The adopted plumbing code is where we look to find the required isolation backflow protection. Isolation, or point-of-use protection, is the protection at fixtures and appliances within a facility. It is what protects the individuals living or working in the structure. This protection can be as simple as an air gap or as complicated as a reduced pressure principle assembly. The United States currently uses three separate model plumbing codes. These include the Uniform Plumbing Code® (UPC®), the International Plumbing Code (IPC), and the National Standard Plumbing Code (NSPC). Three states still use state authored codes: Massachusetts, Kentucky, and Wisconsin. The 47 states that do adopt model plumbing codes, in many cases, amend some of the code language to meet the needs of their communities. Simply put, the regulation of isolation protection is not a one-size-fits-all situation.
Add to this issue the fact that model codes are updated every three years. We also need to realize that authorities having jurisdiction (AHJs) may amend the model code or, in many cases, delay adoption of the updated code or even skip a complete code-cycle update altogether. All of these factors make it incredibly important for people in the industry to understand the rules and regulations in any and all areas in which they are working. Some states adopt codes on a statewide basis, while others allow AHJs within the state to amend the adopted state code or even, as in the state of Texas, adopt a different model code. For example, the city of Dallas adopts the IPC, while the city of Houston adopts the UPC. We also need to understand that state environmental or health agencies may adopt regulations or rules that do not conform to the regulations in the state-adopted plumbing code. Sticking with Texas as our example, the Texas Commission on Environmental Quality (TCEQ) allows, in certain cases, the use of a low-hazard double check valve assembly (ASSE 1015) for landscape irrigation protection, while both model codes used in the state, the IPC and the UPC, require high-hazard protection on all irrigation systems. Situations like this reinforce the need for individuals to understand local, national, and state regulations. We also need to understand that these regulations can and do change.
The 2027 model plumbing codes are now becoming available. The UPC has made changes related to the required cross-connection protection. Product standards have also been updated, which may affect these regulations. While the laws of physics have not changed, the products and practices we use have. Change is the only constant in our industry.
As we look at the 2027 UPC, cross-connection control is covered in Chapter 6. Starting with Section 602.0 and ending with Section 603.5.23, the code gives clear, concise information on the selection and installation of the proper crossconnection in most situations. Chapter 15, Alternate Water Sources for Nonpotable Applications, and Chapter 16, Nonpotable Rainwater Catchment Systems, also contain cross-connection control information and requirements.
It is important to remember that the code is the minimum standard. An installer or designer can always go above and beyond these requirements. If we look at the code process, it is clear that, no matter which model code we look at, the code process looks at the technical merit of code requirements or of code changes in its decision-making process. Each code body has a process it must adhere to that allows industry stakeholders to have a voice in some part of that process. I personally prefer the open consensus process used by IAPMO in the development and updating of the UPC. This process allows industry stakeholders a voice and a vote throughout the process.
If we look at code changes that took place during the 2024 UPC code cycle, several addressed specific issues with cross-connections. One such issue is the installation of chemical dispensing equipment.
In Section 603.5.22, the 2024 UPC inserted new language to address an existing problem with the water supply to an ASSE 1055 Chemical Dispenser with Integral Backflow Protection. This change in subsection (1) addressed the issue of using an existing faucet as the water supply.
603.5.22 Chemical Dispensers. The water supply to chemical dispensers shall be protected against backflow by one of the following:
(1) The chemical dispenser shall comply with ANSI/CAN/ASSE/IAPMO 1055. Where an installation involves a water source coming from a faucet with an integrated vacuum breaker device, a pressure bleed device conforming to IAPMO PS 104 shall be used to protect the vacuum breaker device.
