(Not printed at Government expense) United States of America Congressional Record PROCEEDINGS AND DEBATES OF THE 924 CONGRESS, FIRST SESSION HUD Building Materials Approval Policy IN THE HOUSE OF REPRESENTATIVES Thursday, May 6, 1971 Mr. DINGELL. Mr. Speaker, one of the most vital and least understood areas within our society is that of industrial standards and building codes. It is a field with which I have been long concerned. My Small Business Subcommittee has held numerous hearings concerning standards and codes over the period of the last 5 years. The development, drafting, promulgation, and enforcement of standards have tremendous potential to affect the lives of each of us. Standards, covering as they do virtually any commodity you can name, can be used to protect the consumer, to insure competition, and to provide the uniformity necessary for an industrialized society. Conversely, their misuse can result in anticompetitive conspiracies and an anticonsumer impact in terms of diminished quality and increased price. The same is true in a more specialized sense of building codes. Codes can be used as a means of protectionism-to keep out new products resulting from new technology, as a means of securing increased market shares for existing products, or as a method of insuring that the home buyer gets a fair shake. In its concern to protect the consumer, Congress cannot afford to overlook the biggest consumer protection issue of all: home buying and home repair. The single biggest expenditure the average American makes as a consumer is the purchase of his home. For those who rent their homes, rent may likewise represent a sizable item of consumer expenditure. This is especially true in the case of per 425-841-25342 sons of low and moderate income, for whom monthly rent payments or monthly mortgage payments constitute a sizeable chunk of the family income. Consumer interest in the construction and repair of residential and other buildings has been badly overlooked by Congress and by the Nation. Recently, the National Bureau of Standards has sought an increased budget to develop performance-oriented building codes. This would be done through a cooperative program between the National Conference of States on Building Codes and Standards and the individual States. Spokesmen from the Department of Commerce have indicated that they hope it will produce significant results within 2 years. During fiscal 1972, the conference is expected to establish a procedure for measuring performance of innovative building systems and components. This is most heartening. All standards and codes should be based on performance. What is important to the consumer is what a wall will do-its strength, its durability, its heating and noise insulation quality, and so forth, not what material is used. Mr. Speaker, I am saddened to have to report to you and my colleagues that, despite the admirable objectives of this proposed National Bureau of Standards' program, the lack of internal liaison and coordination within the present administration is destroying whatever gains might have been achieved through this innovative approach. Despite recent pronouncements by HUD Secretary George Romney that more emphasis will be placed on performance criteria for building materials by the Federal Housing Administration, the record to date simply does not corroborate this. Indeed, it points in the opposite direction toward blind obei sance to the old ways-the acceptance of individual materials by name, size, composition, and so forth, rather than on the basis of their performance. Amazingly, during a period when much progress is being made on increased consumer protection, HUD is seemingly fleeing into the miasmic mists of the past. As an example, in a recent letter to a Member of this body, the distinguished gentleman from Indiana, RAY MADDEN, Patricia Hampton, Acting Chief of the Workable Program Branch of the Department of Housing and Urban Development, has stated: To set the record straight, we should like to reiterate that HUD does not require the use of any particular material, does not attempt to judge the merits of such material, does not attempt to judge the credibility of the industry standards under which a particular material is produced, and makes no claim regarding any product or system of construction. (Emphasis supplied). This quotation may be paraphrased rather briefly-let the buyer bewareand if he ends up with his largest single investment represented by a house which is not durable and does not function well, that after all is scarcely the problem of HUD. This is shocking. If the public interest is not the point of HUD's existence, then how do we justify the many billions of dollars expended by that vast bureaucracy. Further, at the very time when the National Bureau of Standards is struggling to obtain adequate funds to protect consumers by converting codes to the vastly more desirable performance