When the Code Doesn’t Work: Another Perspective I am writing to comment on Julius Ballanco’s  recent  column, “When  the Code  Doesn’t  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 commission’s 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 conformance. 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.  Ballanco’s  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 bureau’s 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 Plumbing Division Lansing, MI Letters PME Letters As Seen In Reprinted with permission from PM Engineer, February 2008 © 2008, BNP Media AR-PME(208)