Dustin Howard Pages 1-7

September 5, 2023

Language and changes the people of Michigan would like to see added or changed in the 2021

Michigan Mechanical Code.

1. Apprenꢀceship, Journeyman, Master:

a. There must be an addiꢀon to the Code that mandates registered apprenꢀces for

a minimum of 3 years or 6,000 hours of documented work, and a Journeyman for

a minimum of 2 years or 4,000 hours of documented work, before an individual is

allowed to write for their Mechanical Contractors License.

b. This would mirror the requirements of the Plumbing Code MCL 339.6117 of the

Skilled Trades Regulaꢀon Act.

c. Registraꢀon Fee of $15.00 for an apprenꢀce or waived with a completed

Military/Uniformed Services Examinaꢀon Waiver Form.

d. “Mechanical Apprenꢀce” means an individual who is registered under the Skilled

Trades Regulaꢀon Act as an apprenꢀce.

e. “Mechanical Journey” means an individual, other than a mechanical contractor,

who is qualiﬁed to engage in the pracꢀcal installaꢀon or maintenance of a

mechanical system and is licensed as a mechanical journeyer.

-A PERSON SHALL NOT ENGAGE IN OR WORK IN THE BUSINESS OF A

MECHANICAL CONTRACTOR, JOURNEY TECHNICIAN, OR APPRENTICE

TECHNICIAN UNLESS LICENSED OR REGISTERED BY THE DEPARTMENT.

EXCEPT AS PROVIDED NI SUBSECTIONS (2), (3), AND (4). INSTALLATION

OR SERVICING OF MECHANICAL EQUIPMENT SHALL BE PERFORMED BY A

LICENSED MECHANICAL CONTRACTOR, JOURNEY TECHNICIAN OR

REGISTERED APPRENTICE. A LICENSED MECHANICAL CONTRACTOR

SHALL BE IN CHARGE AND RESPONSIBLE FOR PROPER INSTALLATION

AND CONFORMANCE WITH THE CODE. INSTALLATION OF MECHANICAL

EQUIPMENT SHALL NOT BE PERFORMED UNLESS THE MECHANICAL

THE CONTRACTOR WHO IS RESPONSIBLE HAS SECURED A PERMIT FROM THE STATE OR A

GOVERNMENTAL SUBDIVISION AUTHORIZED TO ISSUE

PERMITS.

(2) A LICENSE IS NOT REQUIRED FOR MINOR REPAIR WORK:

(3) A HOMEOWNER WHO OCCUPIES OR WILL OCCUPY AHOME MAY

INSTALL HIS OR HER OWN MECHANICAL EQUIPMENT IN HIS OR HER

SINGLE-FAMILY DWELLING IF A PERMIT IS SECURED.

(4) THIS ACT DOES NOT PREVENT A PERSON FROM PERFORMING

ACTIVITIES WITHIN THE SCOPE OF LICENSURE OR REGISTRATION UNDER

ANY OTHER LICENSURE OR REGISTRATION ACTO R APPLICABLE CODES

FOR THAT LICENSED OR REGISTERED PROFESSIONAL ADOPTED

UNDER LAW.

