In the last issue of Working Pressure, we outlined where Listing Evaluation Criteria documents (LECs) fit within a manufacturer’s development process for innovation. We also explained the process and the checks and balances involved in developing and releasing an LEC. An LEC is a document akin to a prototype product standard for a product category that has not fully developed. At one point, every backflow assembly and thermostatic mixing valve that we take for granted today was a brand-new engineering marvel. Today, 50 years later, we have similarly innovative products. Rather than making it an uphill battle for inventors to explain to Authorities Having Jurisdictions (AHJs) that their product is safe, an LEC with third-party certification lightens that load. In fact, to make an AHJ’s job easier and to help the manufacturer, one of the considerations during LEC development is applicability with model codes.
LECs generally cover three types of products:
Type 1: A product that spans multiple standards’ scopes and the requirements in the LEC are how to reconcile the differences
Type 2: A product that meets the majority of a standard’s scope with minor or major differences that require alternate or additional testing
Type 3: A product that is new to the market and is not within the scopes of existing standards
How AHJs Can Use LECs with Confidence
It is the responsibility of the AHJ to enforce the requirements of local plumbing code. Paramount is the health and safety for the jurisdiction they serve. When their users want to install new products that do not explicitly meet the letter of the code, certification to an LEC can help minimize the risk taken by both the building owner and the AHJ to meet the spirit of the code.
Let’s take an example. LECs are very similar to IAPMO’s Guide Criteria (IGC). IGC 168 has been available since 2012 and applies to supply stops that have an integral water hammer arrester. The product itself is comprised of two components that on their own would comply to ASSE 1010, Performance Requirements for Water Hammer Arresters, and ASME A112.18.1/CSA B125.1, Plumbing Supply Fittings. This is categorized as a Type 1 LEC, per above. The IGC is not referenced in the Uniform Plumbing Code® (UPC) nor the International Plumbing Code® (IPC). Therefore, when the AHJ sees it installed in the field, they need more information. In order to show traceability, assuming the product was listed by IAPMO R&T:
- It would have a UPC shield signifying compliance with the UPC
- The certificate would show that it is compliant with IGC 168
- The inspector would have to read IGC 168 to see that the two standards referenced meet the requirements of their local plumbing code.
Safely Advancing the State of the Art
The first iteration of anything newly designed requires extensive feedback for the next iteration to be that much better. ASSE is continually seeking your input, even more so with LECs. We expect and want AHJs to scrutinize both the products and the LEC documents to provide feedback and have discourse on how both can be improved. That way there is a check and balance to innovation so that it ensures that the needs of local codes are addressed.
Prior to an LEC being released, there is a public review period where all comments are addressed by the Product Standards Committee. We announce all LEC public reviews through our website at www.asse-plumbing.org/lec and through our Standards Alerts email list. You can sign up for the alerts on our standards page at www.asse-plumbing.org/standards.html.
By being cautiously open to new ideas and products, our plumbing industry can advance while we keep the health of the nation at the forefront.
If you have questions about existing LECs or about how to develop one with ASSE, do not hesitate to reach out at staffengineer@asse-plumbing.org.
