most popular North American water closet bowls to establish the performance comparison — first with the factory gravity-flow tank installed and then with the replacement flushometer tank.
Unfortunately, despite the certified comparable test results, IAPMO initially rejected the test results because the lab was not on its approved list. In going through the process of obtaining IAPMO certification, the lab’s expenses cost WCI several thousand more dollars and a big-time delay.
To top it all off, after IAPMO finally approved the lab, it then demanded more tests. Finally, after completing the additional requirements and paying the expensive listing fee, the flushometer tank was approved for listing. In today’s dollars, the cost of this exercise was close to $500,000.
By comparison, when the second-generation flushometer-tank, the PF/2 Energizer, was introduced in 1997, it flew through the model and municipal code approval process, partly because the system had been streamlined since the ‘70s and very much because this pressure-flush system was merely a sustaining innovation, or product improvement, rather than a revolutionary concept.
Luck counts
In the early 1970s, the federal government accurately projected that water availability and waste treatment capacity would become serious problems within a few years. As a result, its National Institute of Science and Technology sponsored a study on toilet extraction and water consumption. This research recommended maximum water closet consumption levels (e.g., 312 gpf) and a series of lab extraction tests that NIST felt would allow manufacturers to forecast satisfactory water closet performance in the market.
Because the federal government withdrew from the standard-writing business at that time, the ANSI publications became the American National Standards. The NIST protocol was adopted into the ANSI water closet standard in the late ‘70s. For the first time, rationed water closet performance became important.
Water shortages in the West and waste treatment capacity shortages in the Northeast combined into a perfect ecological storm. Political pressure literally blew away the bureaucratic resistance to new technology.
While that was good luck for product innovators, this also accelerated premature acceptance of the 6-liter gravity toilet, fashioned after European designs. Field performance problems of these early 6-liter gravity WCs led to building official complaints that the ANSI standard was inadequate; widespread failure of low-flow toilets in the marketplace was occurring with models that had been certified as meeting ANSI’s minimum requirements.
As a result, an ANSI working group was reactivated and an update was published in the early ’80s. This included:
- Addition of the 1.6 gpf category;
- Simplified minimum extraction criteria; and
- Adoption of a minimum waste-transport requirement because of concern that the lower discharge volume and flow velocity of 6-liter gravity toilets could cause drainline clogs.
ANSI rules require that all standards be updated every five years by a working group made up of industry, public and private interest people. Because the current ANSI working group’s latest update has been successfully passed through public review, it should be published shortly.
Harmonization
Like ANSI in the United States, the Canadian Standard Association issues toilet standards for Canada. CSA has also recently completed its WC update. Because its standard is similar but not identical to ANSI’s, representatives from both organizations have formed a Joint Harmonization Task Group with the goal of merging the two standards. If this is accomplished, then, for the first time, all WCs will have to meet the same performance requirements in both countries.
Even with harmonization, however, the true cost of updating national WC standards will still be too costly and inefficient. While harmonization will simplify the product innovator’s approval process, it will increase the standard development cost because it adds another layer of bureaucracy to the system — a harmonization review group on top of ANSI and CSA. The ironic part is that several of the same people are members of all three “groups.”
While I support the concept of harmonization, to me a more economical and efficient way to protect the health and safety of the North American public would be to have the CSA and ANSI plumbing task groups merge into one committee that would meet jointly to resolve five-year standard updates. An ANSI/CSA working group merger would save both money and time by eliminating the back-and-forth review procedure.
The standard-writing process would become much more responsive to the ever-changing technology world.
Bruce Martin is the inventor of the pressurized flushing device technology (a.k.a. flushometer tank). His first development was the Flushmate flushometer tank, which was acquired in 1986 by Sloan Valve Co. His second, the PF/2, was purchased by Chicago Faucet, a Geberit company, in 2002.