Chicago Proposes Interim Plumbing & Mechanical Code Changes

The Chicago Department of Buildings is planning to propose interim mechanical and plumbing changes to the building code, prior to comprehensive rewrites of those sections of the code. When the 2019 Chicago Building Code was adopted, only minor changes were made, with the intention of modifying and adopting changes in 2020 and 2021.

MAPS reviewed the high-level changes to the plumbing and mechanical codes and commented on the likely impacts of each. We believe this suite of changes will have cost savings and allow more efficient designs.

Note: The Alternative Plumbing Materials Pilot Program has been extended to December 31, 2020.

• Align requirements for a minimum number of plumbing fixtures with the International Building Code.
  
  Formulas for determining the minimum number of plumbing fixtures required for different types of buildings and businesses will be updated based on the same model code used to update the Chicago Building Code in 2019, reducing confusion and the need for variances.
  
  

  MAPS response: Chicago had overly stringent requirements for plumbing fixtures which resulted in high plumbing fixture counts. Additionally, there was confusion or conflict between the Chicago Building Code, Illinois Plumbing Code, and the International Building Code. A very common remedy of this was to seek an ACAR for plumbing fixture count by using the state's requirements. This change will likely eliminate the need to obtain that ACAR.
  

• Recognize additional materials and methods for drain pipes based on cost and performance data from a 2-year pilot program.
  
  Several types of plastic drain pipe material will be allowed for use underground and in buildings up to five stories above grade. For larger buildings, with enhanced fire-safety requirements, several additional methods of joining metal drain pipes will be recognized. These changes are expected to provide significant cost savings and equivalent performance based on data from a pilot program run by DOB since late 2017.
  
  MAPS response: This essentially integrates the pilot program into the code so that it doesn't need to keep being renewed. The cost of cast iron for plumbing waste has always been a challenge. Using PVC or CPVC will save building owners a significant amount of money.
  
• Adopt provisions for optional all-gender restrooms.
  
  Single-user toilet room signage requirements will be updated based on recent changes in Illinois law and optional provisions for all-gender restrooms with private toilet stalls and shared sinks, based on best practices recently adopted in Denver and Vancouver, will be incorporated.
  
  

  MAPS response: We wrote about this change to state law in the fall of 2019. Clarifying the requirements of all-gender restrooms and the impact on the total plumbing fixtures count, if any, will be helpful.
  

• Align Requirements for Public Swimming Pools with 2014 Illinois Department of Public Health (IDPH) Regulations.
  
  Provisions that are inconsistent with state swimming pool regulations adopted in 2014 will be eliminated. Provisions for private residential pools (not regulated by the state) will have inconsistent provisions removed.
  
  

  MAPS response: There have always been discrepancies between the Chicago code, Illinois Plumbing Code, and the Illinois Department of Public Health related to the plumbing requirements. It will be helpful to have a common language amongst these codes.
  

• Clarify requirements for water-conserving plumbing fixtures.
  
  Inconsistent water usage requirements for different types of plumbing fixtures will be clarified based on federal regulations and previous legislation that requires new plumbing fixtures to be certified under the EPA’s WaterSense program, where applicable.
  
  

  MAPS comment: Referencing the Environmental Protection Agency's WaterSense program is a good thing to add to the code because it can provide clear directions related to reducing water use.
  

• Update standards for plumbing fixtures, consistent with the latest national standards.
  
  Minimum standards for plumbing fixtures such as faucets, toilets, and showers will be updated to reflect the latest national product safety and performance standards so that newer products are fully recognized without confusion or the need for variances.
  
  

  MAPS comment: Further aligning the Chicago Building Code with national standards is important.
  

• Streamline administration of trade licenses.
  
  DOB will be given full responsibility for licensing and disciplining both plumbing contractors and drain layers. Plumbing contractors will be authorized to perform drain repairs without a separate license.
  
  

  MAPS comment: This will make it less cumbersome for contractors to obtain from one agency instead of separate agencies, so they can get to the project site with less delay.
  

• Align requirements for protecting sewer systems from grease with national standards.
  
  Requirements for pre-treatment of grease-laden waste from commercial food service establishments will be updated to reflect the latest technical standards, allowing businesses to comply using off-the-shelf products. Requirements for catch basins in multifamily residential buildings, which are not based on current science, will be eliminated.
  
• Recognize additional methods for venting based on model plumbing codes.
  
  Designers and builders will be given additional options for configuring plumbing waste and vent systems, which have been shown in a national study to provide significant savings for residential construction and renovation work.
  
  

  MAPS comment: This provides more design flexibility for mechanical engineers to design mechanical systems more efficiently that would be in line with sustainable requirements.
  

• Strengthen and clarify requirements to protect drinking water.
  
  Chicago’s commitment to enforcing lead-free standards in new plumbing will be restated in clearer language while methods allowed for joining copper pipe and connecting faucets and appliances to the building plumbing with short lengths of flexible hose will be clarified.
  
  

  MAPS comment: This will make the code more understandable to designers and tradespeople alike to ensure all on-site methods are compliant.

• Standardize the method of accepting listed and labeled heating, cooling, and ventilation appliances that have been rigorously tested to meet or exceed safety standards.
  
  Listed and labeled heating, cooling, and ventilation appliances that have been manufactured and tested to standards listed in the Mechanical Code will no longer be subject to field inspection or requests for in-field modifications which might void product warranties or result in unsafe conditions.
  
  MAPS comment: Modifying listed and labeled equipment in the field may violate the manufacturer's warranty. This used to be an issue for adding or extending refrigeration venting and extending the outside air intake of rooftop units. It is better, safer, and more robust to keep listed equipment as provided by the manufacturer.
  
• Adopt national standards for the use of energy-efficient condensing clothes dryers for residential applications.
  
  Requirements for through-wall venting have long made it cost-prohibitive to provide in-unit laundry in both new and existing residential buildings, especially affordable housing. By adopting consistent standards for the safe installation of condensing clothes dryers, which do not require an exterior vent, will facilitate this popular feature.
  
  MAPS comment: This should solve the problem of dryer venting in many existing buildings where venting outside can be cost-prohibitive or not possible. In conjunction with the condensing dryers, there should also be clarification about the dryer room exhaust. The code currently requires dryer rooms, where electrical dryers are installed, to be exhausted. If dryer room exhaust is still required, the benefit of using a condensing dryer will be limited.
  
• Update requirements for the exhaust for domestic cooking appliances.
  
  Currently, the Chicago Mechanical Code requires all domestic cooking appliances to be exhausted to the outdoors. Recognizing the increasing popularity of electric and induction-based cooking technologies, and consistent with national model codes, provisions will be added to allow recirculating hoods for electric and induction-type cooking appliances.
  
  

  MAPS comment: Clearly stating that a recirculating hood is acceptable will reduce confusion.
  

• Update the list of recognized refrigerants.
  
  All refrigerant types recognized by the 2021 International Mechanical Code will be recognized, and outdated references to refrigerant types banned by federal law will be removed.
  
  

  MAPS comment: This is a good clarifying change since the Chicago construction codes still list refrigerants that are old and some are not used anymore except for older systems. The newer refrigerants are not listed.
  

• Recognize energy recovery ventilation systems.
  
  Energy recovery ventilation systems allow energy contained in air that is being exhausted from a room or space to be captured and used to precondition incoming ventilation air, which reduces the energy required for heating and cooling. The Mechanical Code will be updated to clearly recognize and allow this important technology.
  
  

  MAPS comment: This supports the Illinois Energy Conservation Code (IECC) 2019 requirements