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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT PEACHTREE SEVENTH BUILDING , ATLANTA, GEORGIA 30323 REGION Ill September 5, 1969 IN REPL Y 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, concerntng 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 setting compound between the earthenware and the connection. The floor flange shall be set on approv~d firm base . The us e of commercial putty or plaster is prohibited . Your let t er out lines two opposing interpr e t ations of this Section, both of which a r e cent e r ed around the pr ovision t hat "the floor flange shall be set on an appr oved fi rm base . " The first int~rpr etat;:. ion is that the choice of materia l s i s r es tric t ed to a slab on gr ade , which , acco r ding t o t hi s interpr e t at ion , i s the on ly slab t hat cons t i tut es "an appr oved f i rm base" i ns ofar as t he us e of br ass or iron flanges is concerned . The second interpretation i s th~t t he intent of t he Sectio~ i s t o permi t the choice of ma teria l s (" br ass , har d- l ead or iron f langes , c a l ked , solder ed , or s crewed to the dr a inage pi pe" ) on slab floo r s above grade . As interpret ed by Reg ional Office codes specia lis t s , the purpos e of the Section i s to permit t he choice of a ll a llowab le mat eria l s on a ll floors constructed in accordance with buil d ing c ode s t andards. They point out that any floor of a building cons tructed in accordance with building code standards should cons titute "an approved firm bas e" and thus, according to the Section as now written, the choice of all allowable materials should apply to any floor so constructed. �-2 In our judgment, the intent, purpose, and correct interpretation of this Section of Atlanta's Plumbing Code can be clarified by amending the code to contain a definition of the term "an approved firm base." A suggested definition is "any base constructed in accordance with building code specifications." 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 "structurally firm base" instead of "an approved firm base." The Department encourages the adoption of codes which contain standards comparable to those contained in nationally recognized model standard codes such as the Southern Standard and the BOCA codes. Thus Section 114 of the Atlanta Plumbing Code meets present Departmental standards as to content and intent if the section is interpreted to permit the choice of allowable materials on all floors 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 posstble cost without lowering reasonable standards of safety and durability. We trust that our comments on this matter will be of some benefit in ·arriving at an interpretation that will be satisfactory to all parties concerned. Sincerely yours, ~ A . Frederick Smith Assistant Regional Administrator Program Coordination & Services Office tJ cc : Mayor Ivan Allen, Jr. �