(2) Water supply shall be protected by one of the following methods:
(a) Air gap
(b) Atmospheric vacuum breaker (AVB)
(c) Pressure vacuum breaker backflow prevention assembly (PVB)
(d) Spill-resistant pressure vacuum breaker (SVB)
(e) Reduced-pressure principle backflow prevention assembly (RP)
This change makes technical sense, but many in our industry are still resisting this common-sense solution, with some jurisdictions still looking to install a testable assembly on these devices. Another change to the 2024 UPC relates to beverage dispensers. The 2021 UPC required the installation of an ASSE 1022 device on all beverage dispensers, including coffee machines. The 2024 UPC states:
603.5.12 Beverage Dispensers. Potable water supply to carbonated beverage dispensers shall be protected by an air gap or a vented backflow preventer that complies with ASSE 1022. For carbonated beverage dispensers, piping material installed downstream of the backflow preventer shall not be affected by carbon dioxide gas. Non-carbonated beverage dispensers, such as ice makers and coffee machines, shall be protected by an air gap or dual check backflow preventer that complies with ASSE 1032 or ASSE 1024.
This was a reasonable change that allowed the use of dual checks in some installations. These small changes in text can result in major changes to the required protection. They are also things that inspectors, installers, and designers sometimes miss. A perfect example of this is our code language about the atmospheric vacuum breaker (AVB). When the ASSE 1001 AVB Product Standard was updated in 2017, a major change went unnoticed by many people. The requirement that no valve be installed downstream of the AVB was changed to state that the device shall have its outlet open to atmosphere. It took the model codes some time to recognize this change, but it has now been recognized, and a valve can be installed downstream of an AVB as long as there is always an outlet open to the atmosphere to prevent continuous pressure or backpressure on the device.
People in every industry resist change. The cross-connection industry is no exception. We need to stay on top of changes in our products, and in our rules and regulations. Several backflow-related changes exist in the 2027 UPC. One is the addition of Section 603.3.13, which addresses hose bibb vacuum breakers in the body of the code. It states: “A hose connection vacuum breaker consists of a check valve force loaded or biased to a closed position, and an atmospheric vent valve, force loaded or biased to an open position when the device is not under pressure.” A number of changes were also made to Table 603.2. Another addition is Section 603.5.20, which covers backflow protection for pet wash stations. It states that where pet wash stations are connected to a potable water supply system, the system shall be protected against backflow in accordance with Table 603.2.
Every time we test a backflow preventer, inspect a plumbing system, conduct a sanitary survey or design a water system, we need to be aware of the rules and regulations in that specific area. We need to stay current. We need to document problems and develop solutions. When I was working in the field and failed an inspection, I always asked the inspector to cite the code section or regulation I was in violation of. Sometimes the change was needed; sometimes the inspector was incorrect and unaware of regulatory changes that had occurred. Chemical dispensers and beverage dispensers are perfect examples of situations in which inspectors may try to require protection that is not required by the codes or regulations. Asking for a stainless steel reduced pressure principle assembly to be installed in a jurisdiction where the regulations allow an ASSE 1022 device can be an expensive issue for your customer. Common sense needs to be used in all situations.
Codes and regulations give us a basis to ensure the correct protection is installed correctly. Clearances, heights, access, and other requirements can be found in the codes, standards, and regulations. Proper inspection by trained individuals also allows us to have confidence that our systems are properly protected. Backflow assemblies are installed incorrectly far too often. In many cases, there is not a specific code section that refers to an assembly’s installation. But if we understand product standards and manufacturers’ installation requirements, we can get the job done properly. An understanding of the purpose of the protection and of the testing and maintenance of that protection should stop the common problem of assemblies being installed 40 feet in the air.
Remember the two P’s when we think about backflow prevention and cross-connection control. Be proactive in everything you do. Look to the future and try to make sure you understand the regulations and requirements and have the specific knowledge required to get the job done. Be pessimistic. Do not assume that whoever was there before you did things correctly. Always consider the worst-case scenario, and make sure the necessary protection is in place. Keep an open mind about changes in regulations and codes and, most importantly, stay current on any and all changes.