-MECHANICAL CONTRACTOR-

UPON THE FILING OF AN APPLICATION ON A FORM PRESCRIBED BY THE DEPARTMENT AND

PAYMENT OF THE EXAMINATION FEE PRESCRIBED IN SECTION 10, THE DEPARTMENT SHALL

CONDUCT EXAMINATIONS TO ESTABLISH THE QUALIFICATIONS AND COMPETENCY OF

APPLICANTS

SEEKING LICENSURE AS A MECHANICAL CONTRACTOR FOR THE CATEGORY FOR WHICH

THE APPLICATION IS SUBMITTED AND SHALL ISSUED LICENSES TO THOSE WHO PASS THE

EXAMINATIONS AND PAY THE INITIAL ISSUANCE FEE, EXCEPT AS OTHERWISE PROVIDED FOR IN

THIS ACT. AN APPLICANT WHO SEEKS LICENSURE IN MORE THAN 1 WORK CLASSIFICATION

LISTED

IN SUBSECTION (3) ON A SINGLE APPLICATION SHALL ONLY BE REQUIRED TO PAY 1

EXAMINATION FEE AND 1 INITIAL INSURANCE FEE AS PROVIDED IN SECTION 10. A PERSON

APPLYING FOR A MECHANICAL CONTRACTOR LICENSE UNDER THIS ACT SHALL ALSO PAY

THE AMOUNT REQUIRED TO BE PAID UNDER THE CONSTRUCTION LIEN ACT, 1980 PA 497, MCL

570.1101 TO570.1305, WHICH AMOUNT SHALL BE PAID TO THE DEPARTMENT FOR DEPOSIT IN

THE HOMEOWNER CONSTRUCTION LIEN RECOVERY FUND. A PERSON IS NOT REQUIRED TO PAY

MORE THAN $50.00-IN ASSESSMENT PERIOD UNDER THAT ACT, REGARDLESS OF THE

NUMBER OF LICENSES-APPLIED-FOR-OF-HELD. (A) IN ADDITION TO THE LICENSE

FEE, A PERSON WHO APPLIES FOR A MECHANICAL CONTRACTOR'S

LICENSE SHALL PAY A FEE OF $100.00 AND, SUBJECT TO SUBSECTION (6)

OFSEC. 201 OF PA 497 OF 1980, A PERSON WHO APPLIES TO RENEW SHALL PAY A FEE OF

OF$10.00 FOR EACH YEAR THAT THE RENEWED

THE LICENSE WILL BE VALID.

(2) AN APPLICANT IS NOT CONSIDERED ELIGIBLE FOR MECHANICAL CONTRACTOR

EXAMINATION UNLESS THE APPLICANT IS OF GOOD MORAL CHARACTER, AS DEFINED IN 1914

PA 381, MCL 338.41 TO 338.47, AND HAS A MINIMUM OF 5 (FIVE) YEARS OF

EXPERIENCE UNDER THE EMPLOYMENT AND SUPERVISION OF A LICENSED MECHANICAL

CONTRACTOR OR AN EQUIVALENT OF THAT EXPERIENCE ACCEPTABLE TO THE BOARD, UPON

PROPER SHOWING TO THE DEPARTMENT, IN 1OR MORE OF THE WORK CLASSIFICATIONS LISTED

IN

SUBSECTION (3). FOR UP TO SIX MONTHS FOLLOWING THE EFFECTIVE DATE

OF THE AMENDATORY CHANGES TO THIS ACT, AN APPLICANT IS

CONSIDERED ELIGIBLE FOR MECHANICAL CONTRACTOR EXAMINATION

WHO POSSESSES 3 YEARS EXPERIENCE IN THE EMPLOYMENT AND

SUPERVISION OF A LICENSED MECHANICAL CONTRACTOR EQUIVALENT OF THAT

EXPERIENCE ACCEPTABLE TO THE BOARD, UPON PROPER SHOWING TO

THE DEPARTMENT, NI 1 OR MORE, OR THE WORK CLASSIFICATIONS

LISTED IN SUBSECTION 3I FO F GOOD MORAL CHARACTER A S DEFINED I N

1974 PA 381.

(3) A MECHANICAL contractor's license obtained shall be classiﬁed and limited.

a s 1 or more of the following:

(a) Hydronic heaꢀng and cooling and process piping.

(D) HVAC equipment.

(c) Ductwork.

(d) Refrigeraꢀon.

(e) Limited service, heaꢀng or refrigeraꢀon.

(r) Unlimited service, heaꢀng or refrigeraꢀon.

(9) Fire suppression.

(h) specialty.

(4) THE MECHANICAL CONTRACTOR'S EXAMINATION SHALL CONSIST OF,

BUT NOT BE LIMITED TO, QUESTIONS DESIGNED TO TEST AN

INDIVIDUAL'S KNOWLEDGE OF THIS ACT, ANY RULES PROMULGATED

UNDER THIS ACT, THE STILLE-DEROSSETT-HALE SINGLE STATE

CONSTRUCTION CODE ACT, AND THE ADMINISTRATION AND

ENFORCEMENT PROCEDURES OF THE CODE, ORAL AND WRITTEN TESTS

AND SHALL COVER THE SCIENCE AND PRACTICE OF INSTALLATION OF MECHANICAL

EQUIPMENT, KNOWLEDGE OF THE STATE MECHANICAL

CODE, LAWS, RULES, REGULATIONS, INTERPRETATION OF CHARTS AND

BLUEPRINTS, AND PLANS OF MECHANICAL EQUIPMENT INSTALLATIONS.

