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Q: Can you explain why natural gas piping is in Division 23 under the new MasterSpec format and not in plumbing Division 22?

This question is the result of a question: if the New York State wicks law addresses natural gas piping as plumbing why do we have it under HVAC Division 23?

A: ARCOM uses CSI/CSC’s MasterFormat to assign numbers and titles to the sections we write. Having said that, I participated on the CSI MasterFormat Expansion Task Team and can convey some of the thinking that went into this decision to include these subjects in Division 23 – HVAC instead of 22 – Plumbing.

In the 1995 Edition of MasterFormat (the 16-division version), plumbing and HVAC were both in Division 15, so it was impossible to determine which trade was responsible. In the expansion of MasterFormat and the development of the 2004 Edition (50-division version), CSI split Division 15 into four divisions, 21 – Fire Suppression, 22 – Plumbing, 23 – HVAC, and 25 – Integrated Automation. During this process, CSI reached out to more than 800 associations, individuals, and government agencies to support decisions. Among those actually participating on CSI’s MasterFormat Expansion Task Team was the Mechanical Contractors of America (MCA). This association had two of its executives working on the task team to represent the interests of mechanical contractors. These two MCA representatives were initially against splitting plumbing and HVAC subject into two divisions, but were eventually won over to this organizational principle. Once this decision was made and agreed to among the task team members and in a national public review, there were several subjects for which it was difficult to decide into which division they should be placed. Fuel distribution systems (specifically natural and LP gas and oil distribution piping) were among those subjects. Even though the task team intentionally and necessarily avoided trade jurisdictions, these issues influenced some of the decisions. Acknowledging trade jurisdictions, in some locales, the plumbing trades claim these fuel distribution systems; in others, mechanical systems pipe fitters claim them. The overwhelming consensus among the task team members and public review comments were to assign these subjects to Division 23 – HVAC. The logic was that most of the equipment connected to these fuel piping systems were HVAC systems, and few plumbing systems connected to them. And, specifying “work results,” these were mainly part of the work results of HVAC systems rather than plumbing systems. So, the decision was taken accordingly.

MasterSpec, in an agreement with CSI, follows MasterFormat numbering and assignment of subject matter.

Realizing that you have a specific problem in dealing with the New York State regulations, and as a practitioner producing project specifications, you have the flexibility to change the Section number to a Division 22 number for those projects required to follow New York State wicks regulations. My recommendation would be to change the numbers to something like Section 221700 – Facility Fuel System, and perhaps, Section 221723 – Facility Natural-Gas Piping, and to parallel the organizational structure in Section 231000 – Facility Fuel Systems.

A word of caution: If you change the Section number, and perhaps the Section title, you need to search other Sections in your project manual that cross-reference this Section (such as gas-fired equipment); then, make the necessary adjustments to those cross-references.

Michael J. King, FCSI, CCS
ARCOM Vice President of
Engineering Specifications

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