# Conflict between sections of the Plumbing Code?



## Too Tired for BS (Jul 23, 2020)

Does the first of these Code sections conflict with the other two?  For context, see below.

Section 606.3:  Access to valves. Access shall be provided to all full-open valves and shutoff valves.

Section 405.6:  Water-tight joints. Joints formed where fixtures come in contact with walls or floors shall be sealed.

Section 421.4.1:  Floor and wall area. Bathtub floors, shower floors, wall areas above built-in tubs that have installed shower heads and walls in shower compartments shall be constructed of smooth, corrosion-resistant and nonabsorbent waterproof materials. Wall materials shall extend to a height of not less than 6 feet (1829 mm) above the room floor level, and not less than 70 inches (1778 mm) above the drain of the tub or shower. Such walls shall form a water-tight joint with each other and with either the tub or shower floor.​
Price Pfister used to manufacture a bathtub/shower rough-in three-handle component -- hot, cold and diverter valves -- that had shutoff valves underneath the hot & cold valves.  *Access to the two shutoff valves could be obtained by rotating the teardrop-shaped hot & cold escutcheons 90 degrees* (which didn't require any tools).  That accessibility presumably satisfied 606.3.  The shutoff valves could be closed or opened using an ordinary flathead screwdriver.

*Recently a plumber sealed the escutcheons to the wall with a silicone sealant, and now the escutcheons can't be rotated to access the shutoff valves*.  The plumbing company says Code required the plumber to seal the escutcheons.  Here's an excerpt of their email:
"Wanted to follow up per our conversation in regards to escustions issue on the tub shower wall being sealed.  Our technician spoke with the manufacturer rep and did confirm that type of escustions that the owner is referring to is no longer in production.  The last manufacturer to have this escustion was Price Fister and discontinued production 5 years ago.  Additionally we have looked into the ICS (International Building Code) section 2511.5 of IBC titled “Wet Areas” has that wet walls and protrusions should be sealed.  Also in the IBC Section 1210.4 it references that tubs are to be sealed to walls (tub wall joints are to be sealed)."​
Here are the two IBC sections cited by the plumbing company:

2511.5:  Wet areas. Showers and public toilet walls shall conform to Sections 1210.2 and 1210.3. When wood frame walls and partitions are covered on the interior with cement plaster or tile of similar material and are subject to water splash, the framing shall be protected with an approved moisture barrier.

1210.2.4:  Waterproof joints. Built-in tubs with showers shall have waterproof joints between the tub and adjacent wall.​
Do any of the above Code sections about seals or water-tight joints apply to the escutcheons in a condo?  If the escutcheons must be sealed, is there a way to seal them that would block water adequately yet still allow them to be rotated? (Perhaps a teflon seal?)  If there's a way to seal the escutcheons that would allow them to be rotated, is that what the plumber needs to do?

I'm also confused about which Code matters for our 8-story condo building in Montgomery County, Maryland.  The county's website mentions the IBC and IRC, and when I google the IRC I get info about the International Plumbing Code.  Is the IBC or the IRC the one that matters for condos, and does the IPC matter for condos too?


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## mtlogcabin (Jul 23, 2020)

The valves are not required under the IPC if there is a unit shutoff valve. So if there is one then seal (silicone) them up and be done with it. 

606.2 Location of shutoff valves.
Shutoff valves shall be installed in the following locations:
1.    On the fixture supply to each plumbing fixture other than bathtubs and showers in one- and two-family residential occupancies, and other than in individual sleeping units that are provided with unit shutoff valves in hotels, motels, boarding houses and similar occupancies.
2.    On the water supply pipe to each sillcock.
3.    On the water supply pipe to each appliance or mechanical equipment.


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## Too Tired for BS (Jul 23, 2020)

mtlogcabin said:


> The valves are not required under the IPC if there is a unit shutoff valve. So if there is one then seal (silicone) them up and be done with it.
> 606.2 Location of shutoff valves.
> Shutoff valves shall be installed in the following locations:
> 1.    On the fixture supply to each plumbing fixture other than bathtubs and showers in one- and two-family residential occupancies, and other than in individual sleeping units that are provided with unit shutoff valves in hotels, motels, boarding houses and similar occupancies.
> ...


​
Thanks, but that doesn't really answer my question.  For an 8-story building like ours, which has over 100 condo units, to me it looks like 606.2(1) requires shutoff valves for each fixture (and they must be accessible).  It's not a 1- or 2-family residential building, nor are there individual sleeping units.

