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                          Draft High Efficiency Toilet Specification

1.0    SCOPE AND OBJECTIVE

This specification establishes the criteria to qualify a high efficiency toilet (HET) under the
United States EPA Water Efficiency Program. It is applicable to:
               single-flush, tank-type gravity toilets;
               dual-flush, tank-type gravity toilets;
               dual-flush, tank-type flushometer tank (pressure-assist) toilets,
               tank-type, flushometer tank (pressure-assist) toilets, and
               tank-type electrohydraulic toilets.
The specification is designed to ensure both sustainable, efficient water use and a high level of
user satisfaction with flushing performance.

2.0    SUMMARY OF CRITERIA

To qualify under the program, toilets must meet criteria in three areas:

       •      Effective flush volume shall not exceed 1.28 gallons1  (4.8 liters), as specified in
              Section 3.0;

       •      Solid waste removal must be 350 grams2 or greater, as specified in Section 4.0;
              and

       •      The toilet must conform to the adjustability and other  supplementary requirements
              specified in Section 5.0.

Conformance with  these criteria must be established through independent laboratory testing, as
specified in Section 6.0.

3.0    WATER EFFICIENCY CRITERIA

       3.1    Single Flush Toilets - The effective flush volume shall not exceed 1.28 gallons
              (4.8 liters). The effective flush volume is the average flush volume when tested in
              accordance with ASME Al 12.19.2-2003.
       3.2    Dual Flush Toilets - The effective flush volume shall not exceed 1.28 gallons (4.8
              liters). The effective flush volume is defined as the composite, average flush
              volume of two reduced flushes and one full flush. Flush volumes  should be tested
              in accordance with ASME All2.19.2-2003 and ASME All2.19.14-2001.
1 The effective flush volume has been established as 1.28 gallons, which is a 20 percent reduction from the 1.6 gallons per flush
standard that became mandatory pursuant to the 1992 EPAct.
2 A qualified HET must provide superior flushing performance while saving significant volumes of water. Based on data
contained in the medical study Variability of colonic function in healthy subjects, 1978, J.B. Wyman, K.W. Heaton, A.P.
Manning, and A.C.B. Wicks of the University Department of Medicine, Bristol Royal Infirmary, the greatest single 'loading' of
the 20 study participants was approximately 450g, and the 99.5% confidence level of the men in the study equates to a loading of
approximately 350g.
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4.0    FLUSH PERFORMANCE CRITERIA

       4.1     Toilet model performance is identified as either a Pass or Fail depending upon
              whether it can successfully and completely clear all test media from the fixture in
              a single flush in at least four of five attempts. Only toilet models that Pass qualify
              for the EPA Water Efficiency Program. Flush performance testing shall be
              conducted in accordance with the test protocol provided in Appendix A.

       4.2     Test media consists of seven test specimens, 50 ± 4 grams each, consisting of
              soybean paste contained in latex casing, and four loosely crumbled balls of toilet
              paper as defined in Appendix A.

       4.3     The flush performance criteria apply to single flush toilets, and to the full flush
              option of dual flush toilets. No solid waste removal requirement applies to the
              reduced flush option on dual flush toilets.

5.0    SUPPLEMENTARY REQUIREMENTS FOR FLUSH VOLUME ADJUSTABILITY

       5.1     All toilets must conform to ASME Al 12.19.2-2003.

       5.2     The criteria in this section apply to tank-type gravity toilets.
              5.2.1    Must conform to ASME Al 12.19.5-2005
              5.2.2   Fill Valve
                     The fill valve shall be the pilot valve type only, or, alternatively, the fill
                     valve shall meet the performance requirements of the fill valve test
                     protocol in Appendix B.
              5.2.3    Tank Capacity
                     5.2.3.1 Any barrier, bucket, dam, displacement device, or similar fixture
                           used in  a toilet tank to affect flush volume shall be tamper-resistant
                           and permanently affixed to the tank. Any device that can be
                           tampered with or removed such that the toilet can be made to flush
                           with greater than the maximum flush volumes specified in Section
                           5.2.3.2 shall be deemed noncompliant.
                     5.2.3.2 The maximum volume of water that may be discharged by the
                           toilet, when field adjustment of the tank trim is set at its maximum
                           water use setting, shall not exceed the following amounts:
                                  For single flush fixtures: 1.68 gallons (6.4 liters) per flush3
                                  For dual flush fixtures:  1.10 gallons (4.2 liters) per flush4
                                  in reduced flush mode and 2.00 gallons (7.6 liters) per
                                  flush5 in full flush mode.
3 Value based on a maximum effective flush volume of 1.28 gallons (4.8 liters) per flush, with no more than 0.40
gallon (1.6 liter) increase with tank trim adjusted to maximum water use settings.
4 Value based on the reduced flush requirement in ASME A112.19.14-2001.
5 Value based on the requirement in the Los Angeles Department of Water and Power Supplementary Purchase
Specification, adopted in 2000 and as amended in 2005
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                           The maximum volume of water discharged, using both original
                           equipment tank trim and using after market closure seals shall be
                           tested according to the protocol in Appendix C.

