Compulsory standards supersede municipal by-laws

2020-02-19T10:52:51+00:00February 19th, 2020|Features|

By Eamonn Ryan

A mistaken belief is that municipal by-laws overrule standards. Wrong: compulsory standards supersede by-laws. There can be adaptation around the soil and water conditions, pressure and such but the standard makes allowance for these.

In discussion with the National Regulator for Compulsory Specifications (NRCS), the Building Control Officer (BCO) and his/her men and women are only responsible for drainage and the sanware connections that dispose of waste – that is, toilets and waste going into the sewer system.

To quote, “The BCO cannot enforce anything not allowed for in the Act, Regulations and the SANS 10400 series. Regulation A13 describes materials as: material used in the erection of a building shall be suitable for the purpose for which it is to be used.” Therefore, the SABS mark is not prescribed within the National Building Regulations & Building Standards (NBR&BS) Act.

Due to there being no requirement in the NBR&BS Act, the regulation of brassware, piping in buildings, geysers, solar and other such plumbing applications does not form part of the BCO/Inspectors jurisdiction nor his role.

The risk in assuming that SANS 10252 and 10254 will be policed due to the fact that they are referenced in SANS 10400 is the reason why there have been repeated requests that such normative references be removed from SANS 10400. This is because, linking the requirements detailed in the SANS 10252 and 10254 in SANS 10400 soothes the industry into a false sense of security that some regulation is being performed.

By normatively attaching such standard also forces the custodian of this Act at Local Government level to have the manpower with the requisite skills to police such. Regulation Part P instructs the BCO “to regulate only drainage and waste removal and the sanware applicable to removal of waste in a building”.

It may be true that industry would be courting disaster should they believe BCOs to be capable of policing all aspects of the plumbing industry nationally. Hence the need for NRCS’s assistance in developing the Plumbing Industry Registration Board’s (PIRB) programme of Certificates of Compliance (COC).

However, plumbers should not be misled that they can install non-compliant products just because the inspectors do not have the power to inspect products like pipes, fittings, taps/mixers and such. There are compulsory standards that exist for each of these and this is where the PIRB comes into play.

The role of IOPSA and the PRB

Herman Strauss of the PIRB explains that the PIRB is the legally registered board through which plumbers can obtain professional status. “One of the responsibilities imposed on the PIRB is to monitor the work done by professionally registered plumbers. At the same time, it has been a legal requirement that all plumbing work needs to comply with the relevant national standards. Leading from both these requirements the PIRB COC and the auditing of these certificates have been born.

“When a registered plumber completes plumbing work, he issues the COC to the client. The COC is his declaration that the plumbing work was done in accordance with the legally mandated standards. After issuing the COC to the client, the plumber needs to log the data of the COC on a national database.

“The PIRB selects at random 5% of the logged COCs and conducts an audit on the installation. The purpose of the audit is to establish if the installation does in fact comply with the legally mandated standards as declared by the plumber. If it is found that some areas of the installation do not comply with these requirements, the plumber is informed and compelled to fix the non-compliances,” says Strauss.

“This system holds plumbers accountable for the work that they do and for the declarations they make through the COC. For the recipient of the COC, this is also beneficial as they can be assured of safe and compliant plumbing work.”

Last year a new product labelling system was launched by IOPSA and PIRB with Strauss as its executive director, SA Watermark. This voluntary register provides plumbers and other trades with a list which verifies a product’s compliance whether at store or prior to purchase by scanning its barcode.

The private sector has – and indeed should – become more involved in certification, which culminated in the establishment of SA Watermark as an alternative avenue of certification based on SANS standards. However, plumbers struggle to differentiate the new certification marks. Today there are any number of testing bodies and accreditation facilities including SAPCS, SABS, IAS, Omega, Bureau Veritas, AENOR, Agrément, SATAS, as well as SA Watermark and JASWIC. Some of these do both testing and certification, including SAPCS, SABS, and AENOR do certification, the others do only testing.

The standards and regulations

SANS 10400 – The National Building Regulations (NBR) Part P Drainage, and Part A – the application of the NBR – every consumer installation must comply with SANS 10252, water supply and drainage for buildings et al, and SANS 10254 – installation, maintenance, replacement and repair of fixed water heating systems, or any other similar…

SANS 10252 consists of two parts: (reference above comment from NRCS)

  • Water supply installations for buildings
  • Drainage installations for buildings

Consumer Protection Act

  • Section 40 – Right to fair and honest dealing – Unconscionable conduct (non-compliance for example)
  • Section 55 – Consumer’s rights to safe, good quality goods. Sub section (d) “Comply with any applicable standards set under the Standards Act, 1993 (Act no 29 of 1993), or any other public regulation”
  • Section 58 – Warning concerning fact and nature of risks

Vollie Brink, a veteran design engineer of 65 years, says: “It seems that so many people still do not understand the institutional hierarchy of the NBR Act, which is so easy to understand, and which are as follows:

  • The NBR Act
  • NBR regulations: there are only a limited number of regulations for each part of the NBR. These regulations are compulsory and the only part that is compulsory. These regulations are in the annexures
  • Deem-to-satisfy rules: these rules are not compulsory, unless the owner decides to follow the deem-to-satisfy rules through the designer
  • SABS standards: these standards are grouped into some deemed-to-satisfy rules and the ‘you shall’ non-negotiable regulations.”

