- UPC Code Amendment Proposal

STATE OF HAWAII CODE AMENDMENT PROPOSAL
FORM FOR PUBLIC PROPOSALS TO AMEND THE HAWAII STATE BUILDING CODES
(Form Version 1.0 May 2010)

Name: Dwight Perkins, Sr. VP. Field Operations

Date: August 23,2017

Department/Company: The International Association of Plumbing and Mechanical Officials

Submitted on Behalf of: The International Association of Plumbing and Mechanical Officials

Address: 53014 Alba Street

City: Lake Elsinore

State: CA

Zip Code: 92532

Phone: 503-307-9944

Ext.

Fax:

E-mail address: Dwight.perkins@iaprao.org

2) Indicate appropriate Model Code(s) and Sections to be amended in Hawaii by this Proposal

CODE AMENDMENT PROPOSAL INSTRUCTIONS
Please provide all of the following items in your code change proposal.
REQUIRED INFORMATION:

The following items are required to be included in your proposal:

1. The proponent shall clearly stale the purpose of the proposed code amendment (e.g.. clarify the Code; revise outdated material; substitute new or revised material for current provision of the Code; add new Hawaii requirements to the adopted Code; delete current requirements, etc.). Any proposed revisions or additions to tables or figures must be included.

2.The proponent shall justify amending the current code provisions, stating why the proposal is superior to the current provisions of the Model Code. Proposals that add or delete requirements shall be supported by a logical explanation which clearly shows why the current Code provisions are inadequate or overly restrictive, specifies the shortcomings of the current Code provisions in Hawaii, and explains how such proposals will Improve the Hawaii State Code,

3. The proponent shall substantiate the proposed code change based on technical information and substantiation. Substantiation provided which is determined as not germane to the technical issues addressed in the proposed code change shall be identified as such, and the proponent shali be notified that the proposal is considered an incomplete proposal and may be held until the deficiencies are corrected.

4.The proponent shall submit a bibliography of any substantiating material submitted with the code change proposal. The proponent shall make the substantiating materials available for review.

5. Per Hawaii Revised Statutes § 107-26. the Stale Building Code Council shall not adopt provisions that relate to administrative, permitting, or enforcement and inspection procedures of each county. Any such code amendments shall be proposed instead to ihe individual county building officials during the code adoption process of each county.

PROPOSAL FORMATTING:

Show the proposal (see form on page 2) using strikeout, underline formal. At the beginning of each section, one of the following instruction lines are also needed;

•Revise as follows

•Add new text as follows

•Delete and substitute as follows

•Delete without substitution

The only formatting thai is needed is BOLDING, STRIKEOUT AND UNDERLINING. Please do not provide additional formatting such as tabs, columns etc. DO NOT USE THE TRACKING CHANGES OPTION, AUTOMATIC NUMBERING, OR ANY OTHER ADVANCED FORMA1TING TOOLS PROVIDED BY WORD.

This Section For official Use Only

Date Considered by Building Official Sub-Committee:_____

Sub-Committee Action on Proposal:_____

Reason for Sub-Committee Action:_____

Action by State Building Code Council:_____

Date:_____

PUBLIC PROPOSAL FORM TO AMEND THE HAWAII STATE BUILDING CODES
HAWAII CODE AMENDMENT PROPOSAL FORM
(See instructions on page 1)

Model Code: _2012 UPC -(Ibc-ob, iebc, iecc, ufc, imc,upc, irc, etc)

Code Sections/Tables/Figures/Standard Proposed for Revision; If the proposal is for a new section, indicate proposed section it.

Proponent: Name/Company/Representing: (DO NOT USE ACRONYMS FOR YOUR COMPANY OR ORGANIZATIONAL NAME)

Dwight Perkins, Senior Vice President, Field Operations, The International Association of Plumbing and Mechanical Officials (IAPMO)

Revise as follows (include deletion in strikeout, with modified text/proposed addition underlined, affected Code Section(s) in Bold):

§3-183-8 General Regulations.

Reason:

• No other discipline in the state is simultaneously regulated by two different codes; rules; sets of practice

• In the code development process and the adoptions of codes at the "local level" stakeholders demand an open, transparent process by the adopting agencies. Adopting a second plumbing code by flat legislation defies this concept.

• Technical Advisory Groups (TAG) are comprised of a broad spectrum of SME's (Subject Matter Expert) who can vet provisions - these committees and their members are completely excluded since the International Plumbing Code (IPC) will be adopted without any review or amendments as has been done to the 2012 Uniform Plumbing Code.

• The public is disenfranchised by not being permitted to speak on their perspectives regarding the IPC.

• The UPC as used in Hawaii since the early 1970's and requires ONE book.

• Journeyman Plumbers and Contractor licensing certify competency by taking exams based on the Uniform Plumbing Code.

• Plumbing Inspectors arc certified to the Uniform Plumbing Code.

• Apprenticeship and Journeyman classes are instructed on the plumbing installations based on the UPC.

• The County building department staff will have to become knowledgeable with the inspections required by the IPC and the differences between the IPC and the UPC.

• Any gain sought by the supposed "flexibility" of the IPC is already available by using UPC section 301.3 "Alternate Materials & Methods of Construction Equivalency". Here a Building Official or Plumbing Inspector have broad discretionary latitude.

• This proposal requires acquisition of six (6) additional volumes in order to have the full set of books required to perform all plumbing applications,

o IPC

o IRC

o IBC

o IECC

o IFGC

o IMC

o Plus NFPA 99 for Medical Gas systems

• "nobody" wants this change - the plumbing industry at large does not want a new or additional code regulating their work. This will cause an undo and unnecessary "unfunded mandate" to the industry

• one, namely the UPC which has served the industry and consumers very well is sufficient

o Journeyman plumbers

o Contractors

o Engineers & designers of plumbing systems

o MCA

o PHCC

o Trainers of apprentices & journeyman

• Cost - it is prohibitively expensive to have two (2) codes in play for all parties noted above. Bottom line, consumers will pay more...

• Hawaii State Statute mandates the use of the Uniform Plumbing Code. The Statute doesn't allow for adopting another code (IPC). Adopting two codes doesn't meet the intent of the Hawaii State Statute.

As a reference, the International Code Council (ICC) recently proposed similar language in Washington State and it was soundly defeated by both the Washington State Building Code Council and the Washington State Legislature because the State Statute mandates the adoption of the Uniform Plumbing Code. To adopt the IPC as an alternate code, it would not comply with the Washington State Statute.

List of Supporting Information References (attached):

Proposals must be submitted using this form and are to be submitted electronically to Council at state. bcc@hawaii. gov or mailed to the Department of Accounting & General Services, Administrative Services Office, 1151 Punchbowl Street, Room 414, Honolulu, Hawaii 96813

The following state regulations pages link to this page.