THE DEPARTMENT SHALL ARRANGE FOR MECHANICAL CONTRACTOR

EXAMINATIONS TO BE H E L D FOUR TIMES EACH YEAR IN THE LOWER

PENINSULA ANDSHALL ARRANGE FORA T LEAST1 MECHANICAL

CONTRACTOR EXAMINATION TO BE HELD IN THE UPPER PENINSULA

EACH YEAR.

(5) UPON FAILURE TO PASS THE MECHANICAL CONTRACTOR'S

EXAMINATION 2 TIMES WITHIN A PERIOD OF 2 YEARS, AN APPLICANT

SHALL BE INELIGIBLE TO SIT FOR ANOTHER EXAMINATION UNTIL A

PERIOD OF NOT LESS THAN 1 YEAR FROM THE DATE OF FAILURE OF THE

SECOND EXAMINATION, AT WHICH TIME HE OR SHE SHALL PRESENT TO

THE BOARD PROOF OF THE SUCCESSFUL COMPLETION OF A COURSE ON

MECHANICAL CODE, MECHANICAL EQUIPMENT FUNDAMENTALS, OR

MECHANICAL EQUIPMENT THEORY, APPROVED BY THE BOARD, IN ORDER

TO BECOME ELIGIBLE TO AGAIN SIT FOR AN EXAMINATION.

-JOURNEYER-

UPON THE FILING OF AN N APPLICATION ON A FORM PRESCRIBED BY

THE DEPARTMENT AND PAYMENT OF THE EXAMINATION FEE

PRESCRIBED NI SECTION 10, THE DEPARTMENT SHALL CONDUCT

EXAMINATIONS TO ESTABLISH THE QUALIFICATIONS AND COMPETENCY

OF APPLICANTS SEEKING LICENSURE AS JOURNEY TECHNICIAN FOR THE

CATEGORY FOR WHICH THE APPLICATION IS SUBMITTED AND SHALL

ISSUE LICENSES TO THOSE WHO PASS THE EXAMINATIONS AND PAY THE

INITIAL ISSUANCE FEE, EXCEPT AS OTHERWISE PROVIDED FOR NI THIS

ACT. AN APPLICANT FOR JOURNEY TECHNICIAN WHO SEEKS LICENSURE

IN MORE THAN 1 WORK CLASSIFICATION LISTED IN SUBSECTION (X) ON A

SINGLE APPLICATION SHALL ONLY BE REQUIRED TO PAY 1 EXAMINATION

FEE AND INITIAL ISSUANCE FEE AS PROVIDED IN NI SECTION 10. (2) AN APPLICANT FOR

JOURNEY TECHNICIAN IS NOT CONSIDERED

ELIGIBLE FOR EXAMINATION UNLESS THE APPLICANT IS OF GOOD MORAL

CHARACTER, AS DEFINED NI 1974 PA 381, MCL 338.41 TO 338.47, AND HAS

A MINIMUM OF 3 YEARS OF EXPERIENCE UNDER THE EMPLOYMENT AND

SUPERVISION OF A LICENSED MECHANICAL CONTRACTOR OR AN EQUIVALENT OF THAT

EXPERIENCE ACCEPTABLE TO THE BOARD, UPON PROPER SHOWING TO

THE DEPARTMENT, NI 1 OR MORE OF THE WORK CLASSIFICATIONS

LISTED NI SUBSECTION (X).

(3) A JOURNEY TECHNICIAN LICENSE OBTAINED SHALL BE CLASSIFIED

AND LIMITED TO 1 OR MORE OF THE FOLLOWING:

(a) Hydronic heaꢀng and cooling and process piping.

(D) HVAC equipment.

(c) Ductwork.

(a) Refrigeraꢀon

(e) Limited service, heaꢀng or refrigeraꢀon.

(Unlimited service, heaꢀng or refrigeraꢀon.

(9) Fire suppression.

(h) Specialty.

