Behind the Scenes: Updating the ISPSC

“The ISPSC [International Swimming Pool and Spa Code] provides a common source for enforceable code language that can be adopted by any state or local authority in the nation. It’s a one-stop shop for safe and correct pool and spa construction and operation,” says Wendy Purser, chair of the Pool & Hot Tub Alliance (PHTA) Code Action Committee (CAC).

The CAC is currently working on one of its most important charges: evaluating change requests submitted by PHTA members and others for needed modifications to the ISPSC, and then creating PHTA proposals to be submitted to the International Code Council (ICC) during the code revision process. ICC is at the beginning of a code revision process for the 2027 I-Codes, the collection of model codes that ICC maintains and publishes and that work together to provide a uniform solution for ensuring safe construction throughout the built environment.

The ISPSC is the product of a PHTA partnership with the ICC. That partnership invests authority for the management of the ISPSC with PHTA and a second code action committee managed by the ICC, the Plumbing, Mechanical, Fuel Gas Code Action Committee (PMGCAC). The PHTA CAC and PMGCAC regularly work together, especially on proposals that have an impact on other codes, such as the International Plumbing Code (IPC), the International Mechanical Code (IMC), or the International Building Code (IBC). That cooperative work helps ensure that there are fewer opportunities for conflict between codes, by considering proposals from different perspectives and giving the different Code Action Committees an opportunity to review new or updated sections that may impact their industry’s codes.

The first edition of the ISPSC was published in 2012 by PHTA (then APSP) and the ICC. An agreement between the two organizations fosters cooperation in the pool and hot tub industry, as reflected by the cobranding of the PHTA standards and the ISPSC. Since then, both groups have continued to develop and update the published 2015, 2018, 2021, and 2024 editions of the ISPSC. ISPSC content was initially drawn from related sections of PHTA American National Standards Institute (ANSI) standards, and the PHTA ANSI standards have since drawn from the latest edition of the ISPSC for revised language and requirements. Since the ISPSC is updated more often than PHTA ANSI standards, it is often the most current, polished, and well-reasoned source for aquatic industry rules.

ISPSC 2027 REVISION CYCLE

In May 2023, PHTA began to solicit public comments for change requests for the 2027 ISPSC. The CAC spent the next five months reviewing, discussing, and ultimately deciding whether those change requests would be submitted by PHTA. Most of the change requests received were approved by the CAC to be included in the PHTA submissions. PHTA communicated with all those who submitted public comments about the status of that change request and the rationale for PHTA’s decision. Those that were not approved for inclusion in the PHTA collection of proposals were informed how they could submit an individual proposal directly to the ICC. PHTA staff were available to assist those who were new to the process, which can be confusing the first time.

In January 2024, the CAC submitted all approved proposals to the ICC for their consideration at the first Code Action Hearing (CAH) in that cycle. All proposals submitted by the deadline were first reviewed by ICC staff to ensure that they contained the information needed for a decision to be made. At the hearing, which took place in April 2024 in Orlando, Fla., a Code Development Committee appointed by the ICC for each code decided the outcome of each proposal: whether it would be approved as submitted, approved as modified, or disapproved. Those that were approved as modified had some form of change to their contents (called floor mods) that could be submitted at the hearing by observers, proposers, and members of the Code Development Committee.

Most of the proposals put forward by PHTA at that first hearing were approved by the Code Development Committee. ISPSC results of CAH #1 can be viewed on the PHTA website, and a full record of all CAH #1 decisions can be found on the ICC website.

In response to the CAH #1 Report, a second round of public comments was opened for the CAH #2, to be held in Long Beach, Calif., in late October 2024. For the PHTA ISPSC proposals that were not approved or for those that needed some other enhancement or clarification to the approved proposal, the CAC deliberated, took decisions, and, working in conjunction with PMGCAC, submitted a handful of public comments for consideration at CAH #2. The results of CAH #2 will be published on the ICC website in early December.

After CAH #2, there will be a final round of public comments and hearings in 2025. Those are conducted by and for government employees, mostly code officials, to provide their final approval of the new I-Code content. It’s a complicated process with a lot of hands-on work, but that is the nature of consensus and deliberative rulemaking. For the I-Codes and the ISPSC, the process is indeed the product.

This article first appeared in the September 2024 issue of AQUA Magazine — the top resource for retailers, builders and service pros in the pool and spa industry. Subscriptions to the print magazine are free to all industry professionals. Click here to subscribe.