Upcoming Changes to Mandatory Plan Review for Schools and Daycares 

Public Health has historically required any work in a school or daycare to go through plan review. Based on public feedback, we will begin reviewing the scope of work on these projects on a case-by-case basis to determine if plan review is required. This change will be rolled out later this year, and we will announce updates in this newsletter. Until then, all work in daycares and schools will still require plan review.  

With this change, each project will be evaluated independently, and the determination will not be made using the standard criteria from our Occupancy and Use guidance document. If the work is considered broad enough in scope that an inspector would have difficulty assessing code compliance in the field, plan review will still be required. Very limited work (such as relocating a single sink or replacing a water heater) will be allowed to proceed with an over-the-counter permit. 

Combination fire/domestic water service is considered plumbing work 

Occasionally when a project is proposing to use a combination fire/sprinkler and domestic water line, there are notations on the plans indicating this work will be installed by the fire/sprinkler contractor. Per RCW 18.106 and the Plumbing Code, this is not permitted.  

The service line up to the point of the fire/sprinkler backflow assembly is considered ‘potable water’ and is required to be installed by a licensed Plumbing Contractor. This work should be on the plumbing permit and will be inspected by a Public Health plumbing inspector. 

“It shall be unlawful for a person to install, remove, or replace or cause to be installed, removed, or replaced a water heater without first obtaining a permit from the Authority Having Jurisdiction to do so,” (UPC/SPC 502.1).

This statement has been in the Seattle Plumbing Code since the 2012 edition and has been in the Uniform Plumbing Code in some form since as far back as 1970. 

Historically, our jurisdiction has not required a permit for the replacement of ‘like-for-like’ water heaters. Public Health has been an outlier in this regard as the vast majority of jurisdictions throughout the State (and the Country) do require permits for all water heater replacements.  

In order to comply with existing code requirements, and to better align with neighboring jurisdictions, Public Health will begin requiring permits for all replacement water heaters beginning July 1, 2026. 

This will be a phased implementation to allow industry to adjust. Note that we are currently in Phase 2 of the implementation. 

Phase 1: 11/1/25 - 4/15/26 

Industry outreach to assess current practices and ability to adjust to new permitting requirements (surveys, newsletter, direct outreach). 

Phase 2: 4/15/26 - 6/30/26 

Communication with industry stating intention to require permits for all replacement water heaters beginning 7/1/2026 (newsletter, direct outreach). Public Health inspectors focus on outreach and education. 

Phase 3: 7/1/26 - 12/31/26 

Begin requiring permits for all replacement water heaters. If a water heater is found to have been replaced without a permit, the contractor will be directed to obtain a permit or add the water heater to an existing permit (an administrative fee will be applied).

There will not be any further penalty. Public Health plan review team will begin ensuring replacement water heaters are listed on permits for projects undergoing plan review. 

Phase 4: 1/1/2027 and onward 

At this point, permits for replacement water heaters will have been in effect for 6 months. Contractors will be expected to obtain permits and include replacement water heaters on permits associated with other plumbing work.

If a replacement water heater is found to be installed without a permit, the contractor will be required to obtain a permit and pay the ‘Already Built Construction’ permit fee (double standard permit fee). 

Why are we doing this now?  

With the development of ever-more-stringent Energy Codes and new technologies coming to market, replacing a water heater is not as straightforward as it once was. New hybrid style water heaters often require direct ducting to the outside, and permanent condensate accommodation. High efficiency gas fired water heaters are often condensing and require condensate neutralization. Additionally, our inspection staff has been witnessing an increase in the number of incorrectly installed gas fired water heaters that have lead to dangerous carbon monoxide (CO) levels within occupied spaces. 

Please be aware, when installing a replacement water heater, a mechanical or electrical permit may also need to be obtained from the appropriate permitting authority. Electrical permits are triggered when any electrical circuit is added or modified. Mechanical permits may be triggered if there is relining of a utility chimney involved, or a new B-vent is added. Split-system type heat pump water heaters (with an outdoor condensing unit) also require a mechanical permit. 

We thank you in advance for your cooperation in ensuring all water heaters are installed in a safe and code compliant manner.