PROBLEM:
Inefficient regulation of plumbing products

The regulatory process for approving plumbing products in the State of Oregon was characterized by unnecessary and duplicative regulation, and excessive complexity in conformity assessment requirements.

SOLUTION:
Statewide plumbing product approval system

The State of Oregon, with the assistance of PMI, American National Standards Institute (ANSI), and the National Institute of Standards and Technology (NIST), developed a uniform statewide product approval system for plumbing products.

DESCRIPTION:
Conformity assessment is a major problem for the majority of the construction industry. The current conformity assessment systems in place are fragmented and uncoordinated within the U.S. as more and more sectored and local conformity assessment programs are being created. This problem is further compounded by the lack of uniformity in conformity assessment from industry sector to industry sector. As our domestic system becomes more costly and cumbersome, the role of product testing and certification has become more important to U.S. international competitiveness. The conformity problems of the plumbing industry are shared by virtually every industry sector.

The program streamlines the product approval process by consolidating that task at the state government level, eliminating the need for local jurisdictions to operate product approval programs in favor of a universally recognized program developed in the private sector. It also alleviates the need for local jurisdictions to dedicate resources to product approval by establishing a structure that recognizes the qualifications of the product testers and certifiers (to national and international criteria). The program can also be used as an educational tool for jurisdictions without a product approval program, and leads to the goal of national and international product approval.

RESULTS:
Cost savings under this program were estimated through a survey of PMI members. Each member was asked to respond to a survey addressing conformity assessment costs associated with gaining code approvals. In general, the survey asked each manufacturer to identify all testing and certification bodies they utilize and calculate the total costs to test and certify products. This included fees paid to various local, state, and federal agencies involved in product approval. The survey also asked each manufacturer to calculate the costs that remain after subtracting the fees paid to agencies performing redundant services. PMI has not conducted a survey of governmental agencies on the cost impacts associated with redirecting resources to other aspects of code enforcement.

SAVINGS:
Any product related costs are generally passed along to the consumer. Therefore, a reduction in such fees should result in saving to the consumer. We have not performed an analysis on the actual impacts of product costs associated with reduced product certification fees.

EVALUATION BY STREAMLINING COMMITTEES:

• Identifies and establishes parameters of plumbing products that can be offered for sale.

• Provides uniform application of plumbing products statewide.

• Approval process with enforcement provisions at state level takes burden off of local official.

• Allows alternate method of approval provision at the local level.

IMPLEMENTATION:
The plumbing product approval program is based on a program currently in use by the State of Oregon. It was developed by the State of Oregon with the assistance of PMI, American National Standards Institute (ANSI), and the National Institute of Standards and Technology (NIST). Development was based upon input from the major plumbing product certification bodies, testing agencies, and accreditation groups through a series of public hearings.

David Viola
Technical Director
Plumbing Manufacturers Institute (PMI)
1234 Remington Road, Suite A
Schaumburg, IL 60173
Phone: (847) 884-9764
FAX: (847) 884-9775
Email: dviola@pmihome.org 

Or NCSBCS Staff:
Carolyn Fitch
Regulatory Specialist
National Conference of States on Building Codes and Standards
505 Huntmar Park Drive, Suite 210
Herndon, VA 20170
Phone: (703) 481-2038
FAX: (703) 481-3596
Email: cfitch@ncsbcs.org
Website: www.ncsbcs.org