(4) THE JOURNEY TECHNICIAN'S EXAMINATION SHALL CONSIST OF, BUT

NOT BE LIMITED TO, ORAL, WRITTEN, AND PRACTICAL TESTS AND SHALL

COVER THE THEORY AND PRACTICE OF MECHANICAL EQUIPMENT

INSTALLATION AND KNOWLEDGE OF THE STATE MECHANICAL CODE,

RULES, AND REGULATIONS. THE DEPARTMENT SHALL ARRANGE FOR

JOURNEY TECHNICIAN EXAMINATIONS TO BE HELD FOUR TIMES EACH

YEAR IN THE LOWER PENINSULA AND SHALL ARRANGE FOR AT LEAST 1

JOURNEY TECHNICIAN'S EXAMINATION TO BE HELD IN THE UPPER

PENINSULA EACH YEAR.

(5) UPON FAILURE TO PASS THE JOURNEY TECHNICIAN EXAMINATION 2

TIMES WITHIN A PERIOD OF2 YEARS, AN APPLICANT SHALL BE

INELIGIBLE TO SIT FOR ANOTHER EXAMINATION UNTIL A PERIOD IF NOT

LESS THAN 1 YEAR FROM THE DATE OF FAILURE OF THE SECOND

EXAMINATION, AT WHICH TIME HE OR SHE SHALL PRESENT TO THE

BOARD PROOF OF THE SUCCESSFUL COMPLETION OF A COURSE ON

CODE, MECHANICAL EQUIPMENT FUNDAMENTALS, OR MECHANICAL EQUIPMENT

THEORY, APPROVED BY THE BOARD, NI ORDER TO BECOME

ELIGIBLE AGAIN TO SIT FOR AN EXAMINATION.

(6) THE BOARD SHALL REVIEW AND DETERMINE THE EQUIVALENCY OF

NATIONALLY RECOGNIZED CERTIFICATION PROGRAMS, WHICH IS

PROVIDED BY THE APPLICANT TO CREDIT NECESSARY HOURS REQUIRED.

(7)A PERSON WHO, AFTER THE EFFECTIVE DATE OF THIS ACT BECOMES

REGISTERED AS AN APPRENTICE TECHNICIAN SHALL UPON PAYMENT OF

THE JOURNEY TECHNICIAN LICENSE FEE AND UPON FURNISHING THE

DEPARTMENT, UPON A FORM PROVIDED BY THE DEPARTMENT, WITH

SATISFACTORY EVIDENCE OF HAVING BEEN EMPLOYED BY A LICENSED

MECHANICAL CONTRACTOR FOR A MINIMUM OF 5 YEARS in one or more of

THE CLASSIFICATIONS HELD BY THE LICENSED MECHANICAL CONTRACTOR WITH 2 YEARS

AT THE JOURNEY LEVEL OR HIGHER IMMEDIATELY PRECEDING THE

EFFECTIVE DATE OF THIS ACT, BE GRANTED A JOURNEY TECHNICIAN

LICENSE WITHOUT EXAMINATION IF THE PERSON APPLIES WITHIN 6

MONTHS AFTER THE EFFECTIVE DATE OF THIS ACT.

-APPRENTICE-

(1) AN INDIVIDUAL EMPLOYED AS AN APPRENTICE TECHNICIAN SHALL

REGISTER WITH THE DEPARTMENT ON A FORM PROVIDED BY THE

DEPARTMENT WITHIN 30 DAYS AFTER EMPLOYMENT.

(2) AN APPRENTICE REGISTRATION IS INVALID AFTER 5YEARS FROM THE

DATE OF INITIAL REGISTRATION UNLESS THE REGISTERED APPRENTICE

APPLIES FOR AND TAKES THE EXAMINATION FOR JOURNEY LICENSE. THE

REGISTRATION REMAINS VALID UNTIL EITHER A LICENSE IS ISSUED OR

THE APPRENTICE FAILS TO TAKE THE EXAM.

(3) UPON REQUEST BY THE APPRENTICE TO THE BOARD, THE BOARD

MAY GRANT AN EXTENSION OF AN APPRENTICE REGISTRATION FOR A

PERIOD OF TIME AS DETERMINED APPROPRIATE BY THE BOARD.

