I just got off the phone with a contractor demanding to know what code section, in either the Uniform or International Plumbing Code, clearly states that a bypass is not allowed around a backflow prevention assembly. He had failed an inspection because of an unprotected bypass around the make-up water supply to a chemically treated hydronic heating system. From what he described to me, he had installed the bypass around both the backflow preventer and the pressure reducing valve feeding the system. I asked him what the code book he normally used and he told me he didn’t have a code book to reference – that was why he was reaching out to me. If you are doing work in a jurisdiction, it is common sense that you should have access to the adopted codes and regulations in that area and be familiar with the requirements of the projects you are working on. Too many times, this time being one, that is not the case. I explained to the individual that the codes do not have a section that specifically says that a bypass is not allowed around a backflow preventer. The code states that cross-connection protection is required. Installing an unprotected bypass around the required protection would be considered an unprotected cross-connection. Common sense tells us that it would be a violation of the regulations to pipe a system in a manner that would create an unprotected cross-connection.
This contractor was having none of this. He made his opinion clear to me that unless the code said it was prohibited, then it was not a code violation. I told him he was fighting a losing battle and he should either remove the bypass, re-pipe it to only bypass the pressure reducing valve, or install another backflow preventer in the bypass. He decided to move forward with option two, although I don’t think he really agreed that it was necessary. Section 602.3 Backflow Prevention of the 2018 Uniform Plumbing Code® states:
No plumbing fixture, device, or construction shall be installed or maintained, or shall be connected to a domestic water supply, where such installation or connection provides a possibility of polluting such water supply or cross-connection between a distributing system of water for drinking and domestic purposes and water that becomes contaminated by such plumbing fixture, device, or construction unless there is provided a backflow prevention device approved for the potential hazard.
This section makes it clear that any bypass would need to also contain backflow protection. Common sense makes this clear.
I also spoke with another individual this week who contacted me about a problem he was having. He had tested an assembly that was installed as containment on a three-story commercial property. The form he received from the water purveyor had listed a reduced pressure principle assembly as the existing valve. When he arrived to do the testing, he found a double check valve assembly was installed and the model and serial number did not match the paperwork he received. He made the correction on the form, tested the existing assembly, and sent the paperwork in. About 10 days later, he received a call from the water purveyor telling him they were not accepting the test form as valid because the building use called for a high hazard assembly and the double check valve that had been installed did not provide the required protection. He contacted me to see if a high hazard valve was really required. He explained that besides the containment assembly, there were no other backflow preventers installed within the facility. I explained that with containment or point of service protection, it is the water purveyor who makes the call as to what is required. I then asked him what the building use was. He said it was a mixed-use site with apartments on the second and third floors and commercial use on the first floor, which included a social club with a bar, restaurant, and catering. The building also contained a boiler and hydronic heating system. I told him that, in my opinion, the high hazard containment assembly made perfect sense to me and that additional protection was needed on the heating system and that issues may also exist inside the kitchen and bar areas. I asked him if he had looked at anything else besides the assembly he tested and he told me he did service work at this facility on a regular basis. I asked him about cross-connection protection on the heating system and he told that it was unprotected. I asked if he had ever pointed that out to the building owner or manager. He seemed surprised by this question and said, “No, why would I do that?” This is again where common sense needs to take over.
If you are testing backflow prevention assemblies in a facility, each test should in fact be a mini cross-connection survey. If we find unprotected cross-connections in any facility, we need to point it out to the owners and end users. We are the experts and, truth be told, not pointing out issues is negligent and may prove to be a liability to your company in the long run. We are not the backflow police and we can’t order people to do the right thing, but we have a responsibility and a duty to let people know issues exist and recommend corrective action. If you are called to test a large reduced pressure principle assembly in a facility with little or no drainage available, you need to document that and explain that it’s an accident waiting to happen. Common sense goes a long way in protecting yourself, your company, and your customers. Most people will do the right thing given the correct information. It’s our job to use our talent, expertise, and above all, common sense to protect the water supply.