Also, the condo units here do not have a unit shutoff valve. (Valves at the 1st floor shut off all the units in a column, not individual units.)


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## cda (Jul 23, 2020)

New construction 

Most of time there i do not see  an access panel to say the back of shower/ valves


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## mtlogcabin (Jul 23, 2020)

Too Tired for BS said:


> Also, the condo units here do not have a unit shutoff valve. (


Bummer so lets go to the definitions

Section 606.3: Access to valves. Access shall be provided to all full-open valves and shutoff valves.

M] ACCESS (TO). That which enables a fixture, appliance or equipment to be reached by ready access or by a means that first requires the removal or movement of a panel, door or similar obstruction (see “Ready access”).

[M] READY ACCESS. That which enables a fixture, appliance or equipment to be directly reached without requiring the removal or movement of any panel, door or similar obstruction and without the use of a portable ladder, step stool or similar device.

So again you should be able to seal the escutcheons just like the plumber did and be code compliant for access and a water seal requirement. IMHO


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## Too Tired for BS (Jul 23, 2020)

cda said:


> New construction
> 
> Most of time there i do not see an access panel to say the back of shower/ valves



I guess you're saying you don't know.

The Price Pfister shutoff valves are accessed from the front (the bathtub side of the tiled wall) by rotating the hot & cold escutcheons out of the way.  They're not accessed from the back.

Our building is not new construction.  At the back of the linen closet is an access panel that gives some access to the drain pipes and supply pipes of the bathtub, but it doesn't give access to the shutoff valves behind the hot & cold escutcheons.  And the panel doesn't give access to the shower of the other bathroom, which also has Price Pfister shutoff valves behind rotatable hot & cold escutcheons.


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## ADAguy (Jul 23, 2020)

Too Tired for BS said:


> ​
> Thanks, but that doesn't really answer my question.  For an 8-story building like ours, which has over 100 condo units, to me it looks like 606.2(1) requires shutoff valves for each fixture (and they must be accessible).  It's not a 1- or 2-family residential building, nor are there individual sleeping units.
> 
> Also, the condo units here do not have a unit shutoff valve. (Valves at the 1st floor shut off all the units in a column, not individual units.)



Not the best initial design, especially for a condo


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## classicT (Jul 23, 2020)

mtlogcabin said:


> Bummer so lets go to the definitions
> 
> Section 606.3: Access to valves. Access shall be provided to all full-open valves and shutoff valves.
> 
> ...


I agree Mt Log Cabin.

The silicone caulking does not obstruct access to the routine servicing of the valve. Most likely, one can grab the escutcheons with a hand, give it a twist, and the caulking will break loose. Scrape it off, repair the valve, then put it all back together again.

Have had to do this exact sequence in both showers of my home.


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## Too Tired for BS (Jul 24, 2020)

Ty J. said:


> The silicone caulking does not obstruct access to the routine servicing of the valve. Most likely, one can grab the escutcheons with a hand, give it a twist, and the caulking will break loose. Scrape it off, repair the valve, then put it all back together again.



I tried applying force to try to rotate one of the sealed escutcheons by hand but couldn't budge it.  I tried to remove the silicone seal with an exacto knife but couldn't get the point of the knife between the wall and the seal, and I'm sure it would have scratched the tile considerably to try sawing away at the seal.  It seems a lot like epoxy.

In my opinion, the silicone seal is an obstruction that's NOT similar to a door or panel; it's not obvious how to remove it and removal wouldn't be quick.  Also, the "directly reached" phrase in the definition of "ready access" surely implies access that's no more difficult or time-consuming than opening a door or removing a panel.

The definition of access isn't limited to "routine servicing" of the valve.  Access to shutoff valves is also important in emergencies, in particular if one of the hot or cold valves fails.  In a multi-story condo building, it's important for the resident to be able to shut off the water quickly.

Is there an alternative seal or barrier that would be easy to remove in a flooding emergency?


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## cda (Jul 24, 2020)

Too Tired for BS said:


> I tried applying force to try to rotate one of the sealed escutcheons by hand but couldn't budge it.  I tried to remove the silicone seal with an exacto knife but couldn't get the point of the knife between the wall and the seal, and I'm sure it would have scratched the tile considerably to try sawing away at the seal.  It seems a lot like epoxy.
> 
> In my opinion, the silicone seal is an obstruction that's NOT similar to a door or panel; it's not obvious how to remove it and removal wouldn't be quick.  Also, the "directly reached" phrase in the definition of "ready access" surely implies access that's no more difficult or time-consuming than opening a door or removing a panel.
> 
> ...






