PMI Warns UPC Code Proposal Threatens Private Labeling
The proposals came about over a longstanding code and courtroom battle between the Cast Iron Soil Pipe Institute (CISPI) and Richmond Foundries, a former cast-iron pipe manufacturer and CISPI member. Richmond now imports all of its pipe and fittings from China, which are labeled with the Richmond name, country of origin and plant logo. CISPI is concerned about traceability and accountability with the current system and has sparked code changes to require the name of the Chinese manufacturer as well as the manufacturing plant location to be listed on the product.
CISPI's key proposal for UPC Section 301.1.2 reads: "Each length of pipe fitting, trap, fixture, material and device used in a plumbing system shall have cast, stamped or indelibly marked on it, the maker's mark or name, and the weight and quality of the product, which shall readily identify the maker to the end user of the product when such marking is required by the approved standard that applies. The maker is the manufacturer's name of the foundry, plant, mill or manufacturing location where the product is cast, extruded or manufactured. All materials and devices used or entering into the construction of plumbing and drainage systems, or parts thereof, shall be marked and identified É"
One of PMI's objections is that the wording of the proposed changes applies to all types of plumbing products, not just cast-iron soil pipe and fittings. As such, the practice of private labeling of products would be prohibited.
"This is especially troublesome for manufacturers that private label for other manufacturers or companies, or for hardware chains or home improvement stores," said PMI technical director Dave Viola.
"The proposal also creates great difficulties for manufacturers of plumbing products consisting of multiple components," he added. "In addition to requiring products to be marked with the actual manufacturer's name or mark, the proposed language requires products to be marked with the manufacturing location. It is inappropriate, unnecessary and unrealistic for a product to bear a label with the manufacturing locations of all primary and secondary components.
"Quality control should not be part of any standard or code," he reasoned. "The listing agency is the body responsible for confirming the quality control procedures of the manufacturers who put the listing agency's mark on the product.
"This whole issue is a marketing one and related to cast-iron pipe. We must strive as an industry not to mix marketing issues in with our codes and standards or quality control issues," said Viola.
IAPMO will be holding its 71st Annual Business Meeting and Conference in Anchorage, Alaska, Sept. 3-7. Code hearings will be held during this time, but you must be a registered voting member of the organization to attend. Information on the hearing outcomes will be available in future PM articles and through PMI.