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Box 1, Folder 4, Document 39
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Mr. Edward H. Baxter, Regional Administrator
Department of Housing & Urban Development
Room 645, Peachtree-Seventh Building
Atlanta, Georgia 30323
Dear Mr. Baxter:
A question has arisen regarding the correct
interpretation of Section 114 of Atlanta's Official Plumbing
Code.
Prior to December 20, 1966, Section 114 re-
quired the exclusive use of wiped lead stubs for floor outlet
water closets and urinals. At about that time HUD made a
study of the Plumbing Code and in the interest of moderniza-
tion recommended that the City amend numerous provisions,
including Section 114.
I have been informed that the revision of Section
114 recommended by HUD followed verbatim the corresponding
provision of the Southern Standard Plumbing Code. As amended,
Section 114 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, 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 an
approved firm base. The use of commercial putty
or plaster is prohibited."
Since Section 114 provides that "the floor flange
shall be set on an approved firm base", one contention is that
the choice of "brass, hard-lead or iron flanges, calked, soldered,
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".
Under that view of Section 114 it would be
permissible to restrict such joints on floors above slab on
grade to wiped lead stubs.
The opposing interpretation is that the purpose
of the amendment of Section 114 in December, 1966, was to
permit the choice of "brass, hard-lead or iron flanges, calked,
soldered, or screwed to the drainage pipe" and that the express
language of the Section is such 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 has, therefore, been raised as to
whether, under Section 114, the engineer or plumbing contractor
is restricted on floors above slab on grade to wiped lead stubs
or has a choice on such floors of using "brass, hard-lead or
iron flanges, calked, soldered or screwed to the drainage pipe".
Since HUD was instrumental in bringing 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 express its judg-
ment as to what the code ought to provide on this point, entirely
apart from the present language of Section 114, in order to
encourage the construction of low-rent, low-cost housing with-
out lowering reasonable standards of safety and durability.
Your help on these matters will be very much
appreciated.
Sincerely yours,
Department of Housing & Urban Development
Room 645, Peachtree-Seventh Building
Atlanta, Georgia 30323
Dear Mr. Baxter:
A question has arisen regarding the correct
interpretation of Section 114 of Atlanta's Official Plumbing
Code.
Prior to December 20, 1966, Section 114 re-
quired the exclusive use of wiped lead stubs for floor outlet
water closets and urinals. At about that time HUD made a
study of the Plumbing Code and in the interest of moderniza-
tion recommended that the City amend numerous provisions,
including Section 114.
I have been informed that the revision of Section
114 recommended by HUD followed verbatim the corresponding
provision of the Southern Standard Plumbing Code. As amended,
Section 114 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, 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 an
approved firm base. The use of commercial putty
or plaster is prohibited."
Since Section 114 provides that "the floor flange
shall be set on an approved firm base", one contention is that
the choice of "brass, hard-lead or iron flanges, calked, soldered,
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".
Under that view of Section 114 it would be
permissible to restrict such joints on floors above slab on
grade to wiped lead stubs.
The opposing interpretation is that the purpose
of the amendment of Section 114 in December, 1966, was to
permit the choice of "brass, hard-lead or iron flanges, calked,
soldered, or screwed to the drainage pipe" and that the express
language of the Section is such 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 has, therefore, been raised as to
whether, under Section 114, the engineer or plumbing contractor
is restricted on floors above slab on grade to wiped lead stubs
or has a choice on such floors of using "brass, hard-lead or
iron flanges, calked, soldered or screwed to the drainage pipe".
Since HUD was instrumental in bringing 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 express its judg-
ment as to what the code ought to provide on this point, entirely
apart from the present language of Section 114, in order to
encourage the construction of low-rent, low-cost housing with-
out lowering reasonable standards of safety and durability.
Your help on these matters will be very much
appreciated.
Sincerely yours,
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