When the Code Doesnt Work:
I am writing to comment on Julius
Ballancos recent column, When the
Code Doesnt Work (Nov. 2007).
Unfortunately, his report does not
include the facts as viewed by this office.
Hopefully, this information will assist
in your readers understanding of the
resulting decision and the reasons sup-
porting that decision.
The Bureau of Construction Codes,
State of Michigan, requested standards
conformance documentation several
years ago for no-hub cast iron soil pipe
used in a project inspected by this office
following a request from a designer
related to state-inspected school projects.
Several suppliers of product manufac-
tured in China who import these mate -
rials provided test reports that were used
in obtaining product listings to support
the acceptance of these products.
The original lab reports used in these
listings for the importers contained seri -
ous discrepancies. Over an extended
time period, the test reports were revised
in order to address errors cited in evalu -
ations to gain the commissions approv-
al. It became evident that the role of
this agency was being misapplied as a
reviewer of the reports in order to iden -
tify errors for corrections.
This agency is responsible for the
evaluation of products and material for
use in the State of Michigan, not as a
third-party evaluator of reports. The
reporting errors resulted in the Michi-
gan State Plumbing Board establishing
acceptance criteria to assure standard
The criteria and standards confor-
mance has not been demonstrated to
date. One of the most basic illustrations
is that two Dimensional Inspection
Reports separated by one year and 10
months are identical in every dimension
to hundredths of an inch from one of
the manufacturers. This was brought to
the attention of all parties and has not
been addressed to the satisfaction of this
office or the State Plumbing Board.
This agency has filed a formal com-
plaint with ANSI to resolve these issues
in an effort to assure consumers have
acceptable products conforming to code-
required standards. Ballancos article
referred to this office being uncomfort -
able with the submitted materials. This
is an unfortunate characterization. It
was demonstrated during the evaluation
that the products do not conform to the
required standards. Unfortunately, this
greater analysis has led to the bureaus
lack of confidence in the conformance
and reporting processes.
The evaluation of this product has
been very time consuming and expensive
for all parties. The agency has relied upon
the professional judgment of appointed
boards and professional staff to evaluate
the submissions and pose the necessary
questions to seek validated information
to support the acceptance of the product.
It would have been a much easier route
to simply accept products rather than
completing the in-depth study, which has
confirmed our position.
Robert G. Konyndyk, Chief
As Seen In
Reprinted with permission from PM Engineer, February 2008 © 2008, BNP Media