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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 30 323 Dear Mr. Baxter: A question has arisen :reg arding the correct interpretation of Section 114 of Atlanta's Official Plumbing Code. Prior to December 20, 1966, Section 11 4 required the e xclu s ive use of wiped lead s tubs for floor o u tlet water clo se t s and urinals. At about that time HUD m ade a s tudy of the P l umbing Code a nd in the inte r es t of moderni z ation recornmenci e d tha t t he C ity arne nd n umer ous p r uvi ~i on:.1, incluJlng S e ction 114 . 1 ha v e been inform.ed that the revision of Section 114 recommended by HUD follo we d verba t im the co rres ponding provi s ion of the Southern Standard Plumbing Code. As Mn.end e d , S e ction 114 1·eads a s follows: Sec . 114 . Fixtu r e conne ction s between dr a inag e pipes a nd wa te r clo sets , F l oor• outlet service sink s , pedesta l ur i nal s , a nd ea rthenwa r e t rap standa rds s hall b e m a de by m e ans of brass , hard-lea d o r i r on fla n ges , call<:. ed ,- solde r ed or s c rewe d t o the drainage pip e . The c onne c tion shall b e b ol ted , with an approved ga s ke t or wa s he r o r se t ting compou nd between the e a r the n war e and t he conne ction. The use of commercial putty o r p l a s ter is prohibited . Since Section 114 provides that "the fl o or flange shall be set on an approved firm base", one contention is that the choice of "brass, hard-lead or iron flanges, calked, soldered 0 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 approved firm base 11 • Under that view of Section 114 it would b'e permissible to restrict such joints on floors above slab on grade to wiped lead stubs. �I Mr. Edwa1·d H. Baxter Page 2 August 22, 1969 The opposing interpretation is that the purpose of the amendment of Section 114 in Decein'lber, 1966, was t o permit the choice of "brass, hard-lead or iron flanges, calked, soldered, or screwed to the draiuage pipe" and that the express language of the Section is s uch as to permit such choice. Under that construction the phrase "an approved firm base" applies equally to all of the materials and not just to those other than lead. The question bas, thel'e!ore, been raised as to whether, under Section 114, the engineer or plumbing contractor is restricted on floors above s lab on grade to wi ped l ead stubs 01· has a choice on such floor s of u s ing "brass , hard-lea d or iron flanges , calked, soldered or scr e wed to the drainage pipe". Since HUD was instrumental in bring 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 expeess its judment as to what the c ode ought to provide on th.is point, entirely apart from the present l anguage of Section 114 , in o rder to enc or.rage the construction of low-:1.·ent, low-cost housing without lowedng reasonable standards of safety and durability. Your help on these matters will b e very much appreciated. Sincere ly, Dan E . Sweat, Jr. Chief .Administrative Officer DESJr:Je �