Update on New Code Change Cycles
The International Code Council (ICC) and the International Association of Plumbing and Mechanical Officials (IAPMO) are currently mid-way through their respective code change cycles. The ICC’s “Group A” codes have concluded their code change process, which include their mechanical, plumbing, fuel gas and residential codes. The ICC energy code change cycle has commenced and proposals were submitted by October 2021. In addition, both the IAPMO Uniform Mechanical Code (UMC) and Uniform Plumbing Code (UPC) have completed their proposal phase and are now into the public comment period. The above code change cycles will result in the publication of the 2024 editions.
The above activity falls under the scope of the ACCA Codes Subcommittee, which takes a proactive role in developing proposed code changes based on member input, plus reviewing other code proposals published for public comment to provide contractor guidance. The Codes Subcommittee is always seeking CONTRACTOR input on changes needed for the above codes. If there are any areas of the codes that you feel need improvement, or “fixing,” please send your ideas or suggestions to ACCA staff at email@example.com. Your suggestions do not have to be in formal code language, just let us know where (and why) the problem or improvement is needed.
Shown below is an update on current code change activities.International Mechanical Code (IMC)
During public comment hearings held in September 2021, the ICC membership considered code change proposals in light of comments received. Shown below are some highlights.
International Energy Conservation Code (IECC)
- Despite ACCA testimony in favor of its modified proposal to add permanent attic stairs for servicing HVAC equipment in new construction, the code officials in attendance voted to reject. The National Association of Home Builders (NAHB) once again voiced opposition. ACCA’s Codes Subcommittee had developed the proposal based on an amendment to the Georgia building code that was effective January 2020.
- Based on comments and testimony from ACCA and other parties, a proposal to require new HVAC systems to be designed to accommodate MERV 13 filters will be located as a new non-mandatory appendix.
- Another proposal to require return air ducts for bathrooms as an option was rejected based on opposition from ACCA and others. ACCA supported this rejection as moist bathroom air should be exhausted and not returned.
- All proposed changes to the mechanical codes covering the use of A2L refrigerants in residential applications were approved. They will be published in the 2024 editions. ACCA joined others in supporting these changes, which were based on applicable UL and ASHRAE standards
For the upcoming ICC energy code change cycle, ACCA has submitted two proposals, as described below.
New IECC Code Development Process
- For Chapter 11, Energy Efficiency, in the 2021 International Residential Code (IRC), a proposed exception to leak testing ducts located inside conditioned space if a duct airflow balancing procedure is conducted, as outlined in ACCA 5 QI, HVAC Quality Installation Specification.
- Also for Chapter 11 in the IRC, the proposed addition of ACCA Manual D, Residential Duct Systems. Currently, ACCA Manual J (load calculations) and Manual S (equipment sizing) are already required by Chapter 11. All three ACCA standards are required for ensuring an energy-efficient HVAC system is designed and installed per the energy codes.
Earlier this year, the ICC Board shifted its energy code development process to a consensus standards committee, based on ANSI procedures. Two new committees were formed, one for commercial and the other for residential. Additionally, working groups have been formed which will review proposed energy code changes and make recommendations to their respective committees. ACCA has applied for membership on the HVAC/Water Heating Working Group of the Residential Energy Code Committee. It is hoped that this new committee process, including its working groups, will provide a better environment for development of logical code requirements. Meetings to review submitted energy code proposals will be held during 2022.IAPMO Uniform Mechanical Code (UMC)
During “virtual” meetings held earlier this year, the UMC Technical Committee considered code change proposals. Promising news from the above meeting includes the approval of proposed revisions to add comprehensive coverage for A2L “mildly flammable” refrigerants for use in home comfort systems. Last year, a special A2L Task Force met many times to develop consensus-based proposals for the coverage. ACCA participated in these meetings to ensure that the interests of our membership were represented to keep contractors and their customers safe. ACCA has voting membership on the UMC TC.Proposals to Eliminate Press-Connect Fittings for Refrigerant Piping
During the above meeting of the UMC TC, proposals were narrowly approved which would eliminate press-connect fittings for refrigerant piping, including piping for A2L refrigerants. The proposals would only allow brazed fittings to be used. Currently, the UMC allows for press-connect fittings for refrigeration if they are tested and certified to UL Standard 207. ACCA and the HVACR industry continue to oppose these changes. Listed press-connect fittings have a proven safety record in the field as installed per manufacturer’s instructions. In addition, there needs to be a viable option if there are situations where brazing is not allowed per local codes.
The TC’s actions on the above proposals are now out for public comment with a due date of January 4, 2022. The TC will meet again in May 2022 to consider public comments and finalize their recommendations.
The UMC is developed by IAPMO using the American National Standards Institute's (ANSI) consensus development procedures. The code is adopted as the California Mechanical Code, and by other states such as Nevada and New Mexico.
Update on 2020 National Electrical Code Requirement for GFCI Protection on Outdoor HVAC Equipment
The Standards Council of the National Fire Protection Association (NFPA) has approved a Tentative Interim Amendment (TIA) which delays the effective date for 210.8(F) in the 2020 National Electrical Code (NEC) until January 1, 2023. The above requirement mandates GFCI protection for outdoor equipment, including HVAC. The delay only applies to variable speed HVAC equipment.
The above TIA was submitted by the Minnesota Department of Labor and Industry, and narrowly focused on variable speed HVAC equipment, instead of all HVAC equipment as with other submitted TIA proposals that have failed NFPA's balloting process over the past year.
In addition, the Council authorized the formation of a task group comprised of GFCI and HVAC manufacturers, as well as other interested parties, “to evaluate and reach an informed technically substantiated resolution to the issues raised.” In response, ACCA Codes Subcommittee Chairman Manny Chaves has appointed Ed Lehr, President, Jack Lehr Heating, Cooling & Electric, Allentown, PA, to represent ACCA on this task group.
Numerous proposals and appeals have been submitted to NFPA to delay the effective date due to the high incidence of nuisance trips in the field. The nuisance trips are due to the electrical incompatibility between currently available GFCI devices and HVAC equipment. Although the above TIA applies only to variable speed compressors, there is evidence of nuisance trips on single speed equipment. This aspect will have to be resolved as well. ACCA has gone on record as supporting all proposed TIAs calling for the delay until a resolution can be found.
The ACCA Codes Subcommittee continues to encourage ACCA members to request their jurisdictions to delete the above requirement if and when they consider adopting the 2020 NEC as their state or local code. The template can be found at the link shown below.
An update on which states have adopted (or are adopting) the 2020 NEC as of October 1, 2021 can be found at the link shown below.
Learn where the National Electrical Code® (NEC®) is enforced. | NFPA
Currently, 14 states have adopted the 2020 NEC as modified by deleting or delaying the above requirement, with 3 more states processing similar amendments. For more information please contact ACCA’s Manager of Codes and Standards at firstname.lastname@example.org.