Division 22 Plumbing
Missing Certification or Compliance Documentation in Division 22 Plumbing submittals
Short answer
A required listing, test report, certification, or compliance document is absent from the submittal package. Default grade in Division 22 Plumbing: Fix and Resubmit.
A required listing, test report, certification, or compliance document is absent from the submittal package. This guide covers how it shows up specifically in Division 22 Plumbing submittals.
What to look for in Division 22 Plumbing
Required certifications in plumbing submittals:
- NSF/ANSI 61 certification (drinking water system components - required for all products contacting potable water)
- NSF/ANSI 372 compliance (lead-free per Federal Safe Drinking Water Act, 2014)
- ASSE standards for backflow preventers and safety devices (1012, 1013, 1015, 1017, 1024, 1047, 1048, 1070)
- ASME certification for water heaters and storage tanks
- UPC (Uniform Plumbing Code) or IPC (International Plumbing Code) compliance
- UL listing for electric water heaters (UL 174 / UL 1453)
- CSA certification for gas water heaters (ANSI Z21.10)
- EPA WaterSense certification for water-efficient fixtures
- IAPMO listing (cUPC mark) for plumbing products
- ADA compliance documentation for accessible fixtures (ANSI A117.1)
- LEED water efficiency documentation (fixture flow rates, WaterSense compliance)
- Seismic certification for water heaters and equipment anchorage (IBC/ASCE 7)
- Buy America compliance (for federally funded projects, ARRA)
- Scald protection certification (ASSE 1016, 1017, 1070 for mixing valves and thermostatic valves)
How severe is it?
Default grade: Fix and Resubmit. Escalates to Blocker when the missing document is a code or life-safety requirement (UL listing, fire rating).
Deviation Check assigns a default per category and escalates or de-escalates based on the spec, always showing its reasoning. See the Division 22 severity rules.
What the PM should do
Stamp the submittal Revise and Resubmit. Mark the deviation, return the relevant spec passage as a redline, and have the sub correct and re-send before fabrication or installation.
Other deviation categories in Division 22
Frequently asked questions
What certifications are most often missing from Division 22 Plumbing submittals for products that contact potable water?
NSF/ANSI 61 certification is required for every product contacting potable water, and NSF/ANSI 372 lead-free compliance is required under the 2014 Federal Safe Drinking Water Act. Both are frequently absent. Gas water heaters must show CSA certification to ANSI Z21.10, and electric water heaters must carry a UL 174 or UL 1453 listing. Backflow preventers must document the applicable ASSE standard - 1012, 1013, 1015, 1017, 1024, 1047, 1048, or 1070 depending on application.
When does a missing certification on a Division 22 Plumbing submittal escalate from Fix and Resubmit to a Blocker?
It escalates when the absent document is a code or life-safety requirement - for example, a missing UL listing on an electric water heater or a missing IAPMO/cUPC listing required by the project's adopted code. ADA compliance documentation under ANSI A117.1 for accessible fixtures and seismic anchorage certification under IBC or ASCE 7 are also escalation triggers. The sub cannot proceed to fabrication or order without those documents in hand.
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