Staff Analysis for

Declaratory Statement Request DS-2014-084

7/03/14

Issue: DS-2014-084. The Petitioner, Gary Kozan, seeks a Declaratory Statement on Chapter 5, Section 504.7 of the 2010 Florida Building Code, Plumbing and on Chapter 28, Section 2801.5, of the 2010 Florida Building Code, Residential.

Petitioner in DS-2014-084 seeks clarification of the following questions:

The issue is whether a water heater that is installed in a garage, but at the same elevation as the interior finished floor, is required to have a pan.

Situation:

Gary Kozan, representing Ridgeway Plumbing, Inc., seeks clarification of code requirements regarding pans required for water heaters or hot water storage tanks installed in a garage.

Applicable Codes:

Florida Building Code, Plumbing Chapter 5, Section 504.7 and Florida Building Code, Residential Chapter 28, Section 2801.5.

Background:

Mr. Kozan is a plumbing contractor involved in numerous tract residential projects statewide. He has an upcoming single-family project in Indian River County in which the water heaters are located in the garage, but on the same floor level as the interior of the house.

Relevant Code Sections

2010 Florida Building Code, Building

CHAPTER 2 DEFINITIONS

HABITABLE SPACE. A space in a structure for living, sleeping, eating or cooking. Bathrooms, toilet compartments, closets, halls, screen enclosures, sunroom Categories I, II and III as defined in the AAMA/NPEA/NSA 2100, storage or utility space and similar areas are not considered habitable space.

Florida Building Code, Plumbing Chapter 5

504.7 Required pan.

Where water heaters or hot water storage tanks are installed above the ground floor space, in attics or ceiling areas, or within the habitable space, the tank or water heater shall be installed in a galvanized steel or other metal pan of equal corrosion resistance having a minimum thickness of not less than 0.0236 inch (0.6010 mm) (No. 24 gage), or other pans approved for such use. Electric water heaters shall be installed in a metal pan as herein required or in a high-impact plastic pan of at least 0.0625 inch (1.59 mm) thickness.

Florida Building Code, Residential Chapter 28

P2801.5 Required pan.

Where water heaters or hot water storage tanks are installed above the ground floor space, or in attics or ceiling areas, or within the habitable space, the tank or water heater shall be installed in a galvanized steel or other metal pan of equal corrosion resistance having a minimum thickness of not less than 0.0236 inch (0.6010 mm) (No. 24 gage) or other pans approved for such use. Listed pans shall comply with CSA LC3. Electric water heaters shall be installed in a metal pan as herein required or in a high-impact plastic pan of at least 0.0625 inch (1.59 mm) thickness.

Informal Interpretation

Question:

Question 1: Is it the intent of Section 504.7 of the Florida Building Code, Plumbing not to require a pan for the heater when the heater is installed on the finish floor level of the home in the garage, not the step down section of the garage floor?

Answer:

Yes

Commentary:

A garage is not habitable space and no pan is required even if the heater is installed at the same elevation as the finished floor of the structure.

Staff analysis:

Question:

The issue is whether a water heater that is installed in a garage, but at the same elevation as the interior finished floor, is required to have a pan.

Answer:

No. As per Chapter 2, Definition of “Habitable Space”. A garage is not habitable space and no pan is required even if the heater is installed at the same elevation as the finished floor of the structure.