Dave Watson  
LARA-BCC-Rules  
From:  
Sent:  
To:  
Dave Watson <dwatson@davewatson.biz>  
Monday, August 28, 2023 9:03 AM  
LARA-BCC-Rules  
Cc:  
Myers, Kole (LARA); tdanielak@ualocal85.org  
Proposed changes to the Construction Codes,Part 7  
Plumbing-Part 7.pdf  
Subject:  
Attachments:  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Att. Tony Williamson  
This is to advise the BCC of my opposition to certain proposed changes in the  
Michigan Plumbing Code.  
Specifically, a new ASSE standard for water heaters, ASSE 1082, is being misapplied  
in the following 2021 IPC sections.  
412.5 bathtubs and whirlpools  
412.10 head shampoo sink faucets  
423.3 footbaths and pedicure sinks  
607.1.2 tempered water temperature control.  
The misapplication of ASSE 1082 could result in hot water scald burns. the  
attached PDF contains the forward to ASSE 1082 where in the highlighted area it  
states " these devices are not intended for end use applications..."  
To continue. An existing ASSE standard, ASSE 1017 "performance requirements for  
mixing valves..." is being misapplied in 2021 IPC 607.1.2. The title of 607.1.2 is  
Tempered Water... Tempered water being 85F-100F per IPC definition. ASSE 1017  
mixing valves may be adjusted to an outlet temperature of 180F and should not be  
listed with standards for tempered water. Additionally, to kill legionella in hot  
water distribution systems, ASSE1017 mixing valves are often used and set at  
160F. An ASSE 1017 mixing valve misapplied for tempered water could result in  
3rd degree burns, even death. Please see PDF ASSE 1017 highlight.  
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To continue. Proposed Michigan rule 727c is a modified 2021 IPC 607.1.2 and  
contains as outlined in the above 607.1.2 statement. So, for this reason, I oppose  
the rule.  
Additionally proposed Michigan rule 727c has added a #5 to the list, "emergency  
eye wash... 60F-100F... conforming to ASSE 1071." This code requirement already  
exists in 2021 IPC section 411. My concern is that adding it to rule 727c, which  
contains ASSE 1017 mixing valves that can be set at 180F, could cause confusion,  
misapplication and hot water scald burns.  
I am Dave Watson, a Michigan based representative for manufacturers producing  
valves to ASSE standards.  
Respectfully,  
Dave Waston  
Thank you,  
Dave Watson  
Dave Watson Associates  
Personal email: dwatson@davewatson.biz  
Corporate email: dwa@davewatson.biz  
ph 517-263-8988  
fax 517-263-2328  
2
Dave Watson  
Kevin Roby  
Lisa Reiheld  
LARA-BCC-Rules  
From:  
Sent:  
To:  
Lisa Reiheld <lreiheld@iccsafe.org>  
Friday, September 8, 2023 7:00 AM  
LARA-BCC-Rules  
Subject:  
Attachments:  
Comments on Proposed Rules Construction Codes - Part 7 Plumbing  
DraftRule Construction Codes - Part 7 L Reiheld Comments.doc  
CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov  
Hello,  
I am an ICC Staff member in the ICC Plumbing, Mechanical, and Fuel Gas Technical Resources group and cover the state  
of Michigan as part of my area of responsibility. I am happy to hear that you are moving forward to the adoption of the  
2021 IPC as the Michigan Plumbing Code.  
I have reviewed the Proposed Rules for Part 7 Plumbing, that I downloaded as Word document from the LARA website,  
and have noted several changes that are primarily editorial in nature to these rules. I believe that these suggested edits  
and corrections will improve the document and make this document match the 2021 IPC document, without changing  
the intent of any modifications that Michigan is attempting to make.  
If I need to submit these comments other than via the attached marked up Word document, please let me know.  