6.0    QUALIFIED TESTING LABORATORIES

A qualified laboratory that is independent of the product manufacturer must conduct testing for
conformance to this specification. Witness testing by personnel from a qualified laboratory
recognized and approved for such testing is permitted. Qualified laboratories are laboratories
recognized and approved for testing to ASME Al 12.19.2 and this specification by the
International Association of Plumbing and Mechanical Officials (IAPMO) Research and Testing.
Currently qualified laboratories are listed in Appendix D.

7.0    PRODUCT SAMPLING

The product sample tested  to these requirements shall be selected according to the procedure
provided in Section A4 of ASME Al 12.19.2-2003, Nonmandatory Appendix A, Demonstrating
Compliance to ASME Al 12.19.2.

8.0    EFFECTIVE DATE

This specification is effective on 1 August 2006. HETs qualified to the predecessor UNAR
specification6 prior to this effective date and having a MaP waste removal performance of 350
grams or greater shall be deemed to be qualified to this specification and shall not be required to
undergo further testing for this purpose.

9.0    FUTURE SPECIFICATION REVISIONS

EPA reserves the right to revise this specification should technological and/or market changes
affect its usefulness to consumers, industry, or the environment. Revisions to the specification
would be made following discussions with industry partners.

10.0   DEFINITIONS

Definitions within ASME Al 12.19.2-2003 and ASME Al 12.19.14-2001 are included by
reference.

Electrohydraulic toilet: A toilet fixture of siphonic or washdown design that uses a motor,
pump and controller to assist flushing action.

Pressure-assist toilet: A flushometer tank toilet as  defined in ASME Al 12.19.2-2003.

Rated flush volume: The stated flush volume of the toilet, as certified.
6 Uniform North American Requirements (UNAR) for toilet fixtures, a supplementary specification developed in
2005 for water utilities. The performance requirements of UNAR are contained within this specification, except that
the minimum waste removal threshold in UNAR requires the successful removal of five (5) 50 gram test specimens,
rather than seven (7) as specified herein.
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Witness testing: A practice whereby accredited laboratory personnel (auditor or inspector)
witness and supervise certification testing at an offsite location, usually at the client's facility,
such as a manufacturer's laboratory. Prior to such testing, the offsite test facility must be deemed
fully capable of and approved for performing the required certification tests, including, but not
limited to, approval of the test facility's equipment and its calibration, the qualifications of the
personnel performing the test, the record-keeping practices of the facility, and the qualifications
of the facility. Documentation of these capabilities must be provided by the facility to the
witness.
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                                     APPENDIX A

                    HET Fixture Flush Performance Testing Protocol7

1.0    SCOPE OF TESTING

       1.1    Toilet model performance is identified as either a Pass or a Fail depending upon
             whether the test fixture can successfully and completely clear all media (350
             grams) from the fixture in a single flush in at least four of five attempts.

       1.2    Tests where toilet sample clogs, plugs, or fails to restore a minimum of a 2 inch
             (50mm) trap  seal following each flushing test will be deemed a failed test.

       1.3    Test media is comprised of the following:
             1.3.1  Seven test specimens at 50 ± 4 grams per test specimen ("test specimen")
                    consisting of soybean paste contained in latex casing, tied at each end
                    forming a 'sausage' approximately 4 ± 0.5 inch (100 ± 13 mm) in length
                    and 1 ± 0.25 inch (25 ± 6mm) in diameter.
             1.3.2  Four loosely crumpled balls of toilet paper ("paper").

