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.August 22, 1969 M r. Edwar d H. Bax t er , Re g ional A dministra tor D epar tment of Hou s ing and Urban D e velopme nt R oom 64 5, P e achtre e - S eventh Building Atlanta , Georg ia 3032 3 Dea r M r. Baxter: A que s tion h a s aris e n r e ga rding th e correct inte rpretation of Section 114 of Atla nta ' a Officia l P l u m b ing Code. Prior to Dec e mber 20 , 19 66, Sectio n 114 requir e d the exclus ive u se of wi p ed l ead s tub s for fl o or o u tl e t wa t e r clo se t s and u r ina ls . A t ab out tha t time HUD mad e a study of the P l umb i n g C ode and i n t he int erest of m oderniz ation r e comme nde d th a t the City anu~nd n umer ous p r ovi tduu l:i , iuduJlng S ec tion. 114 . I ha ve b een informe d that th e revision of Section 114 r e comm e nde d by H UD f o ll ow ed v e rbatin 1 the correspond i ng provi s ion of the S outhe r n Sta ndard Plumbing C ode . As htne n ded , Se ction 114 1·ead s a s foll owa : Sec. 114 . Fixtur e conne cti on s between d ra i nage p ipe s and water closets , F loo r- o u tl et se rvice sinks , p e destal urina l s, and earthenware t rap standard s s h a ll be made by m ean s of brass , hard- l ead o r i ron flanges , c a l ked, s olde1· ed or screwed t o the dra i nage pipe . The c onnec t ion shall be bolted, w i th an appr o ved gaske t or washe r or set tin g compound between the e a rthenware a nd the conne ction. T he use of commercial putty or plaster is prohtbited. Since Section 114 provides that "the floor flange shall be set on an approved firm base", one contention is that the choice of " b1•ass, hard-lead or iron flanges, calked, soldered, or screwed to the drainage pipe" applies only to a slab on grade , which constitutes "an appr o ved firm base". Under that theory Section 114 does not permit a choice of the three materials on iloors abovEl a slab on grade because such other 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. �i Mr. Edward H. Baxter Page 2 .August 22, 1969 The opposing interpreQaa.tion is that the purpose o! the amendn1ent of Section 114 in December, 1966, was to permit the choice of "brass , hard-lead or iron flanges, calked, s oldered, or screwed to the drainage pipe" and that the express language ot. the Section is such as to permit such choice. Under that construc-tion the phrase "an approved firm base applies equally to all of the materia ls and not just to those othe r than lead. The question bas, the1·efore, been raised as to whether, under Section 114 , the engineer or plumbing contractor is restricted on floors above s lab on grade to wiped l ead stub2 or has a choice on such floo rs of using "brass, hard- l ead or iron flanges, c alked·, soldered o r ac1·ewed to the drainage pipe". Since HUD was iustrwnontal in bring a bout the e n actment of Section 114 in its present form, the City w ould like to know what HUD regards as the cor rect answer to that question. In addition to the correct interpretation of Sec tion U4, it will be he lpful if HUD will expcees its judment as to what the code ought to provide on this point,· entirely apart from the present language of Section 114, in order to gnconrage the construction of low- 1·ent, low-cost housillg without lowering reasonable standards 0£ safety and dura bility. Your help on these matters \trill be very rnuch appreciated. Sincerely, Dan E. Sweat, Jr. Chief Administrative Of!icer DESJr:Je �