Paschal Engineering & Forensic Consulting, LLC Appeals 2008/1 - 1160-09...7345 Merritt Road • Ypsilanti, MI 48197 • 734-340-4045 Paschal Engineering & Forensic Consulting, LLC

7345 Merritt Road • Ypsilanti, MI 48197 • 734-340-4045

Paschal Engineering & Forensic Consulting, LLC

October 20, 2008 Ms. Gabriella Davis Standards Council Secretary IAPMO 5001 East Philadelphia Street Ontario, CA 91761-2816 Delivered via e-mail only, to: [email protected] Re: UPC ROP Items 85, 94, 102, 203 Dear Ms. Davis, It is my understanding that provided the Technical Committee upholds their previous action on these items, the assembly action taken in Atlanta (1-Oct-2008) will result in an automatic appeal to the Standards Council. The purpose of this letter is to submit documentation in rebuttal to that appeal, and to request that I be allowed to speak on this issue at the Standards Council meeting. I will be representing Aquatherm, GmbH, Attendorn, Germany, for these items. The assembly session voted to reject these proposals, although they had been previously accepted as submitted by the Technical Committee. I am requesting that the Standards Council uphold the Technical Committee action to accept these proposals. The following pages provide supporting documentation for these proposals and this request. In summary:

1) The rationale for rejecting the proposals is that the proposals lacked sufficient substantiation. This was first mentioned at the assembly session in Las Vegas, Sep-2007. At that time, I submitted additional documentation to IAPMO to rebut this action, and was told that because these items were accepted as submitted, I could not send any additional information to the Technical Committee.

2) At the subsequent Technical Committee (TC) meeting in May-2008, I presented the additional rebuttal information verbally and the TC voted to accept these proposals once again.

3) Data for each of the items mentioned in the assembly action motion is enclosed here for review by the Standards Council. This information was verbally provided to the TC, as I was not allowed to provide any further written documentation to the TC.

Thank you. Sincerely, James R. Paschal, P.E. Ph/Fax: 734-340-4045 Mobile: 734-347-7428 [email protected]

UPC Items 85, 94, 102, 203 Page 1 of 14



UPC ROP Items 85, 94, 102, and 203 Polypropylene (PP-R) Pipe for Hot and Cold Water Distribution and Water Service Text shown in Italics is the motion made by the assembly. Text shown in bold underline is the rebuttal to the motion.

• Proposal lacks sufficient substantiation. The proposal is to add ASTM F 2389 to the UPC. A copy of ASTM F 2389 was provided with the proposal. Additionally, this specific manufacturer is listed by IAPMO as complying with ASTM F 2389 as shown in the enclosed listing. Supporting IAPMO and NSF test reports for ASTM F 2389 compliance are also enclosed.

• Mere reference to standard ASTM F 2389 and to listings in other model codes is not sufficient substantiation to list this product in the body of the code. This standard provides all the requirements for PP-R piping used in water distribution and service. Accepting this standard into the code would then require that any products meeting the code must meet the requirements of the standard for long-term strength and pressure rating (100 psi @ 180°F), NSF 61 for potable water, chlorine resistance of 50 years minimum, dimensions, impact resistance, thermal cycling, heat reversion, melt flow, resin density, tensile strength, and the use of virgin materials. The code change is not a request to add a specific manufacturer’s product, but rather to add a specific type of product complying with the requirements of ASTM F2389.

• Lack of data exists regarding use of this product for long-term hot and cold potable water systems. Aquatherm has been manufacturing this product for use in hot-and-cold water distribution for over 25 years. The products are used in more than 70 countries for this application. Additionally, they first received their NSF potable water and pressure piping listing in 1992. Attached are copies of a 1992 test report and 1993 product listing showing compliance.

• Relevant leaching, permeability, life expectancy and durability studies and data were not

provided; therefore no scientific data has been submitted to substantiate proposal. Regarding leaching, the NSF 61 test report is enclosed, which also addresses the next bullet. Regarding permeability, life expectancy, and durability, the ASTM F2389 requires a 50 year stress rating and pressure rating on the pipe and fittings based on testing per ISO 9080. This data is attached in Bodycote Report P-02-124.

