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Understanding Cured-in-Place Pipe (CIPP): A Regulatory and Historical Overview

jar546

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Cast- In-Place Pipe (CIPP) lining has revolutionized pipe repair since its invention in 1971 by Eric Wood in London, England. This "trenchless" method offers an efficient way to rehabilitate existing pipelines without extensive excavation. The initial process involved inserting a felt tube impregnated with polyester resin into a leaking pipe, then inflating it to allow the resin to cure and form a new, seamless "pipe" within the old one. Remarkably, a pipe rehabilitated with this initial CIPP process in 1971 is still in use as of January 2025.

However, like any evolving technology, CIPP has been subject to a developing framework of standards, codes, and regulatory requirements to ensure its proper and safe application.

Evolution of CIPP Standards: ASTM and Manufacturer Specifications

The establishment of industry standards has been crucial for CIPP technology.

ASTM F1216 (1989): The American Society for Testing and Materials (ASTM) approved ASTM F1216 as the standard for "Standard Practice Rehabilitation of Existing Pipelines and Conduits by the Inversion and Curing of a Resin-Impregnated Tube". This standard mandated "continuous" material installation, producing "dimples" at branch connections, and requiring "remote-controlled cutting tool" reinstatement of these connections.

ASTM F1743 (1996): ASTM further approved F1743 as the "Standard Practice Rehabilitation of Existing Pipelines and Conduits by Pulled-in-Place Installation of Cured-in-Place Thermosetting Resin Pipe". Similar to F1216, this standard also required "continuous" material installation and remote-controlled cutting tool reinstatement for branch connections.

Manufacturers also play a vital role in providing installation guidelines. Perma-Liner Industries, a prominent player, publicly distributed "SPECIFICATIONS FOR INSTALLING CURED-IN-PLACE (CIPP) DRAIN, WASTE, AND VENT PIPE LINING". Initially, in 2013, their specifications noted awareness of alternative reinstatement methods like "Start & Stop," "Gapping," and "Spin-Casting," but stated they did not publish guidelines or offer training for these methods if not offered by Perma-Liner, warning that using them could void warranties. By May 2015, Perma-Liner's updated specifications began publicly distributing an "approval" for the "Gapping" reinstatement method, though they still recommended third-party engineer approval for any alternative reinstatement method.

Florida Building Code and CIPP: A Focus on Regulation

Florida has been at the forefront of establishing clear regulatory requirements for CIPP installations.

DS 2015-106 (November 2015): The Florida Building Commission issued Declaratory Statement 2015-106, a pivotal decision. This statement confirmed that permits are mandatory for the installation of CIPP in residential and existing building drainage systems, as required by Section 105 of the Florida Building Code (5th Edition, 2014). It explicitly affirmed that such work falls under regulated plumbing work, subject to permitting and inspection requirements. Furthermore, it mandated that installations must comply with the manufacturer's published instructions and relevant code sections. This ruling was confirmed by the unanimous vote of the Code Administration TAC and Plumbing TAC, emphasizing that the installation must be in accordance with the manufacturer's instructions and comply with Florida Building Code, Existing Building, Section 609.1 Materials, and Florida Building Code, Plumbing, Section 303.2 Installation and Materials.

2024 Florida Building Code Supplement (April 2024): The Florida Building Code officially published language requiring CIPP rehabilitation of building sewers and drainage systems to comply with ASTM F1216 and ASTM F174315. These provisions, found in Section 718.1 of the Building Code and Section P3012.1 of the Residential Code, became effective on April 16, 2024, aiming to ensure consistent and compliant code enforcement across the state.

DS 2024-044 (February 2025): A later Declaratory Statement, DS 2024-044, further solidified the requirements. It confirmed that all CIPP rehabilitation must comply with Sections 718.1 and P3012.1 of the 8th Edition Florida Building Code (2023), which mandate adherence to ASTM F1216 and ASTM F174318. Critically, this statement evaluated non-continuous methods like "gapping," "start and stop," or "hybrid" lining. The conclusion was definitive: these segmented approaches have no applicable ASTM standards and therefore do not meet Florida Building Code requirements. Only fully conforming installations performed in accordance with approved ASTM standards are recognized as code-compliant. This decision strongly reinforces the importance of continuous, standards-based CIPP applications for structural drainage rehabilitation22. The urgency of this clarification was underscored by real-world issues, such as a Structural Integrity Reserve Study (SIRS) in May 2024 at Highland Towers, which revealed significant deficiencies related to CIPP "Gapped" material installation.