2.0    TESTING PROTOCOL

       2.1    Fixture Model Selection
             The product sample tested to these requirements shall be selected according to the
             procedure provided in Section A4 of ASME Al 12.19.2-2003, Nonmandatory
             Appendix A, Demonstrating Compliance to ASME Al 12.19.2.

       2.2    Set-Up
             2.2.1  Samples shall be assembled according to manufacturer's written
                    instructions as contained within the product packaging, and placed on test
                    rig, ensuring tank and bowl are level.
             2.2.2  Tank water level shall be adjusted to the level specified by manufacturer
                    in the manufacturer's instructions (e.g., set to waterline) where applicable.
             2.2.3  Static water supply pressure shall be set to 50 ±3 PSIG.
             2.2.4  Inlet water temperature shall be 65 to 80°F (18 to 27 °C).
             2.2.5  Flush sample a minimum of three times prior to commencement of testing.
             2.2.6  Re-adjust tank water level to proper level if required.

       2.3    Flush Volume Measurement
             2.3.1  Measure and  record flush volume of sample (sample set-up as outlined in
                    Section 2.2).  Repeat the test two additional times and record the results
                    and the average of the three test replicates. A receiving vessel may be
                    used,  either calibrated in increments not exceeding 0.025 gallon (0.1 L) or
                    placed on a load cell with a readout in increments not exceeding 0.025
7 Testing protocol based on Maximum Performance (MaP) Testing Protocol, Version 3, January 2006, by Bill
Gauley, Veritec Consulting, Inc., and John Koeller, Koeller and Company.
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                    gallon (0.1 L).  Other methods capable of measuring volumes to within in
                    0.025 gallon (0.1 L) shall be acceptable.
              2.3.2  Samples with average flush volumes in excess of 0.10 gallon (0.4 L)
                    greater than their rated flush volume shall be deemed to fail testing
                    requirements due to excessive flush volume8.
              2.3.3  Samples with average flush volumes less than 0.10 gallon (0.4 L) greater
                    than their rated flush volume shall be adjusted, if possible, to their rated
                    flush volume prior to performance testing.
              2.3.4  Samples with average flush volumes less than their rated flush volume
                    shall be tested at measured volume and this volume shall be recorded on
                    test report.

       2.4    Waste Extraction Test
              2.4.1  Test specimens shall be formed by hand such that they are roughly
                    cylindrical in shape and uniform in diameter.
              2.4.2  A test specimen drop guide shall be placed across the top of the bowl, with
                    the centerline of a 2 inch (50 mm) diameter opening 6 inches (15 cm) in
                    front of the center of the seat post holes, equidistance from each hole.
                    Drop guide may be made of plastic or other rigid material, to be no more
                    than 0.5 inch (12 mm) thick, and be of sufficient length to span top of
                    toilet bowl.
              2.4.3  Seven (7) test specimens (350g) shall be freely dropped in a vertical
                    orientation through opening in drop guide into bowl.
              2.4.4  Remove drop guide and freely and randomly drop four balls of crumpled
                    toilet paper over center of bowl sump.
              2.4.5  Wait 10 ± 1 seconds.
              2.4.6  Flush sample. Collect discharged media in strainer or other suitable
                    container positioned below toilet fixture.
              2.4.7  Record test as Pass or Fail (test is a Fail if any waste remains in the bowl
                    or trap, or if minimum 2 inch (50 mm) trap seal has not been restored).
              2.4.8  Remove (rinse) discharged toilet paper from test specimens, and prepare
                    test specimens for further testing.
              2.4.9  Flush sample to clean bowl and trapway and fully restore trap seal.
              2.4.10 Repeat testing until toilet sample either (i) achieves four Pass grades or
                    (ii) achieves two Fail grades.
              2.4.11 Models must Pass at least four of five attempts to qualify for the EPA
                    Water Efficiency Program.