(4) AN APPRENTICE TECHNICIAN SHALL, AS HIS OR HER PRINCIPAL

OCCUPATION, BE ENGAGED IN NI LEARNING AND ASSISTING IN THE

INSTALLATION OR SERVICE OF MECHANICAL EQUIPMENT UNDER THE

EMPLOYMENT AND SUPERVISION OF A MECHANICAL CONTRACTOR.

(5) SERVICE WORK AND INSTALLATION PERFORMED AT ANY TIME BY A REGISTERED

APPRENTICE REQUIRES DIRECT SUPERVISION BY A LICENSED MECHANICAL JOURNEY

TECHNICIAN.

2. RATIO FOR JOURNEYER TO APPRENTICE:

a. To ensure proper training, educaꢀon, and safety for the apprenꢀce.

b. This method is currently enforced under the Michigan Electrical Code 339.5717

AND 339.5723 under the Skilled Trades Regulaꢀon Act. The addiꢀon of this raꢀo

has proven its value for the future of Michigan’s skilled labor workforce.

-THE RATIO OF MECHANICAL JOURNEYER OR MASTER MECHANICAL LICENSE

HOLDER TO REGISTERED MECHANICAL APPRENTICE SHALL BE ON THE BASIS OF 1

MECHANICAL JOURNEYER OR MASTER TO NO MORE THAN 3 REGISTERED MECHANICAL

APPRENTICES. THE DEPARTMENT OR ENFORCING AGENCY SHALL ENFORCE THE RATIO

ON A JOBSITE BASIS.

3. CONTINUOUS EDUCATION FOR JOURNEYER MECHANICAL LICENSE:

a. Under secꢀon 339.5411 of the Skilled Trades Regulaꢀon Act (d): THE PERSON

SUBMITS PROOF OF HAVING COMPLETED THE EQUIVALENT OF 1 YEAR OF

CONTINUING EDUCATION WITHIN THE 12 MONTHS IMMEDIATELY PRECEDING

THE DATE OF THE APPLICATION OF AS OTHERWISE PROVIDED IN A SPECIFIC

ARTICLE OF THIS ACT OR BY RULE IF CONTINUING EDUCATION IS REQUIRED FOR

THAT LICENSE UNDER A SPECIFIC ARTICLE.

b. All Plumbers must take a minimum of 5 hours of a code update within 1 year of

the new code adopꢀon. 339.6113 OF ACT 407.

c. All electricians must take a minimum of 15 hours of a code update within 1 year

of the new code adopꢀon. 339.5713 OF ACT 407.

d. THE MECHANICAL CODE MUST HAVE THE SAME REQUIREMENTS. EACH OF THE

(10) SUBSECTIONS OF THE MECHANICAL CODE SHALL HAVE A MINIMUM

REQUIREMENT OF 5 HOURS PER SUBSECTION OF REQUIRED CONTINUOUS

EDUCATION IN ORDER TO RENEW A PERSON’S JOURNEYER OR MASTER OR

CONTRACTOR LICENSE WITHIN 1 YEAR OF THE NEW CODE ADOPTION.

4. MECHANICAL INSPECTOR; REQUIREMENTS; PROHIBITED CONDUCT: 339.6123

a. AN INDIVIDUAL LICENSED UNDER THIS ACT EMPLOYED OR

ACTING AS A MECHANICAL INSPECTOR SHALL NOT ENGAGE IN, OR BE

DIRECTLY OR INDIRECTLY CONNECTED WITH, THE MECHANICAL

EQUIPMENT INSTALLATION BUSINESS INCLUDING, BUT NOT LIMITED TO,

THE FURNISHING OF LABOR, MATERIALS, OR APPLIANCES FOR THE

CONSTRUCTION, ALTERATION, OR MAINTENANCE OF A BUILDING OR THE

PREPARATION OF PLANS OR SPECIFICATIONS FOR THE CONSTRUCTION,

ALTERATION, OR MAINTENANCE OF A BUILDING AND SHALL NOT ENGAGE

IN ANY WORK THAT CONFLICTS WITH HIS OR HER OFFICIAL DUTIES IN THE

INSPECTOR'S RESPECTIVE JURISDICTION(S).