My group at ICC often provides education for building officials within a state on the significant changes from one code  
edition to the next, incorporating any state adopted amendments as well. Please let me know if that would be of any  
value to you as you go forward with your adoption of the 2021 version of the IPC as the Michigan Plumbing Code.  
Thanks in advance for your consideration of the suggested edits,  
Lisa  
Lisa Reiheld  
International Code Council  
Director, PMG Technical Resources  
Mobile: (202) 945-7875  
lreiheld@iccsafe.org  
www.linkedin.com/in/lisa-reiheld/  
PMG - ICC (iccsafe.org)  
Join us in St. Louis, MO for the 2023 International Code Council's Annual Conference and Expo, October 8-11.  
This year's event will feature industry-leading education, special networking events, inspiring speakers and  
historic building tours.  
1
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William Hordyk  
My name is William Hordyk, and I am a registered Building Official in the State of Michigan serving the  
community of Grand Rapids. I also hold 20 national certifications with the International Code Council,  
including that of Master Code Professional.  
I present these finding on behalf of myself and the Metro Building Inspectors Association of Greater  
Grand Rapids, a group of over 130 registered building officials and inspectors performing their duties for  
over 70 delegated authorities in the state of Michigan.  
We are concerned about the proposed rules for the 2021 Michigan Plumbing Code. We believe that  
there has been insufficient effort put forth by the bureau in reviewing the existing administrative rules  
in context of the 2021 code, not by lack of trying from the individuals tasked, but by the lack of  
leadership in recognizing the enormity of the task.  
Specifically, I have found that:  
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Multiple existing rules reference code sections that do not exist in the 2021 code.  
Some proposed and existing rules reference unassociated code sections.  
Many rules propose the exact language of the 2021 model code.  
We are also concerned about the bureau's apparent intent to strike model code language that has  
existed from the conception of the Stille DeRossett-Hale Single State Construction Act. Code language  
that has not changed but is now deemed to contradict the Act.  
We believe that the bureau should not be in the business of overruling the will of the legislators. If the  
writers of PA 230 objected to the model code language available to them when crafting the legislation,  
they would have written such language out within the Act.  
Finally, I am concerned about the multiple instances where new administrative rules are proposed with  
exacting language of the 2021 International Plumbing Code. As rule 701 proposes to adopt the 2021 IPC,  
we see no reason for additional rules to specifically adopt individual sections of the model code.  
Following this are 5 pages of specific errors within the proposed rules.  
We urge you to reconsider the proposed rules and to ensure that they are consistent with the Stille  
DeRossett-Hale Single State Construction Act and the language of the model code.  
Thank you for your time.  
Rule 701  
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It is proposed to except section 104.8 and 104.8.1. We would request a reasoning to why  
the bureau is removing protections for the Code Official from the model code language.  
IIt is proposed to strike section 108.2.5, 108.2.5.1 and 108.2.5.2. No such sections exist in  
the 2021 International Plumbing Code. The sections should be removed from the excepting  
statement.  
It is proposed to except sections 114.1 to 114.4. While section aa4.1 does exist in the 2021  
International Plumbing Code, Sections 114.2 t0 114.4 do not. The excepting statement  
should only identify section 114.1.  
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Sections 404.2 and 404.3 provide coordination with the accessibility standard and should be  
removed from the excepted sections to remain in the code.  
Section 712.3.3.1 and 712.3.3.2 provide for appropriate materials to be used with sump  
pumps and should be removed from the excepted sections to remain in the code.  
Section 802.4.3.1 is an acceptable alternative for compliance of a laundry tray and  
standpipe. It should be allowed to remain in the code by striking reference to it from the  
excepting language.  
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Chapter 13 and Chapter 14 have been stricken from the model code. Neither section is a  
requirement for construction but do provide requirements if the applicable systems are  
chosen to be utilized. The related systems would be great opportunities for conservation of  
water and should remain as options. 1301 to 1304.4.2 and 1401 to 1403.2.1 should be  
stricken from the excepting language.  
