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Interpretations Request Input

Original Request

  • Request ID: 8467
  • Requested By: Eric Victor
  • Requester E-Mail: ericv@ehs.ufl.edu
  • Code Version: 2017
  • Code: PLUMBING
  • Code Description:
  • Chapter: Chapter 6 Water Supply and Distribution
  • Section: 607.1
  • Topic: Hot or Tempered water in nonresidential occupancies
  • Question: Is it the intent of the last sentence of 607.1, which reads "In nonresidential occupancies, hot water or tempered water shall be supplied for bathing and washing purposes," to require non-public lavatories (lavatories considered private - confined in a classroom) in a public school to have hot or tempered water delivered from them?
  • Comment: A public school has bathrooms within a classroom and the AHJ has agreed that these bathrooms may be deemed as private since they are limited to those students within the classroom. However, the public school is stating they do not have to provide hot or tempered water to the lavatories since they are not public and are using 416.5 as the reason. The AHJ has denied plans based on the last sentence of 607.1 and has interpreted 607.1 to require hot or tempered water be piped to lavatories confined within classrooms. SREF does not specifically exempt bathrooms from this requirement, therefore it is the AHJ's understanding that public schools shall meet this requirement.
  • Attachment 1: Download

Existing Interpretations and/or Declaratory Statements Related to this request

Is it the intention of 607.1 to require hot water for hand washing in public restrooms or for other hand washing sinks for all occupancies?
Is it the intent of the code that all non residential bathrooms have hot water?
Is it the intent of 607.1 to require hot or tempered water for a break room sink 25""x22"" in a business office build-out?

Input Received:

By definition, bathrooms located within public school classrooms are still considered public, not private, by both the plumbing code and the accessibility code. And although Section 607.1, FBC-Plumbing requires hot water (110 F or greater) in residential occupancies, it provides the option of supplying either hot water or tempered water (85 F – 110 F) for bathing and washing purposes (including hand washing) in non-residential occupancies such as schools.

Section 416.5, FBC-Plumbing specifically requires that only tempered water “be delivered from lavatories and group wash fixtures located in public toilet facilities provided for customers, patrons, and visitors.” Tempered water must be delivered by an approved water-temperature limiting device conforming to ASSE 1070. Furthermore, Section 453.16.6, FBC-Building - State Requirements for Educational Facilities (SREF) - also requires a mixing valve be installed at hand-washing lavatories, in order to control the temperature “which shall not exceed 110 F.”

To me the code is clear – the bathrooms in question are considered public, and the hand-washing lavatories must be provided with tempered water through an ASSE 1070 mixing valve.

It should be noted that in the upcoming 7th Edition FBC, Section 419.5 (renumbered) will permit the use of cold water as well as tempered water for public hand-washing facilities. Recent scientific studies, including CDC, have proven that the water temperature for hand-washing has no impact on the removal of bacteria. And further research has shown that the average cold water temperatures in Florida water distribution mains range from approx. 68 F to 75 F, perfectly suitable for hand-washing.

Bottom line, the current code prohibits cold water to public hand-washing lavatories, but the next code will allow it.
I agree with Gary. So can we just say Yes, these locations are considered "public" based on definition.
I agree with Gary as well. I think a Yes answer with Gary's rationale as a comment will be helpful to building officials in their decision-making process.

Answer:

Yes, these locations are considered public based on definition

Commentary:

By definition, bathrooms located within public school classrooms are still considered public, not private, by both the plumbing code and the accessibility code. And although Section 607.1, FBC-Plumbing requires hot water (110 F or greater) in residential occupancies, it provides the option of supplying either hot water or tempered water (85 F – 110 F) for bathing and washing purposes (including hand washing) in non-residential occupancies such as schools. Section 416.5, FBC-Plumbing specifically requires that only tempered water “be delivered from lavatories and group wash fixtures located in public toilet facilities provided for customers, patrons, and visitors.” Tempered water must be delivered by an approved water-temperature limiting device conforming to ASSE 1070. Furthermore, Section 453.16.6, FBC-Building - State Requirements for Educational Facilities (SREF) - also requires a mixing valve be installed at hand-washing lavatories, in order to control the temperature “which shall not exceed 110 F.” It should be noted that in the upcoming 7th Edition FBC, Section 419.5 (renumbered) will permit the use of cold water as well as tempered water for public hand-washing facilities. Recent scientific studies, including CDC, have proven that the water temperature for hand-washing has no impact on the removal of bacteria. And further research has shown that the average cold water temperatures in Florida water distribution mains range from approx. 68 F to 75 F, perfectly suitable for hand-washing. Bottom line, the current code prohibits cold water to public hand-washing lavatories, but the next code will allow it.

Comments on Draft:

I agree with Doug. These lavatories within a classroom are defined as public and not private per the definitions in the Plumbing Code.
Although lengthy, I agree
Looks good the answer is simple and then the comment
Agreed