Box 1, Folder 4, Document 46

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REGION III September 5, 1969



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

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, hard-
lead 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 approved firm base.
The use of commercial putty or plaster is prohibited.

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, which, according to this
interpretation, is the only slab that constitutes "an approved firm base"
insofar as the use of brass or iron flanges 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, calked, 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.


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 possible
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

Sincerely yours,

Ml We. Tirefelerioa

A. Frederick Smith
Assistant Regional Administrator
Program Coordination & Services Office

cc: Mayor Ivan Allen, Jr.

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