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• No data was provided showing conformance with NSF 61 The proposed code change requires the PP-R pipe and fittings to comply with ASTM F2389. This standard, F 2389, requires that the products comply with NSF 61. So, the code change would require that all PP-R products comply with NSF 61. Additionally, the NSF 61 test report (data) and NSF 61 listing are attached showing compliance with NSF 61 for this specific manufacturer’s product line.

• Resistance to degradation from exposure to hot water, chlorine or commonly encountered household substances must be disclosed. The proposed code change requires that the PP-R pipe and fittings comply with ASTM F 2389. This standard, F 2389, requires that the products be tested for chlorine resistance in accordance with ASTM F 2023, and that the products have a minimum 50-year chlorine resistance rating for either traditional domestic water or continuous re-circulation systems. Additionally, data for this specific manufacturer is attached in summary report P-08/45 from Bodycote.

The next pages are only the first pages of each of the documents for sake of brevity. The full documents are given in the appendix. Enc : IAPMO listing

ASTM F 2389 IAPMO/NSF test report 1992 NSF test report 1993 NSF listing NSF 61 test report NSF 61 listing Bodycote P-02-124 report Bodycote P-08/45 summary

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IAPMO Research and Testing, Inc. is a product certification body which tests and inspects samples taken from the supplier's stock or from the market or acombination of both to verify compliance to the requirements of applicable codes and standards. This activity is coupled with periodic surveillance of thesupplier's factory and warehouses as well as the assessment of the supplier's Quality Assurance System. This listing is subject to the conditions set forth inthe characteristics below and is not to be construed as any recommendation, assurance or guarantee by IAPMO Research and Testing, Inc. of the productacceptance by Authorities Having Jurisdiction.

Effective Date: June 2008 -Rev. 9/29/2008- Void After: June 2009

Product: Pressure Rated Polypropylene Piping Systems File No. 5053

Issued To: Aquatherm GmbhBiggen 5D-57439 Attendorn, Germany

IDENTIFICATION: Pipe shall be marked at intervals of not more than 5 ft. with the

manufacturer's name or trademark, nominal size, for metric series pipe -

the term "metric" and the dimension ratio or both the outside diameter

and wall thickness, IPS series pipe shall include "Schedule 80" or "SCH

80", type of material (PP-R) and classification number (80 or 100),

pressure rating and temperature for which pressure rating is valid, the

designation "F2389", manufacturer's production code, and pipe intended

for the transport of potable water shall bear the mark of the lab making

such evaluation. Fittings shall be marked with the manufacturer's name

or trademark, nominal size, dimension ratio or schedule for

corresponding pipe and type of material (PP-R). The fitting or

packaging shall be marked with "Metric" or "NPT" for threaded fittings,

and the designation "F2389". All products shall bear the Classified

IAPMO certification mark.

DOC#081A

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789 Dixboro Road, Ann Arbor, Michigan 48105-9723 USA1-800-NSF-MARK 734-769-8010

www.nsf.org

FI20070511071540 A-00018361

NSF InternationalMay 11, 2007

This report shall not be reproduced, except in its entirety, without the written approval of NSF. This report does not represent NSF

Official NSF Listing, (www.nsf.org). The results relate only to those items tested. Certification or authorization to use the NSF Mark. Authorization to use the NSF Mark is limited to products appearing in the Company's

Page 1 of 9

TEST REPORT

Send To:AQUATHERM GMBHBIGGEN 5

GERMANYD-57439 ATTENDORN

Attn: MR. HOFFER

Thank you for having your product tested by NSF.

The enclosed report details the result of the testing performed on your product. Your program representative will

Reviewer:

be contacting you in the near future if there are any remaining issues concerning the status of this product.

Please do not hesitate to contact us if you have any immediate questions pertaining to your product.

