Reprinted with permission from Ron George Design & Consulting Services I recently read an article by a well-known plumbing engi- neer and industry code consultant attacking Michigan for not approving Chinese cast iron pipe for use in the state. The writer’s client, an importer of Chinese cast iron pipe, sub- mitted paperwork intended to support the seller’s request for state approval of the products. The paperwork was intended to provide evidence of the supplier’s compliance with the prod- uct standards required by the Michigan Plumbing Code. The seller argued that a third party listing certificate should be suf- ficient   for   acceptance   of   his   products.   Ultimately,   the Michigan Plumbing Board did not agree. Michigan’s product review I   reviewed   copies   of   the   transcripts   of   the   Michigan Plumbing  Board  meeting  and  the  Michigan  Construction Code Commission meeting addressing the requested approval of the seller’s Chinese cast iron pipe, and I reviewed copies of the certified lab reports that were submitted by the seller. This issue boils down to an importer trying to gain acceptance of Chinese pipe with inadequate documentation to prove that it meets the manufacturing requirements for cast iron pipe. The  problem  is  that  an  importer,  wholesaler  or  seller  of imported Chinese pipe might not use just one but dozens of Chinese   foundries.   The   importer   in   the   Michigan   case attempted to present his company as the maker of the pipe, despite the numerous requirements in the standard for on-site testing and quality control that the seller could not possibly have  performed  or  witnessed.  The  importer  submitted  test reports that were supposedly from the foundry in China, but that foundry may or may be the one where the importer might eventually purchase the pipe. If a seller can purchase products from another foundry at a lower price, then the lowest priced material  may  get  shipped,  and  chances  are  that  it  will  not come from the foundry submitting the paperwork. It would be inaccurate for a seller or importer to be listed as the foundry, because   the   importer   has   no   control   over   the   overseas foundry’s testing, manufacturing process or quality control. My experience Over the last few years, I have been a plumbing designer on numerous  major  projects  in  Michigan.  On  more  than  one occasion, after they had already provided submittals for U.S.- made pipe that met the referenced standards in the code, con- tractors  have  asked  whether  I  would  approve  Chinese  cast iron pipe materials. In one case, not wanting to just say no, and in an effort to be fair, I asked for submittals of the Chinese pipe  information  and  received  one  typewritten  page  with  a note saying that the cast iron pipe for the project would be equivalent to the previously submitted U.S. pipe. There was no manufacturer documentation, no warranty information and no installation instructions as required in our specification. I decided to discuss these Chinese materials with a few peo- ple in the industry that I knew had experience working with them. One of them is a close friend who is a master plumber and is now a plumbing inspector in Michigan. He has more than 40 years experience in plumbing and heating. He report- ed  that  he  had  recently  had  the  experience  of  installing Chinese cast iron pipe, and that there was a distinct difference between the Chinese pipe and U.S.-made pipe. He said that when  he  cut  U.S.-made  pipe  from  a  manufacturer  such  as Tyler or Charlotte it would snap off clean, and that, when it snapped off, the pipe would make a distinctive bell ringing sound. When  he  cut  the  Chinese  pipe  it  made  a  crunching sound, and it would often crush or break irregularly and leave jagged ends. Based on the information I had gathered and on the fact that there was no product data, manufacturer’s installation infor- mation, warranty information or proof of product listings, I decided not to approve the Chinese pipe on my projects. Test reports are questioned The Chinese pipe seller submitted production and quality test reports to Michigan, allegedly from one or more of the many foundries in China that produce cast iron pipe for the third-party listing agency to review for their product listing. I was surprised to see that the test reports were in English. I would have expected to see the test reports written in Chinese. (I would be just as surprised if a U.S. manufacturer prepared their reports in Chinese.) There were numerous things that raised my suspicions con- cerning these test reports. The tension test for metallurgical consistency, for example, indicated that the Chinese material always fractured at the exact same fracture or breaking load force on 16 consecutive tests. It is nearly impossible to frac- ture or break 16 different test bars and have the exact same fracture or breaking load on even two occasions. Still another red  flag  was  that  all  16  Chinese  test  bars  were  exactly  the same in diameter, measured to a thousandth of an inch. The  testing  I  have  witnessed  in  the  U.S.  manufacturing facilities  convinced  me  that  it  was  extremely  difficult  to machine a cast iron test bar on a lathe to the exact same diam- eter within a thousandth of an inch sixteen consecutive times. Even  with  a  very  sophisticated  computer-controlled  lathe, there are typically some variations of several thousandths of an inch between samples. Another odd coincidence was that the minimum breaking load recorded on their test report for each test bar diameter was the same number listed in the pub- lished charts for the minimum failure point of the test for each of the sixteen tests. Other aspects of the report raised suspicions as well. The handwriting was all uniform and neatly written with the same ink, and it was in perfect alignment, which is not likely to hap- pen with multiple entries in a log over a long period of time. The interesting thing was that the person who did the testing apparently  never  sleeps.  The  log  listed  the  same  person’s name as conducting the testing around the clock. Other conflicting information in the submittal was that the purchase order paperwork from the importer identified a total Michigan Ruling on Cast Iron Soil Pipe Code Report From Ron George, CIPE, CPD President, Ron George Design & Consulting Services