"""""""it's important for the resident to be able to shut off the water quickly."""""""

Not sure if a resident would know what to do.

Not sure even if ease of access was there, that someone would know there is  shut off behind it.

Loosen them and use regular tub sealant??


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## Too Tired for BS (Jul 24, 2020)

cda said:


> Not sure if a resident would know what to do.
> 
> Not sure even if ease of access was there, that someone would know there is shut off behind it.
> 
> Loosen them and use regular tub sealant??



In this case, I'm the resident. (As for other folks, a bit of education would be needed and should be provided.  It seems to me that an ethical plumber should take a moment to provide that education when s/he notices the shutoff valves or the teardrop-shaped escutcheons.)

Does your suggestion of "regular sealant" (plumber's caulk?) mean you agree that the Code's "access" requirement means seals that obstruct access to shutoff valves need to be reasonably quick and easy to remove?  The plumbing company's position is that they don't need to do anything, as if the access requirement doesn't exist.  They haven't attempted to explain why the access requirement doesn't apply, and they haven't claimed the sealant is reasonably easy to remove.  My position is that they need to replace the silicone sealant with something that's easy to remove.


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## Paul Sweet (Jul 24, 2020)

If they met the code in effect when they were originally installed they shouldn't need to be modified to meet the current code.


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## Too Tired for BS (Jul 24, 2020)

Paul Sweet said:


> If they met the code in effect when they were originally installed they shouldn't need to be modified to meet the current code.



The condo building was constructed in the early 1970s.  As far as I can tell, the shutoff valves were always accessible and the hot & cold escutcheons were never sealed... until the recent plumber's work, which reversed it by sealing the escutcheons and making the shutoff valves inaccessible.  Do you mean the plumber needs to make the shutoff valves accessible again, as they were originally?

Do you know whether the 1970s Code allowed the escutcheons to be unsealed?

I haven't looked at the back sides of the escutcheons.  Perhaps they have built-in barriers that block water from reaching the hole behind them?


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## cda (Jul 24, 2020)

Install a two piece escutcheon  



https://www.homedepot.com/b/Plumbin...r/N-5yc1vZc6aoZ1z0lopv?visualNav=Tub & Shower


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## Too Tired for BS (Jul 24, 2020)

cda said:


> Install a two piece escutcheon



Can you provide more information about how two-piece escutcheons would solve the problem?  Your link to Home Depot displayed many products.  If you meant their "split escutcheon" I don't understand how it would be sealed and provide access to the shutoff valve.

Even if it's a great idea, I would still need to arrange for the plumbing company that sealed the escutcheons to undo their work at no cost, and without scratching the tiles.  In other words, I still seek expert opinions about whether their work violates Code by making the shutoff valves inaccessible.


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## north star (Jul 27, 2020)

*% : % : %*

Too Tired,

Are you sure that the Plumbing Contractor actually used
silicone ?........While most of todays escutcheon plates
are [ typically ] sealed with silicone; for easy removal later,
the plumbers in your application "may" have used whatever
was available on their work truck, ...maybe some
construction adhesive from another job.......IMO, using
E-poxy would take too much time to mix & apply !

The only way to know is to remove the escutcheons yourself
and have the sealant tested \ verified.

Removing them without scratching the tile may be difficult.
I can recommend 2 ways to do this:  *(1)* Using just a single
hacksaw blade and carefully & slowly sawing around the
escutcheons to loosen or cut the adhesive material, or *(2)*
using a Dremel type tool on low rpm's, slowly cut the
escutcheons enough to grab them with pliers and peal them
off.......I believe that either of these two ways can remove
them without damaging the tile.......If the tile is scratched,
try using one of the polishing heads of the Dremel tool to
remove some of the scratching, then apply some good
quality car wax [  i.e. - Meguiar's Carnauba Wax  ] to fill in.
Once removed, then buy two new, solid escutcheons
and a small amount of silicone and reinstall........A silicone
seal [ typically ] can be broken or cut relatively easy.

While this may not satisfy your attempts to hold the plumbing
company accountable, this may assist you in replacing the
escutcheons and moving forward.

Respectfully, ...as I am sure that you are well aware, not
everything is installed to Code or to someone's satisfaction.
We; on this Forum, sincerely try to assist everyone with their
problems, from recommending legal advice or legal action,
to constructing stairs to non-habitable attic areas and
everything in between........We are trying to assist you !

P.S.  Thank you for coming to this Forum with your questions.

*% : % : %*


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