5. OUT-OF-STATE LICENSING REQUIREMENTS:

a. CURRENTLY ACT 407 AND THE CURRENT MECHANICAL CODE STATES: THE

DEPARTMENT MAY LICENSE, WITHOUT EXAMINATION AND UPON THE PAYMENT

OF THE

INITIAL LICENSE FEE PRESCRIBED IN SECTION 10, AN APPLICANT WHO IS LEGALLY

AUTHORIZED

MECHANICAL CONTRACTOR IN ANOTHER STATE OR COUNTRY IF THE LICENSING

REQUIREMENTS OF

THE STATE OR COUNTRY IS CONSIDERED BY THE BOARD AND THE DEPARTMENT

TO BE

SUBSTANTIALLY EQUIVALENT TO THE LICENSING REQUIREMENTS OF THIS STATE

AND THE STATE OR

THE COUNTRY OBSERVES RECIPROCITY IN REGARD TO MECHANICAL

CONTRACTORS LICENSED IN THIS

STATE.

(2) THE DEPARTMENT MAY LICENSE, WITHOUT EXAMINATION OR PAYMENT OF

THE FEES

PRESCRIBED IN SECTION 10, AN APPLICANT WHO IS CERTIFIED TO INSTALL,

MODIFY, TEST,

SERVICE, INSPECT, OR MAINTAIN REQUIRED FIRE SUPPRESSION SYSTEMS UNDER

THE FIRE PREVENTION CODE, ACT NO. 207 OF THE PUBLIC ACTS OF 1941, BEING

SECTIONS29.1 TO 29.33 OF THE MICHIGAN COMPILED LAWS AND WHO SEEKS

LICENSURE UNDER THIS ACT ONLY.

IN THE WORK CLASSIFICATION SET FORTH IN SECTION 6(3)(G).

(3) THE HOLDER OF A LICENSE ISSUED PURSUANT TO THIS SECTION SHALL HAVE

THE RIGHT TO

RENEW THE LICENSE PURSUANT TO SECTION XX.

b.

Stated in Act 407 secꢀon 339.6111 (4) A licensed plumbing contractor

may operate 1 or more branch offices in this state under the same

business if a licensed master plumber is in charge and has the

responsibility of supervision at each branch.

(5) If a license is issued to a plumbing contractor represented by a

master plumber, the plumbing contractor and the master plumber are

jointly and severally responsible for exercising the supervision or

control of the plumbing operations necessary to secure full compliance

with this article, the rules promulgated under this article, and all other

laws and rules related to the installation of plumbing.

(6) Both a person, unless the person is a plumbing contractor, and

the master plumber are jointly and severally responsible for exercising

the supervision or control of the plumbing operations necessary to

secure full compliance with this article, the rules promulgated under

this article, and all other laws and rules related to the installation of

plumbing.

(7) If a plumbing contractor is represented by a licensed master

plumber who ceases to represent the plumbing contractor, the

plumbing contractor has 30 days after the date the master plumber no

longer represents the plumbing contractor in which to designate

another licensed master plumber as the representative of the

plumbing contractor. The plumbing contractor shall notify the

department in writing of the change.

c.

The same standards must be held to the Mechanical Code as the Plumbing Code.

This ensures life safety and proper training for license holders for the State of Michigan.

Roger Papineau Page 8

LARA-BCC-Rules

From:

Sent:

To:

Code Guy <rogerpa5401@gmail.com>

Tuesday, September 5, 2023 3:28 PM

LARA-BCC-Rules

Subject:

Part 9A Mechanical Code - Rule Set 2022-55 LR.

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov

9/5/2023

Bureau of Construction Codes

Attn: Tony Williamson, Bureau of Construction Codes P.O. Box 30254, Lansing, MI 48909

Bureau of Construction Codes, P.O Box 30254, Lansing, MI 48909

Via Email to Lara-bcc-rules@michigan.gov

Dear Mr. Williamson.

I am writing today to point out an obvious drafting error in the proposed language for Rules for Construction Code - Part

9A Mechanical Code

Rule Set 2022-55 LR.

The error is in R 408.30905a Definitions

Rule 905a

(b).

The Michigan Uniform Energy Code was rescinded by 2012 Act 504, eff. March 28, 2013.

The correct reference document, I believe, should be Michigan Energy Code (Part 10a).