basis, HUD representatives are insisting that local codes must allow builders to use any material approved by HUD. It should be noted, however, that HUD does not assume any responsibility to assure that individual building materials meet any 2 performance criterion as to safety or durability. Thus, HUD is now in the process of breaking down consumer protection feaures built into State, county, and municipal building codes-which term includes also regulations pertaining to plumbing, mechanical, and electrical systems, but not housing codes. These codes, while crude and imperfect measures of consumer protection, do embody a very important principle, that is, production is for the sake of consumption and not vice versa; no producer of a building material is entitled to market his commodity simply for the reason that he somehow managed to produce it. To the extent that a code regulates or restricts use of any construction material or method, based upon reliable performance criteria, it constitutes a qualification on the wide open homebuilder practice of "buyer beware." Granted that a given restriction may be unwise, unnecessary, or unsupported by scientific or technological data. This is a question of fact, a question of applying the general principle to particular sets of circumstances. The general principle remains eminently necessary for the protection of the public health, safety, and welfare. The "home buyer beware" approach is unworthy of a Federal Goverment which spends billions of dollars annually in an effort to help those of moderate means acquire their own homes. The aim of public policy at all levels of Government should be to reform building code restrictions, not eliminate them entirely. HUD has embarked upon a policy of forcing or requiring any country or municipality seeking recertification of its "Workable Program for Community Improvement" to throw out all code restrictions even though originally enacted to protect the consumer. The HUD code philosophy has beer spelled out for the record in a letter from Secretary Romney to the distinguished senior Senator from Alabama; said letter can be found in published hearings before a subcommittee of the House Select Committee ou Small Business, held in Chicago, Ill., September 18, 1970, at pages 249-250. I am reliably informed that the same policy has been reaffirmed recently and continues in effect. The policy is precisely stated as follows: Our policy regarding local codes is based on the premise that all materials, irrespective of nature or origin, which have been produced under nationally recognized and accepted industry standards and which have 425-841-25342 CONGRESSIONAL RECORD been certified as having met the require- In the same letter, Secretary Romney HUD does not... have the facilities or budget appropriations necessary to conduct the type of research and testing that has been suggested... We, of necessity, accept the published findings of the National Bureau of Standards, Underwriters Laboratories, the American Society for Testing and Materials and the National Sanitation Foundation, among others. These organizations are equipped and staffed to judge the adequacy of materials and methods and are nationally recognized as experts in their respective fields." HUD makes extensive use of model building and related codes published by some half-dozen organizations which it refers to as "Nationally recognized model code organizations." Examples are: Building Officials and Code Administrators International, Southern Building Code Congress, and International Conference of Building Officials. Secretary Romney in the letter cited above quite correctly points out that these code organizations are, like HUD, dependent upon the findings of the testing organizations and also upon the standards produced by such organizations. One of the problems encountered in attempting to understand standards and codes is their complexity and the fact that they cover many, many thousands of individual commodities. One of the individual commodities that has become somewhat familiar to me through testimony before my Small Business Subcommittee is plastic pipe. Recently, a violent controversy has occurred within the plastics industry concerning a new standard for smaller, thinner-walled polyvinyl chloride-PVC-plastic pipe for drain, waste, and vent usage. The standard has just recently been approved by the American Society for Testing and Materials, one of the organizations relied upon by both HUD and the model code publishers for testing as well as production of standards. The recent case of this ASTM standard, known as D-2949, deserves to be carefully studied by the Congress in both respects. It received its final approval on April 7 of this year, to become effective May 7. During the recent fight to prevent 2 by 4 lumber from which homes are, in the main, framed and built from being made skinnier by virtue of a new standard, one of