DESIGN: DEAR MR PLUMBER
board with all the support parties, such as
the subcontractors. All of this goes through
a legal process, from the appointment of the
consultants right through the tender process
and the appointment of the contractor with
subcontractors.
THE GREATER HIERARCHY
The abovementioned all forms part of a greater
hierarchy, which is as follows:
1. The government department responsible
for the NBR is the Department of Trade
and Industry (dti).
2. Under the dti are two institutions, namely:
a. The NRCS, responsible for
regulations; and
b. The SABS, responsible for standards.
3. Regulations are compulsory and a “thou
shall” rule.
4. Standards are not compulsory unless it
has been promulgated by the minister as
a regulation.
5. SANS 10400-XA is an example of such a
document that has been promulgated as
compulsory regulation and a “thou shall
comply” rule.
6. The role of the building control officer
(BCO) is to apply the NBR and their
mandate is the NBR only.
7. The BCO is not appointed by the dti but by
the municipality, which is under the authority
of the South African Local Government
Association (SALGA). The fire officers are
also appointed by the local authority.
8. The BCO has the authority to approve
drawings and issue the final CoC for
occupation.
9. Some standards and design codes of
practice have been promulgated under
the authority of the Department of Water
and Sanitation (DWS) and the Water Act,
and were used as model water by-laws
for the municipalities to be adopted and
also used as local water by-laws and
adopted by some private institutions.
10. Local by-laws are the lowest ranking
and ‘trumped’ by all other legal
documentation.
11. The documents that were adopted by the
DWS are: SANS 10252-1 (water), SANS
10252-2 (drainage), and SANS 10254
(geysers).
12. SANS 10252-2 (drainage) overlaps
with SANS 10400-P and is basically
a duplication of SANS 10400-P, but it
13.
14.
15.
16.
17.
a.
b.
c.
33
does contain some additional technical
information to that of SANS 10400-P. Yet,
it becomes problematic during conflicts
in litigation as to which document is the
legal document under the NBR. Strictly
speaking, these documents are not NBR
documents, but it is implied that there is
reference to it in some form.
The local by-laws are under the authority
of the specific municipality that operates
under SALGA — normally under the
municipal engineering department and
not under the BCO. Therefore, the BCO
doesn’t require drawings for the water
systems of buildings, except that they do
require the fire department to inspect the
fire drawings and recommend to the BCO
to approve the design, which the BCO
then signs off.
The local water by-laws state that a set of
water drawings must be kept on site, but
there is no way to submit it to the office
of the BCO and to get approval for it.
The office of the BCO does not carry out
inspections and does not issue a specific
CoC for the water installation. The reason
given is that it is not part of the mandate
of the BCO and not a requirement under
the NBR and NBR Act.
SANS 10252-1 has been used by the
plumbers as their handbook and they
proposed that it become the new Water
Part of SANS 10400.
SANS 10252-1 was originally designed
and written as a design code of practice
and originally published as SABS 0252-1
— Code of Practice. It cannot be used
as is as a regulation since the contents
are not prescriptive, but it does consist
of many choices (assumptions) to be
made, which forms the basis of design —
intelligent engineering design. It does not
contain ‘recipes’ to be used as deem-to-
satisfy rules to comply with a number of
regulations still to be developed.
Therefore, we need:
A number of performance regulations
similar to SANS 10400-P, P1 to P7.
Several deem-to-satisfy rules — a
recipe for compliance to the performance
regulations, which could come from SANS
10252-1, and alternatives.
SANS 10252-1 could be retained as a
code of practice for design with any other
internationally approved design standard.
Continued on page 35 >>
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March 2019 Volume 25 I Number 1