Chair, WEF Water Reuse Committee
I’ll start at the beginning of this important issue, which is ultimately about organizations working together to protect public health and sustainable water supplies. Purple is the standard color for pipe adopted by the international utility industry to distribute municipally treated reclaimed water. In late June 2008, a question was raised alerting water reuse professionals to a proposed plumbing code that would require use of purple pipe
for all graywater systems. The proposal was embedded in updates to the 2009 Uniform Plumbing Code under final development by the International Association of Plumbing and Mechanical Officials (IAPMO) and the indication was all reuse organizations had approved it. IAPMO used the Canadian CSA B128 Design and Installation of NonPotable Systems as a guide to coordinate with international standards.Utility members and reuse professionals at the Water Environment Association (WEF), the American Water Works Association (AWWA) and the WateReuse Association (WRA) were not aware of this proposed change, and they responded—along with several state health departments—based on a three-decade history of distributing high-quality reclaimed water through purple pipe and gaining public support for highly treated reclaimed water. Their concerns included:
- Potential cross connections between two purple pipe systems with significantly different quality;
- The public could be exposed to inadequately treated water in a municipal purple pipe system contaminated by an on-site cross connection; and,
- Public exposure and cross connections would negatively impact public confidence in the municipal reclaimed water system.
Based on this feedback, a joint letter signed by Executive Directors of WEF, AWWA, and WRA was submitted to IAPMO on September 24, 2008. I believe this letter represents the first letter endorsed by the three organizations in a common effort to eliminate a public health threat. In a separate action, Florida Department of Health (FDEP) sent a letter protesting the proposed Code.
Discussions at WEFTEC.08 among representatives of IAPMO and all three water groups regarding Code revision revealed that the issue included not only on-site graywater systems but also other sources of alternate water to include rainwater harvested water, stormwater, and air conditioning condensate and showed that other entities unfamiliar with reclaimed water production might influence its use, distribution, and quality.
Based on all of the input they received, IAPMO formed a Task Group to review the proposed code requirements and to develop alternative code requirements acceptable to plumbing code inspectors and municipal utility providers. I was appointed to this committee to represent WEF and WRA, while Alan Rimer, Chair of the AWWA Water Reuse Committee will represent AWWA.
The bottom line is that technical solutions will be developed for consideration by both reclaimed water utility interests and plumbing code enforcement officials. Water utilities and professionals have done a good job of “branding” purple pipe
and educating constituents within the immediate service area about the value of reclaimed water use to the community. It is now apparent that water professionals, utilities, and state health departments must become more involved with local, state and national building code development to ensure that highly treated reclaimed water protects public health and guards against public exposure to inadequately treated alternate waters originating from on-site treatment units. I believe this increased involvement should include:- Improved communications between IAPMO and professionals from the water field by providing technical presentations to educate each other about their respective approaches to public health;
- Improved education within our own house-including utility, health and environmental department professionals so we can recognize well-intended efforts by others that may impact the value of our purple pipe liquid assets;
- Evaluation, by utilities, of state and local regulations that may be in conflict with the Plumbing Codes adopted by the local communities and direct communication with the state entities to provide clear regulations protective of public health without causing regulatory conflict; and,
- Identification of additional common code/public health concerns related to use of non-potable water on property also served with potable water that should be mutually addressed.
The IAPMO Task Group and greater utility awareness are good starts. It is incumbent on all water utility professionals to work toward improved recognition of design controls and regulations that are supportive of public health and sustainable water supply solutions. Meanwhile, I’d invite you to visit www.iapmo.org to learn more about this important code development organization and watch for further developments as we all work together for a cleaner environment.
You might be interested in the experiences of greywater installations in the Netherlands with a name like Van der Tulip I imagine you have some contacts there but google it anyway.
ReplyDeleteBy the way the IAPMO does not develop the International Plumbing Code but the Uniform Plumbing Code (UPC(R)) accuracy on the web should be a prime concenr!
This is great news. Purple should be left to reclaimed water and proactive work must continue to protect against it from being applied to other alternate water sources. I am very pleased to hear that Mr. Vantertulip and Mr. Rimer are working closely with IAPMO.
ReplyDeleteI urge WEF, WateReuse and AWWA to seek representation on the committee that writes the IAPMO UPC. This code is a very important document that shapes the plumbing regulation landscape across the country and beyond.
Thanks for your hard work!
The Water Warrior
Water Warrior,
ReplyDeleteSounds like you've been drinking from the IAPMO Koolaid. It is wise to work with them as they do play a critical role in establishing plumbing regs. Ditto on the need to work with IAPMO committee.
Thanks.
In Canada purple pipe is already used for marking non-potable water of all kinds. You don't brand with color, you identify hazard. What color do you do if you mix snowmelt and reclaimed water or make your own reclaimed water? Not all states even have such a programme.
ReplyDeleteThey guy you need to talk to over at IAPMO is Dave Viola. He is heading up IAPMO's efforts to incorporate up-to-date provisions in the code regarding reclaimed water. Go to their website for his contact info.
ReplyDeleteThanks to our eagle eye reader for noting the error regarding the Uniform Plumbing Code. We have posted the correction accordingly.
ReplyDeleteto Anonymous 12/02 12:04 PM. Dave Viola is the IAPMO official we have been coordination with.
ReplyDeleteI have been following your progress through the code development and appeals process at IAPMO and applaud your efforts to get involved in the code development process.
ReplyDeleteI would ask though, that you please consider sharing your expertise in the International Code Council process as well as we develop the International Plumbing Code and the plumbing provisions for the International Residential Code. Both are more widely adopted in the US than the UPC and we would surely welcome your input and expertise.
Please visit the ICC site to get involved in code development or contact me directly.