3.0    TEST MEDIA SPECIFICATIONS

       3.1    Soybean paste nominal  specifications:
       •      35.5% water, 33.8% soybean, 18.5% rice, and 12.2% salt, and having a density of
              1.15 ± 0.10 g/mL (i.e., density greater than that of water).
8 For example, fixtures rated at 1.28 gallons per flush (the HET maximum) but flushing at greater than 1.38 gallons
(5.2 L) when adjusted to water line shall be deemed to have "failed" the requirements of this specification.
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       3.2
       3.3
       •
       3.4
       •
       •
       3.5
       •
       3.6
       •
Latex casing specifications:
Casings made from non-lubricated latex materials conforming with ASTM
D3492-03.

Cord used to tie casing:
1.0mm diameter polymer cord that will not crack or harden with time. (Stretch
Magic Bead & Jewelry Cord, available from Pepperell Braiding Company, P.O.
Box 1487, Pepperell, MA 01463, 800-343-8114, or equivalent)

Cased test specimens:
Each test specimen shall have a mass of 50 ± 4 grams.
Test specimens must be able to span clear distance of 3 inches (76 mm) for
minimum of 15 seconds when tested at 65 to  80°F (18 to 27°C) (setup illustrated
in Figure 1).
Test specimens with rips, tears, punctures, or other damage, shall not be used.
Test specimens may contain small volumes of air, however, specimens that float
shall not be used.
(Note: cased test specimens are available from Veritec Consulting, Inc., listed in
Appendix D.)

Recommendations for storage of cased test specimens:
Test specimens should be stored in air-tight containers and refrigerated (4 ± 4°C
or 39 ±7°F) when not in use.  A damp sponge should be placed in bottom of
container to prevent test specimen drying.

Toilet paper specifications:
Each ball of paper is comprised of six sheets of single ply toilet paper conforming
to ASMEA112.19.14-2001,  section 3.2.5.1.2.
                                     76mm span
                                     3 inch span
                    Figure 1
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                                     APPENDIX B

                         HET Fill Valve Integrity Test Protocol9

1.0    SCOPE OF TESTING

This requirement shall apply to all fill valves that are not otherwise classified as pilot valves.
Samples must conform to both Sections 2.0 and 3.0.

2.0    CONSISTENT WATER LEVEL

       2.1    Purpose of Test: To determine whether or not the fill valve shuts off at a
             consistent water level in a toilet tank independent of any change in inlet water
             supply pressure.

       2.2    Test Procedure:
             2.2.1  Install the fill valve in the toilet tank provided, install the tank on a leveled
                    test stand, and adjust the water level per the manufacturer's
                    recommendation at an inlet water pressure of 20 ± 2 PSIG or at the
                    manufacturer's  recommended minimum pressure as noted in the product
                    literature and product packaging.
             2.2.2  Flush the tank to verify and mark water level after completed refill.
             2.2.3  Increase the inlet water pressure to 60 ± 2 PSIG.
             2.2.4  Flush the tank.
             2.2.5  Measure any difference in water level after completed refill.
             2.2.6  Repeat steps 2.2.3 to 2.2.5 utilizing 80 ± 2 PSIG inlet water pressure.

       2.3    Performance Requirement:  The fill valve shall shut off at the same water level
             ±0.5 inch (±12  mm) for all three inlet water pressures.  In addition, water shall not
             enter the overflow tube or flow out of the tank at any of the three tested inlet
             pressures.

3.0    SHUTOFF INTEGRITY WITH INCREASED WATER PRESSURE

       3.1    Purpose of Test: To determine whether or not the fill valve shuts off at a
             consistent water level in a toilet tank independent of changes in inlet water supply
             pressure.

       3.2    Test Procedure:
             3.2.1  Install the fill valve in a toilet tank and adjust the water level per the
                    manufacturer's  recommendation  at an inlet water pressure of 20 ± 2 PSIG
                    or at the manufacturer's recommended minimum pressure as noted in the
                    product literature and product packaging.
9 Testing protocol based on Appendix B to Los Angeles Department of Water and Power Supplementary Purchase
Specification, 16 November 2005 version.
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             3.2.2  Flush the tank to verify and mark water level after completed refill.
             3.2.3  Increase the inlet pressure to the fill valve from 20 (or recommended
                    minimum pressure) to 60 PSIG, then to 80 PSIG at a rate of less than 10
                    PSIG per second.