What are the correct standards in terms of vents?

The answer in this case can also be found in SANS10400-P. The following are some important aspects that relate to the DTSR:

  • There must be a 100mm-diameter open vent pipe at the highest, furthest point of the drainage system of a building
  • All branch drains longer than 6m shall have a vent pipe of at least 50mm in diameter. This is a minimum requirement
  • The vent pipes shall rise beyond the roof and above all windows as detailed in SANS10400-P
  • It is very important that a vent valve shall also be situated above the window and above the roof
  • A two-way valve shall not be installed inside a building

Why is the quality of materials important?

The basis of the NBR is health and safety, and quality directly relates to health and safety. It also relates to longevity (lifespan and durability) and it also relates to operation, maintenance and costs.

Inferior quality of materials can be dangerous and require more costly maintenance and may be a health threat. Low-quality piping has caused serious technical problems, costly replacements, and expansive water wastage. The SABS standards for materials and many other international standards are for good quality, safe, and economic installations.

When it comes to the installation and management of drainage, it is crucial to consider not only the obvious health risks, but when using products of a lower quality that do not last, the risk of human contact becomes greater, which leads to greater probability of health issues. This includes the risk of leaks contaminating potable water supply or boreholes, which not only affects a single point but can harm entire communities.

Better quality, or best quality, is important for a long-lasting system. The general lifespan of a commercial building is between 20 and 25 years and the quality of piping, fixtures, and equipment must be able to last for this period. Updated standard development requires piping to last as long as 50 years.

What will happen with newer technology like no-flow or low-flow devices?

These types of fixtures are still not officially approved and therefore will not be specified in SANS10400-P, but it is important for the future of drainage to find solutions for our water shortages, as well as other alternatives.

One solution may be the adaptation and development of systems to use greywater, and low-flow toilets and urinals, which will also significantly alter the design and workings of a drainage system, as additional elements would need to be specified and implemented, such as treatment facilities per property.

What elements does the inspector look at and why does the installation typically fail?

It is both a regulation and a legal requirement that a building inspector must/shall inspect a drain before it is closed and be present when the pipe is pressure tested. Only on the final inspection will he or she issue the COC. The building inspector is supposed to inspect the total installation to ensure it complies with the deem-to-satisfy rules if it is not a rational design. If it is a rational design, then the engineer is responsible for approval.

It is important to note that the building inspector does not inspect the water installation; he or she only has to inspect the hot-water generation and the elements pertaining to SANS10400-XA.

The most common problems are:

  • Incorrect gradients of the discharge pipes and drainpipes
  • Water pipes that fail because of a leak
  • Hot-water systems that are incorrectly designed and incorrectly installed
  • Contractors who appoint unqualified plumbers to do the work and then completely ignore the design drawings, with the result of a hugely and costly failed installation

What elements are involved in the design approvals?

The only design drawings that are relevant or required for approval, are the drawings on the sanitary drainage system. In SANS10400-A, all the information required on the drainage drawings are stipulated. The important elements are:

  • The site plan
  • The building’s floor plan
  • The relevant elevations
  • The relevant sections.

The drainage piping must be indicated on all the floors and sections, the elevations with all the piping and piping elements with pipe sizes must be indicated, and ventilation piping with all the gradients in all the prescribed colours must also be indicated.

The design must only be done by a person who is termed ‘competent’ by having the technical and theoretical qualification, experience, and understanding of all of the elements of a drainage system.

Conclusion

With drainage, if it is done correctly, everything flows as it should, but when done incorrectly, it has a negative impact that results in major health risks.


Q&A: Plumbing compliance

The following is a Q&A with Sascha Altmann (SA), Managing Director: Stiebel Eltron Southern Africa on the subject of plumbing compliance:

From the perspective of Stiebel Eltron, what is the value of compulsory standards and compliance?
SA: We fully agree and are for compulsory standards and compliance. Standard and compliance is a topic which is taken very seriously globally by the Stiebel Eltron group. Product safety and customer satisfaction are core values for us. It is highly recommended, by Stiebel Eltron, that the instantaneous water heaters are installed by qualified tradesmen which follows these standards and compliances.

Please outline your thoughts regarding SANS 1356 Fixed electric instantaneous water heaters.
SA: The applicable standard for instantaneous water heater in accordance to NRCS is SANS/IEC 60335-2-35.

Why is compliance important, especially as regards instantaneous water heaters?
SA: Due to the close proximity of electricity and water it is important that all standards need to be followed, whether it be product or installation orientated.

Please outline the issue of the pros and cons of the use of a pressure release valve on an instantaneous water heater.
SA: Due to the instant water heater having a flow switch it is not required to have a pressure release device if the unit is equipped with another pressure or temperature sensitive safety device. All our instant water heaters are rated to 10Bar of working pressure, it is however required according so SANS that a pressure regulating valve be installed at the premises.

In respect of your portfolio of products, are they certified locally and in what manner?
SA: All our instant water heaters, be it single or 3-phase are tested in accordance to IEC/SANS 60335-2-35 and have LOA’s from the NRCS.