the arguments advanced against the new standard was that existing pipes will not fit inside a wall built around the new skinnier 2 by 4. Proponents of the new lumber standard solemnly assured us that this was not a valid argument. It is highly disturbing to diseover now, retrospectively, that the plastic industry in its advertising notes that the new skinnier pipes will fit inside the walls and that this is one of their great virtues. Is it not a shame that equal confirmation of this position could not have been received from the industry before the new standard allowing the skinnier 2 by 4's had been adopted? Now that this product, namely, 3-inch thin wall PVC plastic pipe and fittings for drain, waste, and vent application, has been blessed with an ASTM standard specification, it must be accepted as approved in the plumbing code of any community desiring to maintain the certification of its workable program with HUD. The penalty for noncompliance is ineligibility to receive Federal loans and grants sometimes amounting to millions of dollars in a particular community. We are told that ASTM has tested it; ASTM has approved it and granted it a standard; therefore it is ready to be tested in the marketplace, and further restrictions by State or local officials in the interest of consumer protection or environmental protection must be pitched out the window. Of what sort then is this ASTM testing and ASTM standards approval process? In this particular case, there has been some revealing documentation in the public record, including the CONGRESSIONAL RECORD, and we are fortunate to have access to certain documentation circulated within ASTM itself. Within ASTM, we are concerned with six bodies within which a proposed standard is considered and voted upon. From the bottom up, they are: task force, section, subcommittee, committee, society membership, and committee on standards. A standard is typically developed within a technical committee and its subordinate bodies. Following committee approval, it is submitted to the membership of the society by letter ballot. The results, even if unanimous, then go to the committee on standards for final action. D-20 is the committee on plastics. 80-741 O 72-8 D-20.17 is the subcommitee on plastic pipe and fittings. D-20.17.01 is the PVC, polyvinyl chloride section. Finally, there was in this case a task group on 3" thin wall PVC-DWV pipe and fittings. The proposed standard D2949 therefore moved out of the task group through the PVC section to the D-20.17 subcommittee. At this point there was a minority report opposing the standard signed by 19 members of the subcommittee. At the committee level the vote was for approval over several dissents, and so the measure went to membership letter ballot, where there was only one dissenting vote cast by a rival industry group. Prior to the final consideration by the committee on standards, the negative vote was sent back to the task group, subcommittee D-20.17 and full committee D-20 for review. This time, the vote at, these three levels reaffirming the previous action was unanimous in all cases. Following a rebuttal made by the dissenter, the committee on standards voted to approve the proposed standard. Mr. Speaker, I include a sample of this ballot in the RECORD at this point. By way of explanation, D-2949 was identified on the ballot as D-2955 and the number was subsequently changed. The ballot follows: BALLOT REQUEST FORM, SOCIETY BALLOT NO. 1-71 (Use the following code: R=Request copy. A=Affirmative, N=Negative, and Ab¤AD stain. NEW STANDARD Thermal and Cryogenic Insulating Materials (Committee C-16): C 677, Use of a Standard Reference Sheet for the Measurement of the Time-Averaged Vapor Pressure in a Controlled Humidity Space Recommended Practice for. Plastica (Committee D-20) D 2951, Thermal Stress Crack Resistance of Types III and IV Polyethylene Plastica. Method of Test for D 2952, Ethylene Plastics Specifications for. D 2953, Polymeric Materials for Service in Ionizing Radiation. Classification System for. D 2954, Determining Absorbed Gamma and Electron Radiation Dose with the Ferrous Sulfate-Cupric, Sulfate Dosimeter. Procedure for. D 2955, Three Inch Thin Wall PVC Plastic Drain, Waste and Vent Pipe Fittings, Specifi cations for. Electrical Insulating Liquids and Gases (Committee D-27) D 2945, Gas Content of Insulating Oils. Method or Test for. 425-841-25342 CONGRESSIONAL RECORD Peats, Mosses, Humus, and Their Composites (Committee D-29) D 2944 Peat Materials, Methods for Sampling. Space Simulation (Committee E-21), E 422. Measuring Heat Flux Using a Water Cooled Calorimeter, Method for. E 423, Normal Spectral Emittance at Elevated Temperatures of Non-Conducting Specimens. Methods of Test for.