       3.3    Performance Requirement: The water level shall remain at the initial mark ±0.5
             inch (±12 mm). In addition, water shall not enter the overflow tube or flow out of
             the tank.
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                                     APPENDIX C

                       Tank Trim Adjustability Testing Protocol10

1.0    SCOPE OF TESTING

All tank-type gravity toilet fixtures must conform to the requirements of Section 2.0, which
address the adjustability of original equipment tank trim and the resulting flush volume of the
toilet fixture. All tank-type gravity toilet fixtures with flush seals must conform to the
requirements in Section 3.0, which address the flush volume resulting from the replacement of
original equipment seals with seals available in the after market.

2.0    TANK-TYPE GRAVITY TOILETS WITH ORIGINAL EQUIPMENT

       2.1     Purpose of Test
              The objective of this tank trim adjustability test is to determine the upper limit to
              the volume of water that may be discharged by the field adjustment of tank trim
              components. The maximum volume of water that may be discharged by the toilet,
              when field adjustment of original equipment tank trim is set at its maximum
              water-use setting,  shall not exceed the following amounts:
                     For single  flush fixtures - 1.68 gallons (6.4 liters) per flush
                     For dual flush fixtures:
                            Reduced flush ("short flush") mode - 1.10 gallons (4.2 liters) per
                                  flush
                            Full flush mode - 2.00 gallons (7.6 liters) per flush
              The following test procedure shall be used to verify that the toilet sample meets
              these requirements.

       2.2     Test procedure
              Test shall be conducted per section 8.4 of ASME Al 12.19.2-2003 with the
              following modifications:
              2.2.1   The toilet shall be installed on a leveled test stand and  all adjustable tank
                     trim components (any field adjustment features in the tank that might
                     increase the toilet flush volume) shall be adjusted to the maximum water
                     use setting, while taking  care not to damage or alter the parts.
              2.2.2   The water  level in the tank shall be set to 0.25 ± 0.06 inch (6 ± 2 mm)
                     below the top of the overflow tube.  Where the tank utilizes an internal
                     containment vessel and does not possess an overflow tube, the vessel shall
                     be filled to a level 0.25 ± 0.06 inch (6 ± 2 mm) below the top rim of the
                     vessel or to the manufacturer's designated water line, whichever is higher.
              2.2.3   The static pressure of the water supply shall be adjusted to 80 ± 2 PSIG.
10 Testing protocol based on Los Angeles Department of Water and Power Supplementary Purchase Specification,
16 November 2005 version, modified to reflect the deletion of certain trim durability and marking requirements
incorporated into ASME A112 19.5-2005.
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             2.2.4  The toilet shall be flushed maintaining the activator in the flushing
                    position for a period of one (1) second, the water being drained into a
                    container.
             2.2.5  After the flush cycle is complete, the total flush volume shall be observed
                    and recorded.
             2.2.6  This procedure shall be repeated until five (5) sets of data are obtained.
             2.2.7  The static pressure of the water supply shall be adjusted to 20 ± 2 PSIG or
                    at the manufacturer's recommended minimum pressure as noted in the
                    product literature and product packaging, and test procedure steps 2.2.4 to
                    2.2.6 shall be repeated.
             2.2.7  For dual-flush toilet fixtures, this test shall be conducted at both full flush
                    and reduced flush modes.

       2.3    Report: The five (5) individual flush volumes and the average of the five (5) runs
             shall be reported for each of the  two static water supply pressures specified.

       2.4    Performance Requirement: The average total flush volume for five (5) test runs
             for each of the two static water supply pressures shall not exceed the following:
                    For single-flush fixtures - 1.68 gallons (6.4 liters) per flush
                    For dual-flush fixtures:
                           Reduced flush ("short flush") mode - 1.10 gallons (4.2 liters) per
                                 flush
                           Full flush mode - 2.00 gallons (7.6 liters) per flush
             The volume of water may be determined visually using a graduated container or
             by weight calculated as a unit to volume unit.