Respectfully submitted,

Roger Papineau

1901 Beulah Highway

PO Box 574

Beulah, MI 49617-0574

231-651-9444

Sent from Mail for Windows

1

Ronald Shughart Pages 9-10

Rheem Manufacturing Company

Heat Transfer Products Group (HTPG)

September 05, 2023

Tony Williamson

Bureau of Construction Codes

Michigan Department of Licensing and Regulatory Affairs

P.O. Box 30254

Lansing, MI 48909

Re: Michigan Construction Code ‒ Part 9A. Mechanical Code Rule Set 2022‒55 LR

Rheem Manufacturing Company (Rheem) appreciates the opportunity to comment on the proposed rule set

2022‒55 LR to revise the Michigan Mechanical Code by adopting by reference the 2021 edition of the

International Mechanical Code with amendments, deletions, and additions as proposed.

Headquartered in Atlanta, Georgia, Rheem operates multiple U.S. facilities for the manufacture and support of a

comprehensive line of residential and commercial air conditioners and heat pumps, with nationwide distribution

through various channels. Through its water heating division, Rheem manufactures heat pump water heaters and

heat pump pool heaters, including those marketed under the Raypak® brand. The Heat Transfer Products Group

(HTPG), a division of Rheem designs, manufactures, and markets energy-efficient commercial and industrial

refrigeration equipment and system solutions sold under the trusted premium brands: Russell, Witt, Kramer, and

ColdZone. Through its Friedrich Air Conditioning division, Rheem is the sole manufacturer of room air

conditioners in North America, offering premium room conditioning and other home environment solutions for

residential, lodging, and multifamily properties.

Rheem supports updates to the Michigan Mechanical Code to enable installation of equipment designed for and

charged with group A2L refrigerants, and encourages the adoption by reference of the latest editions of the

consensus safety standards ANSI/ASHRAE 15 (2022), ANSI/ASHRAE 34 (2022), ANSI/UL 60335‒2‒40

(2022), and ANSI/UL 60335‒2‒89 (2021), as proposed by Mr. Thomas Deary in his public comment submitted

on behalf of the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) during the public hearing on

Tuesday, August 22, 2023 in Lansing, MI.

On December 15, 2022, the US Environmental Protection Agency proposed to restrict the use of certain

refrigerants in newly manufactured air-conditioning and refrigeration equipment.¹These restrictions are effective

from January 01, 2025. Through SNAP Rules 23, 25, and 26 the EPA approved the use of several substitutes in

these end uses²; many of these substitutes bear the ASHRAE safety classification of group A2L. The “2L”

¹Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection (i) the

American Innovation and Manufacturing Act of 2020, 87 Fed. Reg. 76738 (December 15, 2022) (to be codified at 49 CFR

Part 84).

²Protection of Stratospheric Ozone: Listing of Substitutes Under the Significant New Alternatives Policy Program, 86 Fed.

Reg. 24444 (May, 06, 2021) and 88 Fed. Reg. 26382 (April 28, 2023) (to be codified at 40 CFR Part 82).

flammability classification indicates lower flammability.³To comply with the EPA’s proposed restrictions,

manufacturers of air-conditioning and refrigeration equipment are re-designing their product portfolio use new

group A2L refrigerants.

Prescriptive requirements on the construction, installation, and operation of air-conditioning and refrigeration

equipment containing group A2L refrigerants are written in the standards cited above. These are industry

standards developed through the ANSI consensus process and have undergone several rounds of public review

and subsequent revision. These standards have been accepted for inclusion by reference in the 2024 edition of

the International Mechanical Code. Inclusion of these standards in the Michigan Mechanical Code will ensure

that installation of air-conditioning and refrigeration equipment in the state of Michigan follows best practices. It

will also prevent market disruption by maintaining consistency between the safety standards used by

manufacturers when designing new equipment, and the safety standards referenced in the Michigan Mechanical

Code.

Your sincerely,

Ronald Shughart

Compliance Projects Manager

cc: Allison Skidd, Director of Global Regulatory Affairs‒Air, Rheem Manufacturing Company.

³American Society of Heating, Refrigeration and Air Conditioning Engineers. (2022). Designation and Safety Classification

of Refrigerants (ANSI/ASHRAE 34‒2022).

Thomas Deary Pages 11-12

William Hordyk Pages 13-14