Rule 711  
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Within Section 101.2; It is proposed to strike the term “townhouse” and replace with the  
phrases “such as townhouse”. The term “townhouse” is a defined term with the I-codes and  
has specific placement within the Residential Code to alter the reference will only cause  
confusion in how the codes are enforced.  
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Within section 101.3; The purpose of the Stille-DeRossett-Hale single state construction  
code act should not be redefined. The purpose and precedence of PA 230 is appropriately  
written into the Act itself and does not require substantiation with the plumbing code  
Section 101.3 should not add “and the Stille-DeRossett-Hale single state construction code  
act, 1972 PA 230, MCL125.1501 to125.1531” to the purpose of the plumbing code. I take no  
issue with the text replacing the term “act”.  
Rule 723  
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The Existing amendment is the current language of the 2021 Model Code. Rule 723 Should be  
rescinded.  
Rule 725d  
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The proposed language is that of the 2021 model code. There is no need for Rule 725d as rule  
701 adopts the language. Rule 725d should not be added to the administrative code.  
Rule 725e  
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The proposed language is exactly that of the 2018 model code. The 2021 model code language  
more accurately addresses hydromechanical grease interceptors. Rule 725e should not be  
added to the administrative code.  
Rule 725f  
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The proposed language is exactly that of the 2021 model code. There is no need for Rule 725f as  
rule 701 adopts the language. Rule 725f should not be added to the administrative code.  
Rule 725h  
The proposed language is exactly that of the 2018 model code. The 2021 language adds a useful  
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standard for test gauges. Rule 725h should not be added to the administrative code.  
Rule 726a  
The proposed rule recreates an existing table from the model code. As an equal alternative to  
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placing duplicative language from the model code into Michigan administrative rules, consider  
the following language with the exacting result:  
“ The following material and standard is added to table 702.4 of the code: Galvanized steel  
pipe, ASTM A53”  
Rule 727  
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The proposed table is exactly that of the 2021 model code. There is no need for Rule 727 as rule  
701 adopts the table. Rule 727 should be rescinded from the administrative code.  
Rule 727a  
The proposed language is that of the 2021 model code, other than the word “space” being  
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added in conjunction with “tenant”. To use the term ‘space’ in the manner suggested could be  
interpreted to mean a full-open valve is required for each and every room. There is no need for  
Rule 727a as rule 701 adopts the appropriate language. Rule 727a should not be added to the  
administrative code.  
Rule 727b  
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The proposed language is that of the 2018 model code. At committee, the benefit of labeling  
was found to not be cost effective and removed from the 2021 International Plumbing Code.  
Rule 727b should not be added to the administrative code.  
Rule 729  
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The amendment of the existing rule recreates table 605.3 from the model code. The proposed  
change to the table exists within the 2021 model code and is unnecessary.  
The exiting rule proports to amend section 609.3. The language given is exacting to the language  
of the 2021 model code and in unnecessary.  
Rule 729 should be rescinded.  
Rule 729a  
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The proposed rule recreates an existing table from the model code. As an equal alternative to  
placing duplicative language from the model code into Michigan administrative rules, consider  
the following language with the exacting result:  
“ The following material and standard is added to table 605.5 of the code: Galvanized steel  
pipe, ASTM A53”  
Rule 729b  
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The proposed rule recreates an existing table from the model code. As an equal alternative to  
placing duplicative language from the model code into Michigan administrative rules, consider  
the following language with the exacting result:  
“ The following material and standard is added to table 605.8 of the code: Galvanized steel  
pipe, ASTM A53”  
Rule 732  
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The proposed language is exactly that of the 2021 model code. There is no need for Rule 732 as  
rule 701 adopts the language. Rule 732 should not be added to the administrative code.  
Rule 736  
The proposed language is that of the 2021 model code with only an unneeded reference to  
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section 607.1.2. There is no need for Rule 736 as rule 701 adopts the language. Rule 736 should  
not be added to the administrative code.  