Keep up the good work.
Jay Peters
Executive Director
Plumbing, Mechanical and Fuel Gas
International Code Council
The 2009 Uniform Plumbing Code and previous versions specifies in Section 601 that non-potable water shall be labelled with a YELLOW background with black lettering "CAUTION: NON-POTABLE WATER, DO NOT DRINK"
ReplyDeleteNow they want to use purple for all non-potable water??? Then what kind of water is the Yellow one for?
Bill Wilson:
ReplyDeletePosted in 2 parts due to length
Maybe I can offer some other considerations in this discussion. I was an advisor in the Title 22 revision process in the State of California in the early 90's when purple pipe (Pantone 512) was adopted as the embedded labeling method to prevent inadvertent cross-connection with potable water piping.
Recently, this issue has come up more and more as the general public and numerous practitioners in the development of 'alternative' water resources have moved out front of the codes in pursuing implementation of water harvesting, graywater, advanced onsite systems, and decentralized recycled water in an effort to conserve water and reduce the impacts of wastewater disposal.
Some jurisdictions in California have responded to this paradigm shift, which has taken on the characteristics of a real movement and change in society, by requiring use of purple pipe to identify non-potable water, while others, most notably Los Angeles Env. Health's Cross-Connection division, have restricted use of purple pipe to 'municipal disinfected recycled water,' in keeping with the position taken by CDM's Vandertulip.
In response to this, I poled the members of the Title 22 Committee on this issue, and we all remembered that the use of the embedded color was intended to not be restricted to municipal recycled water, but rather to be just that: An embedded non-potable alert to anyone working on a piping or plumbing system. Since most recycled or non-potable water in wide use since the early 90's has been from centralized municipal systems, it seems that a segment of our community of professionals has come to associate use of purple pipe solely with municipal recycled water, but this presents some other problems that need to be addressed if this more restrictive position is to truly be institutionalized.
The advantage of having an embedded pipe color vs using labeling tape is readily apparent to anyone that has ever torn into a wall that was insulated with blown foam, or dug up a pipe to repair a leak or modify an irrigation system using 'alternative' or non-potable or recycled water. You are 'lucky' if you ever come across the labeling tape, which is usually completely destroyed during the excavation. And since this excavation is usually done by labor crews with no general awareness of 'alternative' water systems and who are not trained to look for labels or tape, the chance of a cross-connection is greater with a taped pipe than with an embedded label. With purple pipe, a general alert is possible, and the contractor or crew forman can at least check with the site manager to find out what the water source is and how to proceed.
As some of the other comments on this site indicate, Canada and some other jurisdictions use it already as an embedded non-potable alert, and I know that in California there are pressurized onsite wastewater lines, drip lines using filtered septic tank effluent, rainwater reuse plumbing, graywater systems, non-potable groundwater well irrigation systems, and condensate and cooling tower blow-down systems in place, with permits from the various fragmented regulatory authorities, that use purple pipe. So in some ways this train has left the station already.
Another thing that should be addressed if purple pipe is to be restricted to municipally supplied recycled water is: What do we do about other 'alternative' water resources, in the face of mounting public pressure to conserve water and develop alternative sources? Given the inadequacies of tape labeling, it seems that if we are really concerned about labeling and notification that we need to provide an embedded label. Yellow is somewhat in use for gas, and blue or green is already somewhat in use for potable water, while white PVC or gray Sch 80 is in use in plastic piping, especially in landscape.
Another issue is: What about hybrid systems?
Best wishes,
Bill Wilson
billwilsonwater@gmail.com
BILL WILSON:
ReplyDeleteContinuation of the previous comment post...
When we designed the new LA Crime Lab facility adjacent to LA State University, a 320,000 gallon rainwater harvesting and storage cistern was put in place under the parking lot, with a pump system for providing landscape irrigation. The irrigation piping, including some bubblers, subsurface dripline, and micro irrigation, was installed using purple pipe. Since this combination site is a likely target for future provision of municipal recycled water, we thought that, looking ahead, recycled water could be used in the cistern for make-up water during the long California dry season. Since this was a State project, it crossed jurisdictional lines, with the State taking the broader interpretation of purple pipe and the County Env. Health Dept. taking the more restrictive view.. To resolve the issue, the irrigation pipe was torn out and replaced. But this was hardly a satisfactory outcome (for all concerned), and situations like this will become more common as the public paradigm shifts.
In an award-winning single family home designed to use 1/4 of the water that a normal home uses and to be 'zero-discharge' for stormwater runoff, the hybrid system uses a cistern to irrigate some landscape zones, graywater to irrigate dedicated graywater zones, cistern water to provide make-up water to the graywater system when the owners are on vacation, and, as a last resort, potable water to provide make-up water to the cistern during the dry season. Under LA County regulatory control, the labeling required has been less reliable than an embedded pipe color would have been.
We have become accustomed to 'single pass' potable water in which it is used once and wasted, and this is no longer acceptable. And people are becoming increasingly aware that there are other sources of water to make use of. I have found that the perceived lack of awareness or expectation of pure, potable water from all pipes is the biggest concern of public health regulators that take a restrictive view on this labeling issue, and I also find that the awareness that there are other sources is expanding at a rapid rate. This intersection is a challenging time, and will require a thoughtful response.
So, going forward, I would urge this group from CDM, WEF, WateReuse, et al to not just participate in a 'turf grab,' but to really open up the discussion and try to reconcile the entire issue if you are going to exert pressure on code authorities. I will tell you that in California at least, and I suspect in other places, you will run into a wide-based coalition of stakeholders that will challenge you on the embedded label issue, and there are a number of considerations that need to be addressed.
Yours truly,
Bill Wilson
billwilsonwater@gmail.com