WMTS:040-2019 Round 2 Public Consultation

The issue with the section is that AS 1589 standard is for copper and copper alloy waste fitting. It seems as though the section is trying to make specific reference to Load Test requirements which are stipulated under AS 1589 clause 3.6 and Appendix G, however the wording leaves some ambiguity and requires clarification and specification.

We propose that the wording for clause 9.1 be changed so that compliance is specified to be in reference to the requirements set under AS 1589 Clause 3.6 ‘Load Test Requirements’ and ‘Appendix G’ for all metallic products, whether or not made from copper or copper alloy.

The new specification is very general and can be interpreted in many ways. It does not serve any real purpose.

We purpose that either it is reverted to the Draft 1 decision for the Clause to be “VOID” or, if intended to remain, be clarified as to what parameters are to be met to avoid damage during transportation and handling.

This comment concerns only the phrase "Aluminium shall not be used where intended to be used in direct contact with concrete or cement" (the phrase).

This phrase is instructional for Aluminium material installation and unnecessary. When using this material, the Plumbing Code of Australia 2019 and manufacturer’s instructions should be followed, which would require that the Aluminium components are insulated from contact with the concrete or cement.

We proposed to remove this phrase in its entirety from clause 5.1.2.

This clause only makes mention of plastic and metallic materials, therefore, limits the potential use of any other type of material. This is considered restrictive and a barrier for innovation in the industry. For example, our organisation is presently developing intellectual property and designs for innovative materials which pass all the performance and dimensional tests, but which may not strictly fall within the narrow materials requirement in the specification.

It is still unclear as to how the 2018 specification managed to overlook commonly used materials such as aluminium when the decision was made to limit the allowed materials. In all the years our organisation has supplied aluminium grates, we have never received a verified complaint regarding the product and its suitability for purpose. On the rare occasion an issue has arisen, the issue was caused by incorrect installation.

We repeat our prior submission that the specification should revert to the 2016 specification requirements in respect of ‘Materials’, in which all materials that are able to pass all performance and dimensional testing for their intended use should be eligible for certification. Materials should be ‘VOID’.