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April 28, 2005

Hot Water Temperature: Lobbying or Science?

Mr. John Archer, Secretary
Canadian Commission on Building and Fire Codes (CCBFC)
Institute for Research in Construction
National Research Council of Canada
Ottawa, ON   K1A 0R6

Dear Sir:

We are aware that the Standing Committee on Building and Plumbing Services has recommended lowering settings on hot water heaters to 49 C from the accepted standard of 60 C, with the intent of reducing the risk of scalds. The proposed change was to be incorporated into both the National Plumbing Code (NPC) and the National Building Code (NBC) this year.

Last October the CCFBC withdrew the proposed change and requested the formation of a national task group with broad representation to examine the health and safety risks associated with hot water delivery in buildings. We understand that the proposed change to establish a maximum hot water temperature of 49 C at fixture outlets in residential occupancies generated significant opposition, including objections from some provincial governments and industry. The task group will review the medical knowledge, statistics and circumstances of legionella contamination, as well as information about injuries related to scalding. Its findings, recommendations and proposed course of action will be of great interest.

The fact that the CCBFC withdrew the proposed change in light of pertinent information, medical and otherwise, is to be commended. However, we are alarmed that the proposed change appears to have been in response to emotionally charged lobbying that ignored the strong scientific rationale behind the 60 C requirement. In other words, it looks like the initial recommendation to lower hot water settings to 49 C did not adequately take into account the evidence-based scientific criteria upon which public health and safety policy must be based.

 Is the CCBFC now allowing letter-writing campaigns and similar tactics to compromise the integrity of the Code process? The above example raises concerns that unscientific decisions are going to be made, decisions that could compromise Canadians’ health and safety.

Sincerely,

Emile-J. Therien
President, Canada Safety Council

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