- REVISION OF STANDARDS Cement (Committee C-1) C 185-70, Air Content of Hydraulic Cement Mortar, Test for C-219-66, Hydraulic Cement, Definitions of Terms Relating to C 430-70 Fineness of Hydraulic Cement by the No. 325 Sleve, Test for C 505-68, Blended Hydraulic Cements, Specifications for. Building Joint Sealants (Committee C-24), C 542-69, Elastomeric Structural Glazing and Panel Gaskets. Specifications for. Electrical Insulating Materials Liquids and Gases (submitted Jointly by Committees D-9 and D-27). D 2413-69, Preparing and Electrical Testing of Insulating Paper Impregnated with a Liquid Dielectric, Methods for. Electrical Insulating Materials (Committee D-9), D 351-62, Natural Muscovite Mica Based on Visual Quality, Specification for D 748-59, Natural Block Mica and Mica Films Suitable for Use in Fixed Mica-Dielectric Capacitors. Specifications for. D 876-65, Nonrigid Vinyl Chloride Polymer Tubing, Method of Testing D 1080-70, Absorbent Laminating Paper for Electrical Insulation, Speciation for.D 1677-62, Untreated Mica Paper Used for Electrical Insulation, Methods for Sampling and Testing. D 2131-68, Natural Muscovite Mica Splittings. Specification for a D 2413-70, Preparing and Electrical Testing of Insulating Paper Impregnated with Liquid Dielectric, D 2885-70, Calibration of Standards and Equipment, Recommended Practices for. Plastics (Committee D-20), D 1527-69, Acrylonitrile-Butadiene-Styrene (ABS) Plastic Pipe, Schedules 40 and 80, Specification for D 2282-69a, Acrylonite-Butadiene-Styrene (ABS) Plastic Pipe (SDR-PR), Specification for. D 2471-68, Gel Time and Peak Exothermic Temperature of Reacting Thermosetting Plastic Compositions. Method of Test forD 2581-69, Polybutylene Plastics, Specification for. Electrical Insulating Liquids and Gases (Committee D-27), D 2283-70a, Chlorinated Aromatic Hydrocarbons (Askarels), Specification for. D 2472-69, Sulfur Hexafluoride, Specification for. ADOPTION OF TENTATIVE AS STANDARD WITH REVISION Electrical Insulating Liquids and Gases (Committee D-27). D 2300-68T, Gassing of 3 Insulating Oils Under Electrical Stress and Ionization (Modified Pirelli Method), Method of Test for. Statistical Methods (Committee E-11). E 177-61T, Use of the Terms Precision and Accuracy as Applied to Measurement of a Property of a Material. Recommended Prac tice for. ADOPTION OF TENTATIVES AS STANDARDS WITHO"T REVISION Plastics (Committee D-20), D 1501-65T. Exposure of Plastics to Fluorescent Sunlamps, Recommended Practice for D 2873-67T, Oriented Polypropylene Film, Specification for Materials for Electron Devices and Microelectronics (Committee F-1), F 83-67T Thermionic Constants of Electron Emitters, Definition and Determination of REAPPROVAL OF STANDARD Electrical Insulating Materials (Committee D-9), D 352-63, Pasted Mica Used in Electrical Insulating Materials for Testing D 618-67, Conditioning Plastics and Electrical Insulating Materials for Testing, Method of. D 1039-65, Class-Bonded Mica Used as Electrical Insulation Method of TestingD 1082-54, Power Factor and Dielectric Constant of Natural Mics, Test for. D 1829-66, Electrical Resistance of Ceramic Materials at Elevated Temperatures, Test for. Plastics (Committee D-20), D 509-59 (1961), Measuring the Flow Properties of Thermoplastic Molding Materials, Method of. D 756-56 (1966), Resistance of Plastics to Accelerated Service Conditions, Methods of Test for D 757-65. Flammability of Plastics, SelfExtinguishing Type, Method of Test forD 864-52 (1961), Coefficient of Cubical Thermal Expansion of Plastics, Method of Test for. D 1181-56 (1966), Warpage of Sheet Plasties, Method of Test for D 1042-51 (1966), Measuring Changes in Linear Dimensions of Plastics, Method for-D 1204-54 (1966). Measuring Changes in Linear Dimensions of Nonrigid Thermoplastic Sheeting or Film, Method for. D 1239-55 (1966), Resistance of Plastic Films to Extraction by Chemicals, Method of Test for. D 1299-55 (1966), Shrinkage of Molded and Laminated Thermosetting Plastics at Elevated Temperatures, Method of Test for D 1433-58 (1966), Flammability of Flexible Thin Plastic Sheeting. Method of Test forD 1499-64, Operating Light- and WaterExposure Apparatus (Carbon-Arc Type) for Exposure of Plastics, Recommended Practice for. D 1672-66, Exposure of Polymeric Materials to High Energy Radiation, Recommended Practice for. D 1703-62, Presentation of Capillary Flow Data on Molten Thermoplastics, Recommended Practice for. 4 D 1712-85, Resistance of Plastics to Sulfide Staining, Method of Test for. D 2117-64, Melting Point of Semicrystalline Polymers, Method of Test for Electrical Insulating Liquids and Gases (Committee D-27), D 878-65, Inorganic Chlorides and Sulfates in Insulating Oils, Method of Test for. Materials for Electron Devices and Microelectronics (Committee F-1). P 23-64, Temperature Measurement of Thermionic Emitters, Method for. P 113-65, Stiffness Testing of Wire for Electron Devices and Lamps. Method ofP 155-65. Temper of Strip and Sheet Metal for Electron Devices, Method of P 300-64, Interface Impedance Characteristics of Electron Tube Cathodes, Method of. WITHDRAWAL OF STANDARD Electrical