.Mjc3.Mjc3

Mr. Edward H. Baxter, Regional Administrator Department of Housing & Urban Development Room 645, Peachtree-Seventh Building Atlanta, Georgia 30323 Dear Mr. Baxter: A question ha.s arisen regarding the correct interpretation of Section 114 of Atlanta's Officia l Plumbing Code. Prior to December 20, 1966, Section 114 required the ex clusive use of wiped lead stubs for floor outlet wat er clos ets and urinals. At about that time HUD ma.de a s t udy of t h e Plumbing Code and in the int erest of moderni zation r ecommended that the City amend numerous provisions, i ncluding Secti on 114 . I have b een i n f ormed that t h e revision of Section 114 rec ommended by HUD f ollowed verbatim the corr espon ding provi s ion of the Southern Standard Plumb ing Code . As amend ed , Section 114 reads a s follows : "Sec . 114 . Fixtu re connec tions b etween drainage p ipes and wa ter clos ets, floor- outlet ser vice s i nks , pedestal ur i na ls, and earthenwar e trap standards shall be mad e by means of brass, hardlead or iron f l anges , cal ked , s olde red. or screwed to the drainage pipe. The connection shall be bolted, with an approve d gasket or washer or setting compound between the earthenware and the connection. The floor flange shall be set on an approved firm base. Th e use of commercial putty or plaster is prohibited." Since Section 114 provides that "the floor flange shall be set on an approved firm base", one contention is that the choice of "brass, hard- lead or iron flanges, calked, soldered, �I -2- or screwed to the drainage pipe" applies only to a slab on grade, which constitutes "an approved firm base". Under that theory Section 114 does not permit a choice of the three materials on floors above a slab on grade because such other floors do not necessarily constitute "an a pproved firm base". Under that view of Section 114 it would be permi s sible to restric t such joints on floors above s lab on g rade to wiped lead stubs. The opposing interpretation is that the purp ose of the amendment of Section 114 in December , 1966, wa s t o p ermit t h e choi c e of "bra ss, hard-lead or iron fla nges, ca lked , sol de red, or screwed t o the dra i nage pipe" and tha t the express language of t he Section i s su ch as to permit such choice. Under th'at c ons t ruction t h e phras e "an approved fi rm bas e " applie s equally to all of the mat e r i als and not jus t to t hose other than l ead . The qu estion has, therefore, been raised as to whether, under Section 114, t h e engineer or plumbing contractor is restricted on floors above s l ab on grade to wiped lead stubs or has a choice on such floors of using "brass, hard-lead or iron flanges, calked, soldered or screwed to the drainage pipe". Since HUD was instrumental in bringing about the enactment of Section 114 in its present form, the City would like to know what HUD regards as the correct answer to that question. In addition to the correct interpretation of Section 114, it will be helpful if HUD will express its judg- �-3- ment as to what the code ought to provide on this point, entirely apart from the present language of Section 114, in order to encourage the construction of low-rent, low-cost housing without lowering reasonable standards of safety and durability. Your help on these matters will be very much appreciated. Sincerely yours, �