Rule 741c  
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The existing administrative rule should be rescinded as the language would dis-allow the use of  
a NFPA 13D suppression system which is allowed per the Michigan Residential and Building  
codes. The language of the model code agrees with the administrative rule while allowing for a  
domestic suppression system (13D)  
Rule 753b  
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The proposed language is proports to add a section to the model code. The language is  
amending a code section.  
Rule 754a and 754b  
The existing rules seem to expand the scope of regulation from a defined climate to the entire  
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State of Michigan. To be clear, yes, the entire state would fall within the stated climate  
standard. There is no need to continue changing the model code language and to avoid a proven  
track record in reviewing code changes, it would be better to resend the code sections as the  
change is inconsequential.  
Rule 755  
The amendment of the existing rule recreates table 1102.4 from the model code. The proposed  
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change to the table exists within the 2021 model code and is unnecessary. Furthermore errors  
remain in the existing text of the rule and it appears intended correction of the table was  
misapplied.  
Rule 755a  
The proposed language is that of the 2021 model code. There is no need for Rule 755a as rule  
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701 adopts the language. Rule 755a should not be added to the administrative code.  
Rule 757  
The existing administrative rule attempts to add section 708.3 (in actuality, the ICC correctly  
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writes the sections as 708.2) But even so the language exists as section 708 of the Model Code.  
Rule 757 should be rescinded.  
Rule 757a  
The existing rule amends the model code to state the requirement for “approved” materials.  
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However, Rule 701 strikes what is to be considered “approved”. Ceder shakes are an “approved”  
material but would not be suitable for discharge piping. Rule 757a should be rescinded.  
Rule 758  
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The proposed change to 403.1.1 is the language of the 2021 model code. There is no need for  
restating the language as it is adopted by Rule 701  
The proposed changes to the text of table 403.1 serves only to align the Michigan Administrative  
Rule with the exact text of the 2021 model code. Rather than continuing to modify the model  
code by rule, the amending of table 403.1 should be struck from the rule to allow the model  
code table to remain unchanged.  
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The proposed amendments to the footnotes of table 403.1 should be rescinded. The only  
change proposed other than to align with the 2021 model code includes a change to substitute  
the term “individuals” for the term “persons”. The term “persons” is a defined term within the  
entirety of the 2021 model codes. To arbitrarily substitute a synonym here will only serve to add  
confusion.  
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Rule 758 should be rescinded.  
Rule 758a  
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The proposed addition would actually be an amendment to existing language. The language of  
the 2021 model code is clearer than that proposed. The proposed language does not add or  
subtract from that of the model. Rule 758a should not be added.  
Rule 758b  
Rule 736 proports to add the same section that also exists as the exact language of the 2021  
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model code. Rule 758b should not be added.  
Rule 763a  
There is an ongoing error and omission that is being corrected by the ICC when publishing the  
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MPC. The text of this administrative code is to modify 416.5, the same-named code section is  
419.5. ICC has been correcting the rule to reference the appropriate section. The amendment to  
the model code language is inconsequential to the enforcement of the code. The administrative  
rule 763a should be rescinded.  
Rule 785  
The Model code section proposed to be modified contains the state language, is clearer, and has  
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been improved from the period in which the existing rule was written. The administrative rule to  
amend the model code should be rescinded to allow the model code language to remain  
unchanged.  
Rule 791  
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"Act" should not be defined in the plumbing code. Nowhere does the model code address an  
"act" as in a Public Act. Defining act here could add confusion where the model code requires  
and individual to perform and act, and now we have a defined term that douse not match the  
intended meaning of the word. There are deferent Public Acts address by rule change, not solely  
PA 233, and everywhere an act is referenced the rule calls out which act specifically by name.  
Act is defined in PA 233, there is no need to redefine it in code language.  
Rule 792  
802.1.8 Does not exist within the 2021 IPC. Rule 792 should be rescinded.  
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;