The 2015 IPC Committee Action Hearings - Food Waste Disposer Proposed Changes

April 27, 2015

In case you are wondering why I haven't posted an article in like over a month, allow me to divulge my recent activities so you will understand and perhaps sympathize with how I set my priorities.

Well if not sympathize, perhaps you could at least feel some pity.  If its not asking too much.

Or not.  Hey, I'm not going to beg.

Anyways...
 
The 2015 Group A Committee Action Hearings for the International Building, Existing Building, Residential-Mechanical and Plumbing, Plumbing, Private Sewage Disposal, Mechanical, Fuel Gas, Swimming Pool and Spa, and Property Maintenance and Zoning Codes were held this past week in Memphis Tennessee (April 19 - 28, 2015).

I was privileged to serve on the International Plumbing Code committee during the hearings in which some 280 proposed code changes were heard.

Now, before going to Memphis to sit on the dais for two very long days, each committee member was given copies of all of the proposed code changes.  

While it would have been nice to just read them through on the fly in Memphis, we were informed in advance that we were required to put in just a bit more effort than that. 

They actually wanted us to review all 280ish proposals in advance.  Yeah.  Like actually read them.

That forced me to weigh my priorities because on the one hand I wanted very much to blog about something interesting, even if only to me.

On the other hand I felt obligated to wade through each proposal and the significant amount of supporting documentation that warranted at least a cursory glance if not an outright perusal.  

Feeling overwhelmed, I put all projects on hold and spent around three weeks methodically going through each proposal in the hope that my efforts would be rewarded later.

Rewarded I was.

Thanks to the preparation and hard work of each of the committee members we were able to get through every single proposal in just two days of sitting on the dais.

That's about 16 proposals per hour or less than four minutes per proposal.

That is a fast pace.

By fast, of course, I mean like Speedy Gonzales on Red Bull running downhill being chased by a herd of cats.

That being said, there were two proposals regarding food waste disposers that you might want to be aware of.

P 231-15 (abbreviated here by me to focus on the relevant portions of the proposal)
1003.3.1
Proponent: Julius Ballanco, JB Engineering and Code Consulting, P.C., representing InSinkErator (JBENGINEER@aol.com)
2015 International Plumbing Code

Revise as follows:
1003.3.1 Grease interceptors and automatic grease removal devices required. A grease interceptor or automatic grease removal device shall be required to receive the drainage from fixtures and equipment with greaseladen waste located in food preparation areas, such as in restaurants, hotel kitchens, hospitals, school kitchens, bars, factory cafeterias and clubs. Fixtures and equipment shall include pot sinks, prerinse sinks; soup kettles or similar devices; wok stations; floor drains or sinks into which kettles are drained; automatic hood wash units and dishwashers without prerinse sinks. Commercial food waste disposers shall not be required to discharge to a grease interceptor or to an automatic grease removal device. Grease interceptors and automatic grease removal devices shall
receive waste only from fixtures and equipment that allow fats, oils or grease to be discharged. Where lack of space or other constraints prevent the installation or replacement of a grease interceptor, one or more grease interceptors shall be permitted to be installed on or above the floor and upstream of an existing grease interceptor.

The part above that is underlined was added by the proponent to the original text.

Basically, this proposal simply attempts to eliminate perceived requirements that a food waste disposer should be routed to a grease interceptor.

While this proposal was disapproved, the second proposal dealing with food waste disposal units was not:

P 233-15 

1003.3.2 
Proponent: Julius Ballanco, JB Engineering and Code Consulting, P.C., representing InSinkErator (JBENGINEER@aol.com) 
2015 International Plumbing Code 

Revise as follows: 
1003.3.2 Food waste disposers restriction. WhereA food waste disposers connect to grease interceptors, a solids interceptor shall separate the discharge before connecting to the grease interceptor. Solids interceptors and grease interceptors shall be sized and rated for the discharge of the food waste disposers. Emulsifiers, chemicals, enzymes and bacteriadisposer shall not discharge into the food waste disposer.to a grease interceptor.

This proposal mandates that food waste disposers be routed directly to sanitary and removes any requirements for a solids interceptor between the food waste disposer and either a grease interceptor or the sanitary.

Testimony in support of both proposals centered around three issues:

1. That food waste disposers prematurely fill up grease interceptors with solids that require the interceptor to be maintained more often than would otherwise be necessary.

2. That a solids interceptor capturing the effluent from a food waste disposer prior to it entering a grease interceptor exacerbates FOG deposit formation. 

3. That effluent from food waste disposers does not have a deleterious effect on collection systems.

While I think testimony from supporters of the proposal may have been confusing to committee members, regardless the committee approved the proposal as submitted (in a narrow vote).  

Look, if I have to be honest about it, I don't mind this proposed change.  Food waste does fill up a grease interceptor prematurely.

So why am I bringing this up?  Because I think some of you may care about this issue and may not agree that the effluent from a food waste disposer is "good" for the system, at least not your collection system or POTW anyway.

So what can you do?

Join the Public Comments Process and make your voice be heard.  The Public Comments Process is open to the public (that's you and me) and it's the next step.

You have just as much right to object to a proposal as a proponent does to support it.

To follow the current code development cycle here's the link: http://www.iccsafe.org/current-code-development-cycle/

It was very obvious to me during the hearings that manufacturer's were represented in proposals, owners were represented in proposals, building officials were represented in proposals, even installers were represented in proposals...

The one group that appeared to lack representation in proposals is the pretreatment community. 

But, it's not too late to get involved if you want to have a say regarding proposals that may effect your jurisdiction down the road.


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