CC:

Clifton Mclellan - Director, Toxicology Services

Status: Pass

Product:

Test Type:

Fusiotherm - 20mm Pipe & 20 mm Fitting

AA - Annual Collection

Plant:Customer:AQUATHERM GMBHBIGGEN 5D-57439 ATTENDORNGERMANY

AQUATHERM GMBHBIGGEN 5D-57439 ATTENDORNGERMANY

Attn: MR. HOFFERAttn: MR. HOFFER

03850

03850 03850

Trade Designation : Fusiotherm

0010 - Plumbing and Related Programs BRANDON RUDOLPH02 - Europe

PA Project: 259688

Program:Program RepRegion:

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03850

Note: Additions shall not be made to this document without prior evaluation and acceptance by NSF International.

NSF International

789 N. Dixboro Road, Ann Arbor, Michigan 48105-9723 USA1-800-NSF-MARK / 734-769-8010

www.nsf.org

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OFFICIAL LISTING

NSF International Certifies that the products appearing on this Listing conform to the requirements of

This is the Official Listing recorded on September 11, 2008.

AQUATHERM GMBHBIGGEN 5D-57439 ATTENDORNGERMANY

Pipe

NSF/ANSI Standard 61 - Drinking Water System Components - Health Effects

49 27 22 950 0

Facility: ATTENDORN, GERMANY

Pipes and Related Products Water Water Contact Contact Trade Designation Size Temp Material

Fusiotherm® - 0610208 20 mm C. HOT PP






























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03850

Note: Additions shall not be made to this document without prior evaluation and acceptance by NSF International.

NSF International

789 N. Dixboro Road, Ann Arbor, Michigan 48105-9723 USA1-800-NSF-MARK / 734-769-8010

www.nsf.org

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Fittings


















Fusiotherm® - 0111109 20/16 mm C. HOT PP

































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1(1) Matter handled by Date Our reference Mattias Svedberg 2008-05-06 P-08/45 Phone +46 155 22 14 56 Your date Your reference Fax +46 155 26 31 25 E-mail [email protected]

Postal address Phone Bank Bank giro account Registered in Bodycote Materials Testing AB +46(0)155 22 14 76 Svenska Handelsbanken 5521-1445 SE-581 13 LINKÖPING SE-61182 NYKÖPING Telefax Box 334 SE-581 03 Linköping Postal giro account Orgnr 556097-0187 SWEDEN +46(0)155 26 31 25 Account 21 71 94-0 E-mail Web 6230 06 652 478 Momsregnr 556097-0187

[email protected] www.bodycotepolymer.com Swiftcode HANSESS Innehar F-skattebevis Vat no SE5560970118701

AQUATHERM GmbH

REF: ADDENDUM TO BODYCOTE REPORT P-07/06

This letter is an addendum to the report BODYCOTE P-07/06, Evaluation of the chlorine resistance according to ASTM F 2023 of the PP-R pipe material Aquatherm Fusiolen). The table below shows calculated lifetimes at different conditions for the evaluated material (Bodycote code 3397) in mentioned report. Testing conducted under report BODYCOTE P-07/06 was in accordance with ASTM F 2023 at a chlorine level of 4 ppm and pH of 6.8. The CL-TD extrapolation assumes 25% of the service life is at 140°F (60°C) and 75% is at 73°F (23°C). The CL-R extrapolation assumes a constant lifetime temperature of 140°F (60°C). EXTRAPOLATED VALUES FOR AQUATHERM FUSIOLEN

CONDITION PRESSURE SDR LIFETIME (CL-TD OR CL-R) PSIG YRS

CL-TD 80 6 285

CL-TD 80 7.3 220

CL-TD 80 11 130

CL-R 80 6 71.8

CL-R 80 7.3 55.3

CL-R 40 11 71.8

CONVERSION TABLE

80 PSIG 5.51 bar 0.551 MPa

40 PSIG 2.75 bar 0.275 MPa

REVIEWED APPROVED Jarno HASSINEN Mattias SVEDBERG BUSINESS DEV MGR OPERATIONS MANAGER

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APPENDIX

FULL VERSIONS OF REFERENCE DOCUMENTS

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Documents

Paschal Engineering & Forensic Consulting, LLC Appeals 2008/1 - 1160-09...7345 Merritt Road • Ypsilanti, MI 48197 • 734-340-4045 Paschal Engineering & Forensic Consulting, LLC