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August 22. 1969 Mr. Edward H. Baxter. Regional .Administrator Department of Housing and Urban Development Room 645. Peachtree-Seventh Building Atlanta, Georgia 30323 Dear Mr. Baxter: A question has arisen re gar ding the correct interpretation of Section 114 of Atlanta's Officia l Plumbing Code. Prior to December 20, 1966, Section 114 required the exclusive use of wiped lead stubs for floor outlet water clos e ts and urinals. At about that time HUD m a de a study of t he Plumbing Code and in the interest of modernization recommended that the City am end numerous p r o visions , including S e ctiur"i ll~. I ha ve been informed that the revision of Section 114 recommended by HUD follo wed verbatim th e corresponding provisi on of the Southern Standard Plumbing Code. As Mn.ended, Section 114 reads as follows: Sec. 114 . Fixture connections between drainage pipe s and water clo sets , F loor •- out l et service sinks, pedestal urinals, and ear taenware trap standards s h a ll be made by m eans of bras s, har d-lead or iron flanges , ca lked, soldered o r screwed to the drainage pipe. The connection shall be bolted, with a n approved gaske t o r washer or s etting compound between the earthenware and the conne ction. The use of comme1·cial putty or plaster i s prohibited. Since Section 114 provides that "the floor flange shall be se t on an approved firm base 11 , one contention is that the choice of "braes, hard-lead or iron flanges, calked, soldered. 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 iloors above a slab on grade because such othe1· floors do not necessarily constitute "an approved firm base". Under that view of Section 114 it would be permissible to restrict such joints on floors above slab on grade to wiped lead stubs. �Mr. Edward H. Baxter l?agc 2 Aug ust 2Z, 1969 The opposing interpretation ·1s that the purpose uf the amendment of Section 114 in Decen-iber, 1966, was to permit the choice of "brass, hard-lead or iron flanges , c alked, solder ed, or screwed to the d rainage pipe" and that the expreGs l anguage o! the Se ction is such as to permit such choice. Under that construction the phrase "an approve d firm base" a pplies equally to a ll of the materials and not juat to tho se other th.an l ead. The question has, therefore, been raised as to whether, under Section 114, the engineer o r plumbing contractor i3 restricted on floors above s lab on grade to wiped lead stubs or has a c h oice on such floors of u sing "bra ss, h a rd-lead or iron flan ges , c alked , soldere d or screwed to the drainag e pipe". Since HUD was instrumental in bring a bout the enactment of Section 114 in its present !orm, the City would like to know what H UD regards as the corre ct answer to that question. In addition to the correct interpretati on of Sec tion 114, it will be helpful if HUD will e xp ess its judment as to ;vhat the code ought to pr ovide on tnia pQ.int, entirely apart from the present language of Se ction 114, in order to enconra.ge the cons truction of low-i·ent, low-cost hou iug wi thout lowering reasonable standards 0£ safety and durability. Your help on th~se matters will be very much appreciated. Sincerely, Dan E . Sweat. Jre Chief Administr tive Officer DESJr :je �