I-2066 Guidance from State Building Code Council & Public Health
Initiative 2066, which Washington voters passed in November 2024 and became law in December, impacts several policies related to natural gas use and penalties in Washington State. Our department has confirmed with both the City of Seattle and Unincorporated King County that we will keep enforcing the applicable energy codes as written until there is an official code change published. The State Building Code Council now has provided similar guidance state-wide on its webpage under "I-2066 Compliance."
Backflow Protection for Commercial Ice Machines
There have been numerous questions about the requirements for backflow prevention at commercial icemakers, specifically of the air cooled variety. NSF 12 is the applicable listing for these, but it is not currently a Plumbing Code requirement. There is a common misconception that having an NSF 12 listing means the ice machine is equipped with an internal air gap, but that is not correct. Section 5.27.1 of the Standard, which covers backflow prevention, allows a multitude of options for manufacturers to use. An air gap is one option, but a statement in the installation instructions noting a backflow preventer should be installed is also an option.
Because of this, we cannot rely on an NSF 12 listing by itself to ensure there is adequate backflow protection. As for the level of protection needed, the primary concern from a public health standpoint is the growth and spread of legionella if an ice machine loses power or becomes inoperative. A back-siphonage event could pull contaminated water back into the domestic water distribution piping where it could potentially be aerosolized through a shower head or similar fixture. Due to the severity of Legionnaire’s disease, we are currently requiring a backflow device that falls under UPC/SPC Table 603.2 for ‘high hazard’ subject to back-siphonage, but not back-pressure. This means an air gap, reduced pressure principle backflow assembly (RPBA), or pressure vacuum breaker.
You may be asked to show a plan reviewer or field inspector where in the ice machine manufacturer’s specifications an air gap is noted. If this information cannot be located, you will be asked to install one of the types of external backflow devices noted above.
The 2024 UPC includes an allowance in Section 603.5.12 to install a ‘low hazard’ ASSE 1024 or ASSE 1032 device. We are currently reviewing whether or not this level of hazard is appropriate and if these non-testable devices will be allowable given that Washington State amendment to UPC 603.4.2 requires all installed backflow devices to be tested.
More information will follow as we continue to evaluate this important issue.
By Dave Price, Assistant Chief Plumbing Inspector, Public Health - Seattle & King County
On occasion, one of our inspectors will come across a project where a sanitary waste pipe has been installed above a food preparation or food storage area. There are certain requirements for pipe protection in this situation, some of which can be found in UPC/SPC Section 317.1. Why only some? Because in addition to following UPC requirements, the installation is also subject to Washington State requirements, specifically Washington Administrative Code (WAC) 246-215-03354. This WAC requires ‘sewer lines’ (WAC term) above food areas to be ‘shielded’.
Measures that comply with the shielding requirement
While the WAC does not provide a definition for ‘shielding’, after discussion with our Public Health Food Safety Program and professional insulators from Heat & Frost Insulators & Firestop Workers Local 7, the following insulation measures have been determined to meet this threshold:
- Fiberglass insulation with ASJ (All-Service Jacket) and PVC jacketing, with 100% glued (welded) seams:
This system involves using fiberglass insulation with an ASJ layer, which provides a moisture barrier and enhances the mechanical strength of the insulation. The PVC jacketing is then applied, and the seams are meticulously glued or welded to ensure a secure and durable shielding solution.
- Fiberglass insulation with ASJ and Ventureclad Jacketing:
Another allowable system type is fiberglass insulation with ASJ, combined with Ventureclad Jacketing. This system involves applying an ASJ layer to the fiberglass insulation, providing similar benefits as mentioned before. The Ventureclad Jacketing, which is a self-adhesive aluminum foil, is then applied over the ASJ layer.
You will notice, standard pipe insulation with an ASJ is not considered adequate shielding.
In addition to the above pipe insulation options for shielding, the pipe can also be considered ‘shielded’ if it is installed above a continuous drip pan or a suspended ceiling. The ceiling may be the lay-in type, or a gypsum board ‘hard lid’. If a hard lid ceiling is used, access panels will be required in order to comply with UPC/SPC 317.1 (5). There is no specific width requirement for the hard lid ceiling. In theory, a 4” waste pipe could have a 6” wide ceiling below it and that would meet the intent of the WAC. If using a drip pan, you will be required to provide a drain connection on the drip pan in at least one location and that drain will need to be routed to an indirect receptor.
Considerations for the plan review process
To ensure the highest probability of success for your project, take note of any possible food preparation or food storage areas below the area of work. It is important to identify these areas on any plans submitted for plan review so that proper shielding, cleanout extensions, confirmation of seepage pans at floor drains, and other similar measures can be verified by the reviewer. It is much easier to implement any corrective actions and make budget or schedule adjustments during plan review than after the piping has already been installed. Please note, if you are performing plumbing work above a grocery store or similar occupancy, the entire floor area may be considered a food storage space.
If you have questions, concerns, or other ideas to share with our team, please feel free to send a note to: planreviewinfo@kingcounty.gov.
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