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 writers client, an importer of Chinese cast iron pipe, sub-
mitted paperwork intended to support the sellers request for
state approval of the products. The paperwork was intended to
provide evidence of the suppliers 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.
Michigans 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 sellers 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
foundrys 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, manufacturers 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 persons
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