Insulating Materials (Committee D-9). D 273-40, Conducting Paths in Electrical Slate. Tests for. D 888-49, Impregnation and Penetration of Glad Yarn with Insulating Varnish, Method for D 1472-62, Set Time for Thermosetting Phenol-Formaldehyde Varnishes, Method of Test for Materials for Electron Devices and Microelectronics (Committee F-1). P 8-64, Electron Tube Materials Using Reference Triodes, Method of TestingP11-68. Electron Tube Parts by Means of a Reference Planar Diode, Method of Testing. Mr. Speaker, now obviously no single individual can know all about-as an example-muscovite mica, splittings, absorbent laminating paper, the temperature measurement of thermetic emitters or phenolformaldehyde varnishes, and so forth, to select but a few. In a speech on the floor of this House on December 17, 1970, my colleague, the gentleman from Alabama (Mr. NICHOLS) alluded to a report on the performance of plastic drainage systems in Europe authored by a certain Rom Rhome, an employee of Uniroyal and former president of the ABS Institute, Inc., a national trade association for the ABS plastic industry. That report was incorporated in Representative NICHOLS' remarks 88 published in the RECORD. It alluded specifically to the proposed ASTM thickness of 3-inch PVC DWV pipe from its present schedule 40 outside diameter 3.50 to 3.25 inches. The summary of findings resulting from Mr. Rhome's investigation follows: INVESTIGATION OF THE PERFORMANCE OF PLASTIC DRAINAGE SYSTEMS IN EUROPE (By Rom Rhome) I. SUMMARY OF FINDINGS 1. In Europe PVC pressure systems were designed with heavy walls and conservatively rated for a life expectancy of fifty years. The 425-841-25342 CONGRESSIONAL RECORD most common dimensional schedule for PVC corresponds to a pressure rating of 10 atmospheres or 147 psl. The wall thicknesses are very close to Schedule 40 PVC drainage pipe in the United States conforming to ASTM D 2665. 2. In determining the design stress for PVC at ambient temperatures of 20° C. (68° P.) proper recognition was given to elevated temperature. On the Continent, both pipe and fittings for pressure service were subJected to 1000 hours of hydrostatic test at a continous temperature of 60° C. (140° F.) before the ambient temperature rating was set. 3. As a result of the proper determination of working stress and allowance for high temperature exposure, PVC pressure systems have steadily displaced conventional materials with a conspicuously successful record of service. 4. Exactly the reverse, however, has been true of PVC drainage piping, which was grossly underdesigned with thin walls to meet the dificult competitive situation prevalling at the time with cast iron, steel, and even asbestos cement (within buildings). 5. With the introduction of automatic dishwashers and washing machines with self-contained water heaters, widespread fallures of PVC drainage systems have occurred. These heat deformation failures occurred in both 3" and 4" soll stacks as well as waste lines 2" and smaller. 6. As a result, PVC has been eliminated entirely from standards in some countries for waste lines as well as 3" soil stacks, with the higher heat resistant plastics, particularly ABS, being used instead. 7. In some countries thinner than Schedule 40 PVC DWV has been retained, but with the restriction that the product be used to handle domestic effluent only. Such service restrictions prolong the use of traditional materials, particularly cast iron, which are thereby required for all commercial installations which could be handled with adequately designed PVC pipe. 8. In the Netherlands, for example, the use of thin wall PVC is continuing, but with the restriction that effluent temperatures not exceed 158° F. This virtually rules out PVC in all modern structures containing automatic appliances. 9. Uniform outside diameter is the most important single achievement in the standardization of plastic pipe. Recommendations of the International Standards Organization have established a single schedule of outside diameters for both pressure and drainage service now in use on four continents. This uniform metric standard for outside diameters parallels the similar standardization in the United States on Iron Pipe Size Outside Diameters. Any effort to introduce nonstandard dimensions, such 88 the 3.250" O.D. proposed for thin wall PVC DWV in the United States, is a serious departure from dimensional standardization. Thus, we have a prominent member of the plastics industry stating that the skinnier walled smaller pipe proposed by the new standard has had a highly unfortunate experience in Europe. This in turn set off additional controversy within the plastics industry. As an example, Mr. R. F. Williams, president of Genova Products of Davison, Mich., one of the largest manufacturers of PVC pipe, in a letter to the editor, published in this year's April issue of Contractor magazine, contradicted Mr. Rhome and then went on