Proposed Code Modification (June 2025): Looking ahead, the Florida Building Commission is scheduled to review a proposed code modification on June 23, 2025. This modification aims to further clarify and reinforce the Florida Building Code regarding CIPP, explicitly requiring that all CIPP installations comply with ASTM F1216 or ASTM F1743. Both of these standards mandate a continuous liner installation with no gaps at branch or service connections, promoting consistent enforcement and aligning Florida's plumbing code with nationally recognized industry standards.

In summary, the journey of CIPP from an innovative repair method to a fully regulated practice highlights the critical interplay between technological advancement, industry standards (like ASTM), manufacturer guidelines, and evolving building codes. Florida, through its Declaratory Statements and code updates, has progressively tightened regulations, particularly emphasizing the necessity of continuous lining and the rejection of non-standard methods like "gapping" to ensure public safety and code compliance.

video on CIPP problem


 
We have a lawsuit brewing up over a job that was done in the vertical stacks in 2016 without a permit in one of the high-rises. The 'gap' method, also known as the 'start and stop' method variation, is not compliant with the standards.
 
Where pressure piping systems are rehabilitated using an epoxy lining system, it shall be in accordance with ASTM F2831.
DWV is not a pressure piping system, so I would say that doesn't apply to DWV. In Chapter 7, we have 715.3:

2022 California Plumbing Code said:
715.3 Existing Sewers
Replacement of existing building sewer and building storm sewers using trenchless methodology and materials shall be installed in accordance with ASTM F1216, ASTM F2561, ASTM F2599, or ASTM F3240.

Interestingly, that only applies to sewers. So I'm unclear on whether rehabilitation of interior DWV is not allowed, or anything goes, or what. Edit: maybe not allowed, as I don't see anything applicable in Table 701.2 on "MATERIALS FOR DRAIN, WASTE, VENT PIPE AND FITTINGS".

Cheers, Wayne
 
Screen Shot 2025-06-29 at 10.49.46 AM.png

La County did not allow the CIPP method of trench-less sewer replacement until it came into the code.

The procedure for the use of trench-less sewer pipe is as follows:
1. A camera run prior to installation that is witnessed by an inspector. The purpose is to identify any laterals that might be cut off and also the general condition of the existing pipe.
2. A second camera run witnessed by an inspector. The pipe must be filled with water and then released. The purpose is to locate any place in the run that holds water. In the case of pipe bursting there shall be no fused joints that were not reamed. With CIPP there shall be no gaps.

The typical way it goes:
1. The contractor obtains a permit for a clean-out with no mention of the liner.
2. The contractor obtains a permit for the liner and calls for a final inspection with no intention of doing the camera run. The first cameras run was not done and the contractor claims that there is no way to fill the pipe with water. While I can agree that the CIPP pipe can't be filled with standing water the camera run must take place with water from a hose.

Note that 715.3 states that CIPP shall not be used when the existing piping is compromised. That's about a mouthful hey. What does compromised include? It doesn't mean collapsed as that was mentioned separately. It is sewer pipe that has but one purpose which is to contain sewage and provide a secure delivery of the sewage to the public sanitary sewer system. If the piping is leaking sewage along the way, it is clearly compromised in the one and only function.

When there is a correction written on a trench-less sewer installation, there is usually no way to achieve compliance short of digging it up and installing a conventional sewer piping such as ABS. At the moment that a correction is written, the permit begins the journey to the expiration date.
 
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La County did not allow the CIPP method of trench-less sewer replacement until it came into the code.

The procedure for the use trench-less sewer repairs is as follows:
1.A camera run prior to installation that is witnessed by an inspector. The purpose is to identify any laterals that might be cut off and also the general condition of the existing pipe.
2. A second camera run witness by an inspector. The pipe must be filled with water and then released. The purpose is to located any place in the run that hold water.

The typical way it goes:
1. The contractor obtains a permit for a clean-out with no mention of the liner.
The contractor obtains a permit for the liner and calls for a final inspection with no intention of doing the camera run. 2. The first cameras run was not done and the contractor claims that there is no way to fill the pipe with water. While I can agree that the pipe can't be filled with standing water the camera run must take place with water from a hose.

Note that 715.3 states that CIPP shall not be used when the existing piping is compromised. That's about a mouthful hey. What does compromised include? It doesn't mean collapsed as that was mentioned separately. It is sewer pipe that has but one purpose which is to contain sewage and provide a secure delivery of the sewage to the public sanitary sewer system. If the piping is leaking sewage along the way, it is clearly compromised in the one and only function.
What you're describing in LA County with CIPP really hits home with how things have evolved in Florida's code. Conducting thorough camera inspections, both before and after, including checking for water-holding spots, is non-negotiable for us to ensure compliance. Your perspective on what 'compromised' piping actually means is spot on, too.
 
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