2021 Seattle Codes to take effect November 15, 2024
The 2021 Seattle Codes are set to take effect November 15, 2024. For additional information, please visit the City of Seattle 2021 Code Adoption-Timeline page. Note, the 2021 WA State Codes are currently in effect for unincorporated King County.
An archive of past PHSKC newsletters is now available online!
We have posted an archive registry with links to all previous issues of the PHSKC Plumbing and Gas Piping newsletter going back to November 2021 along with general descriptions of the contents of those newsletters. We will work to keep this registry updated regularly as time allows.
Grease interceptor installation requirements
Please be aware, there are installation requirements for grease interceptors that may go above and beyond what is specifically noted in the Plumbing Code. Seattle Municipal Code requirements and Seattle Public Utility (SPU) standards also apply to installations within the City of Seattle.
All suspended grease interceptor installations in Seattle are required to be reviewed for compliance by SPU prior to installation, with no exceptions. Grease interceptors are required to have a minimum of 36 inches clear from the top, and the lid must be no more than 48 inches above the surrounding floor level unless a permanent (and permitted) service and inspection platform is provided. We will be issuing a more comprehensive article on grease interceptor installation requirements soon.
By Dave Price, Assistant Chief Plumbing Inspector, Public Health - Seattle & King County
We’ve previously discussed the requirements in the Uniform Plumbing Code (UPC) for products to be third party Listed, and we’ve also reflected on the need for certain products to be listed to NSF 61, specifically. In this article we’ll take a closer look at which product types the NSF 61 listing requirement applies to and where we are as an industry in meeting those requirements. Note that this article is intended as an editorial, rather than an edict from the Authority Having Jurisdiction (AHJ).
Historical context on the requirements
Back when NSF 61 was introduced as a ‘Referenced Standard’ in the UPC, the federal law had a higher lead limit for plumbing components than it does now. When the federal law was updated to require lower lead levels, the National Sanitation Foundation (NSF) had to make some adjustments. This began with an add-on to NSF 61 called ‘Annex G’. If a product was listed to NSF 61-G, that meant that it met the requirements of the current NSF 61 standard and the new lower lead limit of 0.25%. Soon after, NSF developed a stand-alone standard called NSF 372. This standard was used to specifically test for lead levels, but nothing else. For a short period of time, some products needed to be listed to both NSF 61 and NSF 372 to show compliance with both federal law and the UPC.
In 2020, the NSF 61 standard was updated to coincide with the newer federal requirements for lead levels and align with NSF 372. Today, any product listed to NSF 61 is automatically in compliance with federal lead requirements and NSF 372. In addition to testing for lead (as NSF 372 does), NSF 61 also tests for leaching of other potentially harmful substances. This is why the UPC requires NSF 61 compliance for certain items and not NSF 372 compliance. NSF 61 is the more stringent standard.
Which products need to be listed to NSF 61?
Anyone can search the term “NSF 61” in an electronic version of the Plumbing Code and come up with an extensive list of products required to meet that Standard. In the 2018 UPC, the list includes: drinking fountains, fixture fittings, pipe, tube, fittings, valves, epoxy coatings, potable water tanks, and expansion tanks used in potable water systems. When it comes to Section 604.1, we are all generally familiar with what qualifies as a Pipe, Tube, or Fitting. These components, when in contact with potable water (‘drinking water’ as stated by the text) are required to comply with NSF 61.
But what about thermowells, test ports, air vents, and similar accessories used for balancing and testing? Surely these items cannot be completely unregulated, right? For that answer, we can look to the federal government. The Safe Drinking Water Act (SDWA) sets a limit on the amount of lead in plumbing components in contact with potable water. The law defines ‘potable water’ to include water used both for human consumption and cooking. As mentioned above, this lead limit happens to correspond with NSF Standard 372 (0.25%). Therefore, it would stand to reason that anything in contact with potable water that is not specifically required by the UPC to comply with NSF 61 should comply with NSF 372 (aka ‘Lead Free’).
So, where is the elephant?
The sections covering specific fixtures (415.1 & 417.1), potable water expansion tanks, and epoxy coatings (Sections 604.9 & 608.2) are not that complicated. There are plenty of those types of products on the market that are appropriately listed. But start to focus on the sections covering valves and potable water storage tanks (Sections 606.1 & 607.2) and, now, we can begin to see the shadow of our illusive pachyderm.
Going back to the text of SDWA, the definition for ‘potable uses’ includes cooking, drinking, food preparation, dishwashing, and human ingestion. Using this definition, it’s fairly obvious that both hot and cold water supplied to a residential kitchen sink and hot water supplied to a domestic dishwasher would be considered a ‘potable use’. You can probably imagine someone using their kitchen sink faucet to fill a tea kettle or a pot to cook rice or pasta. It is entirely feasible that they may tilt the faucet lever toward the left and use either hot water exclusively, or a mix of both hot and cold water to fill the vessel. We’ll get in to why this matters in a moment.
Let’s take a closer look at Section 606.1 (Valves). Most valve manufacturers will be happy to sell you an NSF 61 listed ball valve, globe valve, gate valve, check valve, etc. But why are there so few balancing valves that are NSF 61 listed? The answer I’ve been given by several manufacturers is that these valves are only used in hot water systems, and hot water is not used for drinking. Going back to the tea kettle example above, this response simply doesn’t check out. The same applies to thermostatic mixing valves. There are very few thermostatic mixing valves for central hot water systems (ASSE 1017) that are NSF 61 listed. Why is that? Isn’t NSF 61 compliance a UPC requirement for all valves in potable water systems? The ASSE 1017 standard does reference NSF 372, but not NSF 61.
Moving on, Section 607.2 requires potable water storage tanks to be NSF 61 listed. So why are storage water heaters not NSF 61 listed? Are they not essentially potable water storage tanks with a heating element? There doesn’t seem to be any water heater on the market (storage or otherwise) with either an NSF 61 or NSF 372 listing. How is that possible? Chapter 5 of the UPC currently only requires water heaters to be listed to UL or CSA Standards. Fortunately, according to the Environmental Protection Agency, the ‘lead-free’ requirements of the federal SWDA also apply to water heaters within a potable water system, so there is some oversight there. All potable-use water heaters should comply with federal law, but without a Listing, it is difficult to verify compliance.
Concluding questions for consideration
Again, this article is meant to generate a discussion more than anything. When are manufacturers going to start listing all of their potable water contacting products to NSF 61? Will the Plumbing Code catch up and start listing these miscellaneous items specifically?
If you have any input or questions and would like to continue the conversation, please send an email to planreviewinfo@kingcounty.gov with ‘NSF 61’ somewhere in the email subject line.
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