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I • DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT PEACHTREE SEVENTH BUILDING, ATLANTA, GEORGIA 30323 REGION Ill September 5, 1969 IN REPLY REFER TO: 3CW Mr. Dan E. Sweat, Jr. Chief Administrative Officer City of Atlanta City Hall Atlanta, Georgia 30303 Dear Mr. Sweat: This will acknowledge your letter dated August 22, 1969, addressed to Mr. Edward H. Baxter, Regional Administrator, concerning the interpretation of Section 114 of the City of Atlanta's Plumbing Code , which reads as follows: Sec. 114. Fixture connections between drainage pipes and water closets, Floor-outlet service sinks , pedestal urinals, and earthenware trap standards shall be made by means of brass, hardlead _or iron flanges, calked, soldered or screwed to the drainage pipe. The connection shall be bolted, with an approved gasket or washer or s etting compound between the earthenware and the connection. The floor flange shall be set on approved firm base. The use of commercial putty or pl as ter is prohibited. -l Your letter outlines two opposing interpretations of this Section, both of which are centered -around the provision that "the floor flange shall be set on an approved firm base." The first interpretation is that the choice of materials is restricted to a slab on grade, wh ich, according to this interpretation, is the only slab that constitutes "an approved firm base" insofar as the use of brass or iron flang es is concerned . The second interpretation is that the intent of the Section is to permit the choice of materials ("brass, hard-lead or iron flanges, c alked, soldered, or screwed to the drainage pipe") on slab floors above grade. As interpreted by Regional Office codes specialists, the purpose of the Section is to permit the choice of all allowable materials on all floors constructed in accordance with building code standards. They point out that any floor of a building constructed in accordance with building code standards should constitute "an approved firm base" and thus, according to the Section as now written, the choice of all allowable materials should apply to any floor so constructed. --, - . �.·• ,,. J -2 In our judgment, tne intent, purpose, and correct interpreta tion of this Section of Atlanta 1 s Plumbing Code can be clarifie d by amending the code to contain a definition of the term "an approved fi r m bas e . 11 A suggested definition is "any base constructed in accordance with building code specifications." ..--;:- .. ,_.-: -"' 4 The Section is identical to Section 606.1 of the 1967 Edition of the Southern Standard Plumbing Code. It is also identical with Section P-503.0 of the 1968 Edition of the BOCA Basic Plumbing Code with one exception . The BOCA Plumbing Code specified a "struct ura lly firm base" instead of "an approved firm base. 11 The Department encourages the adoption of codes which contain standards comparable to those contained in nationally recognized model standard codes such as the Southern Standa rd and the BOCA codes. Thus Section 114 of the Atlanta Plumbing Code mee ts present Depa rtmenta l st andards a s to content and intent if the section is interpret ed to pe rmit the cho ice of allowable materials on all flo ors constructed to building code specifications. Such an interpretation would also make this Section consistent with a policy of permitting the construction of housing at the lowest possible cost without lowe ring reasonable standards of safety and durability • . .. •·.. We trust tha t our comments on thi s ma t t er will be of s ome benefit in arriving a t an inte r pr e tation that will be s a tisfactory to all parties concerned. Sincere l y yours, . . ;{~ft,_~ ~ ~ ~ tJ ·1 cc: -i Mayor Iva n All en, Jr. ·1 0 . Frede rick Smith Assistant Regional Administra tor Program Coordination & Services Office �