to say that while PVC was a reliable product, ABS plastic pipe was not. Europeans refused to use it, he said, since it was a fire hazard. Quoting Mr. R. Edmondson, chairman of the Board of the Hunter Group of Companies, large British plastic DWV manufacturer, Williams says: As you can see, he states in no uncertain terms that the statement "widespread failures" as used in Mr. Rhome's report is totally untrue. He further states that ABS stacks are not used or specified because of fire transmission hazards. This fact is as well known in this country as in Europe. I am sure that we will follow Europe's lead in banning this most flammable plumbing material from all stack uses as soon as more people become aware of the hidden danger already built into many otherwise "fire safe" buildings. The minority report of the 19 dissenting members of subcommittee D-20.17 which considered the standard illustrates how violently the issue was fought by the competing forces within the same branch of the plastic pipe industry. I am inserting in the RECORD at this point the minority report with the names of those who supported it. The minority report makes the point that the wall thickness of so-called thin wall under the new standard will be only 58 percent of that of schedule 40 pipe in the same numerical 3-inch size. The full report follows: MINORITY REPORT ON ASTM D-20 BALLOT OPPOSING 3 INCH THIN-WALL PVC DRAINAGE PIPE AND FITTINGS 1. This standard revives a pipe dimension which a concensus of the industry agreed to abandon eight years ago. Dimensions were detailed in OS 219-59. The O.D. of nominal 3 inch SWP (solvent welded pipe) in CS 21959 was the same as in the proposed specification 1.e. 3.25" O.D. Reasons for abandoning this dimension are as valid now as then. a. The multiplicity of sizes were confusing to the user and expensive to stock for the manufacturer and distributor. b. The Schedule 40 pipe which was based upon the established standards of the steel industry was well known and understood by the piping industry. c. The SWP pipe offered nothing to the .consumer that could not be done better by Schedule 40 pipe. d. Even though SWP pipe with its thinner wall than Schedule 40 sold for less than Schedule 40 it was still abandoned in the interests of quality. 2. We object to the fact that this proposed standard equates a product with only 58% of the wall thickness of the Schedule 40 pipe in the same nominal 3" size. Given the two types of PVC DWV each having ASTM specifications, the lower cost product 18 bound to displace the presently accepted Schedule 40. The financial hardship resulting from the proposed ASTM specification would involve obsolescence of millions of dollars of investment in tooling and Inventories of both Attings and pipe. Since the only competitive advantage of this proposed Thin Wall Pipe is lower cost it will force a revival of a corresponding thin walled ABS pipe as was discussed in Part 1. The flaw of the "product description" concept under which the proposed specification is being advanced can only lead to an indefinite proliferation of dimensional standards with continual thinning of the wall. This must result in product misapplication, eventual failures and a reflection upon the plastics industry as a whole. Too often an ASTM standard is sought for a product that sells at a lower price not in the interests of standardization but as a sales gimmick to be used before less knowledgeable code authorities with the implication the ASTM specification indicates a product that has the blessings of the pipe industry. TO MEMBERS OF ASTM COMMITTEE D-20 The members of ASTM D 20.17 listed below support the position expressed in the attached minority report opposing 3 inch Thin Wall PVC Drainage Pipe & Fittings. Their signatures subscribing to this report have been sent to the secretary of D20.17. Bryce Batzer, Thomas Doyle, Roy Eastman, Paul Finn. William Gallagher, Clifford German, William Hess, John Madden, Robert McAtee, D. L. Moody Jr. Thomas Pillichody, Rom Rhome, Joseph Richerson. Joseph Rourk, Ben Mr. Speaker, other correspondence relating to this matter was published in various issues of Contractor magazine, published semimonthly by Buttenheim Publishing Corp. at Berkshire Common, Pittsfield, Mass. These letters are: first letter from G. R. Munger, executive director, Plastics Pipe Institute of New York, which appeared in the March 15 issue; and second letter of Rom Rhome, identified above, which appeared in the May 1 issue: RIGID TESTS FOR THIN-WALL PVC DEAR SIR: We are writing concerning the information on PVC Thin-Wall DWV at 425-841-25342 CONGRESSIONAL RECORD tributed to Mr. Rom Rhome which appeared in the Feb. 1 issue of CONTRACTOR. PVC Thin-Wall DWV is a relatively new product which has recently been assigned an ASTM standard number, ASTM D2949-71. The granting of such a standard indicates that this product has undergone the same rigid testing procedures