Provisional Translation
| OTO No. | 465 | Classification | MOC-15 |
|---|---|---|---|
| Date of Acceptance | November 28, 1991 | Ministry/Agency Receiving Complaint | Economic Planning Agency |
| Responsible Ministries | Ministry of Construction | Related Laws | Building Standards Law |
| Complainant | Domestic firm | Exporting Countries | Germany |
| Subject | Review of technical standards for electric dishwashers | ||
| Details of Measures | Implementation statute Article 129-2-2, Clause 3 Section 2 of the Building Standards Law states that where the structure of waste water drainage pipes is concerned, "pipes for draining waste water must include a waste water trap, * ventilation and other facilities necessary for sanitation." Further, Ministry of Construction Notice 1597-3-1b1. of 1975, based on the same article, specifies that wastewater drainage may not be connected directly to dishwashers, and that indirect drainage must be used. In other words, water drained from a dishwasher must leave the pipe and be collected in a receptacle for indirect waste water (appliance with an appropriate waste water trap and which measures to keeps the water retaining located a sufficient distance away that the water will be flow back into the pipe. The reason for this requirement is that connecting the dishwasher drainage pipe directly could cause sewage or sewage gases to flow backward, due to blockage or other abnormality of the draining pipe, contaminating dishes etc. directly and creating very unsanitary conditions. In a hot and humid climate like Japan's, there is also the risk that mildew or bacteria could contaminate surfaces through the drainage pipe. As a special measure under Article 38 of the Building Standards Law, when the minister for Construction acknowledges that structures (including facilities) using special materials or structural methods are of equivalent safety to those set out in the Building Standards Law statutes, the provisions of Chapter 2 of the said Law (concerning the plot of land, structure and facilities of the building), orders based on the Law or ordinances shall not apply, to permit a flexible response to progress in technology. Dishwashers linked directly to drains are a new technology, and since no clear technical standards are stipulated, the minister for Construction determines the safety of each model in accordance with Article 38 of the Building Standards Law. Regarding the dishwasher which is the subject of this complaint, the trap structure this appliance is claimed to have consists merely of a hose placed upright, and it is doubtful whether this will ensure adequate safety to prevent contaminants from entering the appliance. Further, there is no back-up provided for this mechanism, and although it is difficult to determine the appliance's safety at this stage, the complainant was informed that if the structure of the trap was improved and it was acknowledged that it could prevent backflow of contaminants into the appliance, it would be certified under the above Article. In order to obtain approval, it is necessary to prove that the appliance has equivalent or better performance than that required under the Building Standards Law. The complainant should present documentation proving to the Evaluating Committee of the Japan Building Center that the structure of the appliance is safe and poses no sanitation risks, and apply for certification of the said appliance after having its performance thoroughly evaluated. It will also be necessary to test the appliance to verify the performance of its backflow prevention apparatus and waste water trap function, and the complainant was further informed that in this case they should follow the directions of the Evaluating Committee of the Japan Building Center concerning details about the required procedure for testing. * Wastewater trap: an apparatus which, by always retaining a certain amount of water, prevents the entry of sewage or odors. |
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| Classification of Processing | Cc | Directions | I-a IV |
| Remarks | |||