3.0    TANK-TYPE GRAVITY TOILETS WITH AFTER-MARKET CLOSURE SEALS

       3.1    Purpose of Test
             The objective of this tank trim adjustability and after-market seal test is to
             determine the upper limit to the volume of water that may be discharged when an
             off-the-shelf replacement flush valve seal/flapper is installed on the toilet. The
             maximum volume of water that may be discharged by the toilet, when the original
             equipment flush valve seal (flapper or other sealing device) is replaced with a
             standard (buoyant) seal available in home improvement centers and hardware
             stores, and the field adjustment of tank trim is set at its maximum water-use
             setting, shall not exceed the following amounts:
                    For single flush fixtures - 1.68 gallons (6.4 liters) per flush
                    For dual flush fixtures:
                           Reduced flush ("short flush") mode - 1.10 (4.2 liters) gallons per
                                 flush
                           Full flush mode - 2.00 gallons (7.6 liters) per flush
             The following test procedure shall be used to verify that the toilet sample meets
             these requirements.

       3.2    Test procedure
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              Test shall be conducted per section 8.4 of ASME Al 12.19.2-2003 with the
              following modification:
              3.2.1   The toilet shall be installed on a leveled test stand and all adjustable tank
                     trim  components (any field adjustment features in the tank that might
                     increase the toilet flush volume) shall be adjusted for maximum water use,
                     while taking care not to damage or alter the parts.
              3.2.2   Remove the original equipment flush valve seal and replace it with a
                     standard (buoyant) non-adjustable after-market seal/flapper for that toilet
                     where possible. In the case of a standard configuration 2-inch flush valve,
                     a Fluidmaster Bullseye Super flapper (part no. 501) or a Coast Foundry
                     Ultra Blue flapper shall be used.  For non-standard flush valves, including
                     3-inch flush valves, one or more replacement seals available at hardware
                     and building supply stores shall be used11.
              3.2.3   The water level in the tank shall be set to 0.25 ± 0.06 inch (6 ± 2 mm)
                     below the top of the overflow tube. Where the tank utilizes an internal
                     containment vessel and does not possess an overflow tube, the vessel  shall
                     be filled to a level 0.25 ± 0.06 inch (6 ± 2 mm) below the top rim of the
                     vessel or to the manufacturer's designated water line, whichever is higher.
              3.2.4   The static pressure of the water supply shall be adjusted to 80 ± 2 PSIG.
              3.2.5   The toilet shall be flushed maintaining the activator in the flushing
                     position for a period of one (1) second maximum, the water being drained
                     into a container.
              3.2.6   After the flush cycle is complete, the total flush volume shall be observed
                     and recorded.
              3.2.7   This  procedure shall be repeated until five (5) sets of data are obtained.
              3.2.8   The static pressure of the water supply shall be adjusted to 20 ± 2 PSIG or
                     at the manufacturer's recommended minimum pressure as noted in the
                     product literature and product packaging, and test procedure steps 3.2.5 to
                     3.2.7. shall be repeated.
              3.2.9   For dual-flush toilet fixtures, this test shall be conducted at both flush
                     modes (full flush and reduced flush).

       3.3    Report: The  five (5) individual flush volumes and the average of the five (5) runs
              shall be reported for each of the two static water supply pressures specified.

       3.4    Performance Requirement: The average total flush volume for five (5) test runs
              for each of the two static water supply pressures shall not exceed the following:
                     For single-flush fixtures - 1.68 gallons (6.4 liters) per flush
                     For dual-flush fixtures:
                            Reduced flush ("short flush") mode - 1.10 gallons (4.2 liters) per
                                   flush
                            Full flush mode - 2.00 gallons (7.6 liters) per flush
11 Where neither the Fluidmaster Bullseye Super flapper nor the Coast Foundry Ultra Blue flapper fit the flush valve,
where a 3-inch flush valve is employed, or in the case of non-standard flush valve seals, the testing laboratory shall
have discretion as to which after-market flapper or seal shall be used in the test.
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             The volume of water may be determined visually using a graduated container or
             by weight calculated as a unit to volume unit.
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                                     Appendix D

                            Qualified Testing Laboratories

IAPMO Testing and Services, LLC
5001 E. Philadelphia Street
Ontario, CA 91761
Mr. Ken Wijaya, Laboratory Director
(909)472-4100
kenwij aya@iapmo.org

Veritec Consulting, Inc.
1495 Bonhill Road, Unit 12
Mississauga, Ontario L5T  1M2
Mr. William Gauley, Prof. Engineer
(905) 696-9391
bill@veritec.ca

Other laboratories approved for testing to ASME Al 12.19.2 are encouraged to become approved
for testing to this specification through IAPMO Research and Testing.
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