and evaluation by producer, consumer and general interest groups which all thermoplastics piping with an ASTM standard must have endured. Also, it has a satisfactory history of usage in DWV applications throughout the country. At present, there are five manufacturing firms producing PVC Thin-Wall DWV and all are reporting satisfactory performance in the field. It is based on the above facts that the Plastics Pipe Institute endorses PVC ThinWall DWV, as it does all thermoplastics piping products with ASTM standards, as an adequate material when installed in accordance, with manufacturers' recommendations and accepted good practice. The failures reported by Mr. Rhome in Europe involved a product which is different from its American counterpart in dimension and basic raw material formulation, It is therefore misleading to imply that, because there have been alleged problems with one, problems are sure to occur with the other. NEW YORK, NY. G. R. MUNGER, Executive Director, Plastics Pipe Institute, MORE ON PLASTIC PIPE REPORT DEAR SIR: Recent issues of Contractor have made reference to my report on the performance of plastic drainage systems in Europe. One article stated that the text of the report was entered in the Congressional Record by Rep. Bill Nichols of Anniston, Ala. The following statements may clarify the nature and purpose of the investigation. 1. The report was a confidential, internal, technical document compiled solely for the guidance of an ASTM committee concerned with the development of standards for plastic pipe. I have been unable to determine how the report reached the hands of Representative Nichols, but any publication of the report was done without my knowledge or consent. 2. While I in no way retreat from the conclusions of the report, the problem is created by the fact that interests hostile to plastic pipe are disseminating the report and quoting it out of context to the detriment of our industry. The same maneuver was used some years ago with a report on plastic drainage systems compiled by the Building Research Advisory Board of the National Academy of Science. 3. The report is really concerned with the philosophy of selecting the proper standards for a product in the light of service experience. In its full text. it is hard to see how this report could benefit the metal pipe industry or in particular the cast iron found 5 ries of Anniston, Ala. Note paragraph 7 of the conclusions: "In some countries thinner than Schedule 40 PVC DWV has been retained, but with the restriction that the product be used to handle domestic effluent only. Such service restrictions prolong the use of traditional materials, particularly cast iron, which are thereby required for all commercial installstlons which could be handled with adequately designed PVC pipe." 4. In other words, our industry's aim is the displacement of metal pipe in drainage service, and the more conservative segment of the PVC pipe industry adheres to the concept that a product with no service restrictions and with consistently successful performance will achieve this objective more rapidly than through the promotion of s limited service product. 5. A competing trade association has made improper use of a confidential document to imply disunity within the plastic pipe industry. Compare this situation to the plight of the metal pipe association which claims that plastic pipe is unserviceable, yet finds eight of its members prominent producers of plastic pipe! 6. The guerilla warfare tactics of our opposition cannot materially delay the eventual day when virtually all new mains under the street, services to the building, and interior drainage plumbing will be PVC, ABS, or other appropriate plastic. ROM RHOME, Products Manager, Uniroyal Chemical. NAUGATUCK, CONN. I am appalled first of all at the statement by Mr. Rhome to the effect that his report-inserted into the CONGRESSIONAL RECORD Was a confidential, internal, technical document, compiled solely for the guidance of an ASTM committee concerned with the development of standards for plastic pipe. Because of the HUD policy mentioned above, an ASTM committee performs a de facto public function, and it is shocking that Mr. Rhome, who benefits from that policy with respect to other products, should entertain the thought that his document is entitled to confidentiality by reason of its having been compiled solely for the guidance of an ASTM committee concerned with the development of standards for plastic pipe. Congressman NICHOLS has performed a magnificent public service by the publication of this confidential internal document right where it very properly should be published, on the pages of the CONGRESSIONAL RECORD. Another troublesome aspect of the ASTM procedure arises from the fact that the 19 dissenters at the subcommittee level and the eight negative votes at the full committee D-20 on plastics level vanished into thin air at the time of the |