Speak now or forever hold your peace

Rich_49

https://www.linkedin.com/grp/post/3898754-5987254677194944513

SWEI

Thanks, Rich.

Bean makes some very good points there.

Rich_49

Kinda makes me wanna read the whole thing for all proposals . Hope others read and comment also .

Tinman

I just read the bullet points. My knee jerk reaction is why not defer to manufacturer recommendations? I don't think the products we use should be treated as commodities. I'd like to think each one of us puts a lot of thought and consideration into what we use and why we use it. Why treat everything as equal using a seemingly arbitrary guideline?

Also, imagine this nightmare...a perfectly designed and installed radiant panel was just installed in a basement that is going to be finished. The plans for the walls were given to the radiant contractor and they carefully avoided running the tubing beneath future walls, lessening the chance that the carpenter shoots a 16cc nail in one.

But then, the plans change after the concrete pour and now we have walls everywhere but where they were suppose to be. The carpenter is careless and hits the tubing in just one spot. Just one. What do you do now? Abandon the radiant panel because no coupling we'll be approved? Not likely. Imagine the potential litigation.

Rich_49

Stephen ,
I would suggest that you utilize the comment period to at least later on be able to say you commented and tried . This is exactly why Robert posted this and why in turn took it here and to Taco FloPro Neighborhood .
Some of these are bad ideas and elsewhere in the document I am sure there will be other things for us to comment on or attempt to bring up to date . Have at it , I know I will be commenting on several things .
If you are in a position to cast a vote as many are able to I encourage it .
We have sat on our asses long enough while the uninformed policymakers destroy our industry . I believe that we all need to be more involved in this end of the process .

Tinman

I used a bunch of questions marks which clearly would suggest I don't pretend to have all the answers. That being said, a few things that I read concerned me.

Tinman

A couple more things and then I'll put a sock in it.

If I know a loop, or loops, have been compromised before the pour I'd gladly replace that loop(s) and hopefully work something out with the guilty party. It would be a small price to pay.

But, if a single loop is hit after the pour I'm going to repair it. One could argue that REHAU's couplings/methods are as strong or stronger than the tubing itself.

Mark Eatherton

Allow me to try and calm the waters here. I do want to encourage as many people as possible to step up to the podium and express your concerns. Steve, this is the UMC and USEHC. Both are consensus ANSI documents, meaning that all stakeholders get an opportunity to express their concerns all along the development phases of the code. This process started for the USHEC about 3 years ago. Unfortunately for the RPA, we got into the process late, and weren't a recognized authority as viewed by the Technical Committee (TC) charged with rebuilding the USEHC.

As an employee of the IAPMO Group, I am not allowed to have any direct influence on the development of the code. I can express my technical concerns, which I did to the UMC, the UPC and the USEHC, but it still comes down to majority rules. If the people who are on these TC's do not see it your way, then your proposition probably won't withstand the test of time. All of Robert's and the other concerned manufacturers are very valid in my personal opinion. And as noted, I suggest that if anyone else has a concern that they express them during the open comment period.

However, and this is a big however, building a "family" of codes that are interdependent on each other is not as easy as it sounds. The three different codes are up every 3 years for review, and comments for modification. There are a limited number of people within the IAPMO Code Development office, and they can only handle so many changes at a given time. So they start with the UPC, and then do the UMC, and then do the USHEC, then finally the USPHTC (Uniform Swimming Pool/Hot Tub Code).

In order to keep from getting into situations of potential code conflict, there is a TCC (Technical Correlating Committee) in place who's job it is to make decisions where there are potential conflicts in the family of codes. The TCC is assembled from TC members from the 4 different code committees to give good balance. Historically, the plumbing and mechanical codes have been the precedent setters because they are completed first, so all following codes are generally correlated to the existing codes.

Such is the case with the fittings in the concrete ruling. The USEHC voted to allow factory approved fittings for direct burial in concrete slabs. The TCC, who's job it is to correlate these codes knew that the UMC doesn't allow for the direct burial of PEX fittings, or other fittings for that matter, except fusion welded or cement solvent welded fittings in concrete. So, they (TCC) reversed the decision made by the USEHC TC. They didn't "outlaw" the use of factory approved fittings in concrete, and it is allowed, provided that you can show proof that the manufacturers have had their materials tested BY a nationally accepted standard testing agency.

In verbal discussions with the UMC TC, they said that their biggest fear was that some guy with a bunch of short lengths of PEX would couple them together in order to get a 300 foot circuit. I think that is a very valid concern, and based on my experience as an expert witness, I can clearly see their concerns. When I express concerns about "repairs" occurring in the field during a pour, they said the code doesn't address "repairs", emergency or otherwise, and most inspectors would look the other way provided that the repair were documented and triangulated for future reference as well as it could be, and were performed using manufacturer approved fittings.

Basically, unfortunately, that train (UMC) has left the station, for the next three years. Once completed, unless there is a serious life, health safety concern, that would warrant the issuing of a TIA, nothing can be undone until the next revision, three years from now. And this is pretty much the case with many of these folks concerns. The big train has left the station. The little, younger train (USEHC and pool codes) are just getting ready to leave the station.

However, there is a much greater need moving forward that all of you have an opportunity to get involved in. The TC positions for the UMC and the UPC are always looking for new volunteers to fill these positions. Many of the people who sit on the UMC and UPC TC's have done so for a couple of cycles. If we can get enough qualified candidate/volunteers to try and sit on these committees WITH SIGNIFICANT HYDRONIC/RADIANT EXPERIENCE, we stand a much better chance of seeing change happen during the next code cycle.

The makeup of all TC's and TCC's have to be done in a balanced manner. It allows for all "stakeholders" the opportunity to sit on one of the TC's and help guide them moving forward. The older candidates on most of these codes have a fairly good understanding of the subjects being thrown at them, but they do not have the expertise on hydronics and radiant hydronics that most people who frequent this site have. By getting onto one of these TC's, once you are in, they ask you questions about your areas of expertise, and will lean on you for advice as they begin reviewing changes for the next code cycle. Both the UMC and UPC are seeking volunteer candidates for these two TC's. The USEHC will not be soliciting volunteers until which time that code is completed and in print, probably some time around the end of September 2015.

Voicing your concerns now are just as important to getting into a given TC, because it shows industry concern, which will hopefully guide that given TC as they move forward with the next round of changes. Some of the changes that came through this last round were put together by concerned people, who unfortunately don't have the expertise necessary to avoid making rules that are in direct conflict with other rules from other Standards Development Organizations.

In closing, no code is perfect, especially a new code, like the addition to the solar code of hydronics. Overall, I think that these changes are good for our industry, and will level the playing field and allow us to instill confidence in the consumer that our industry really does make an effort to try and get things as right as we can, given the constraints with which we are required to work.

If you are interested in getting involved in the development of these codes, please feel free to contact me at mark.eatherton@iapmo.org and I will get you the necessary paperwork to allow you to apply for placement on these committees.

The good news, as I have already stated, is that these codes are reviewed and renewed every three years, which in old man terms, is like TOMORROW.

Thank you for taking the time to read this lengthy submission, and feel free to ask any questions you have and I will address them as well as I can given my position.

EDIT: Added link to USEHC Code web site.

http://codes.iapmo.org/home.aspx?code=USEHC

All codes are available for review at www.iapmo.org and then click on Codes. If you have any questions of staff, please feel free to contact Hugo Aguilar at 909-472-4111

Thank you for your continued support of these very important programs.

ME