Corrugated Stainless Steel Tubing (CSST) Gas Pipe

If you have corrugated stainless steel tubing (CSST) installed in your home for gas distribution you are strongly urged to read the following information. I have long been against the idea of installing CSST for gas piping. As with many other building materials that have been developed to decrease costs to the home building industry, the manufacturers of this product seem to have cut too many corners. In the process they have increased the need for precise installation of the product and decreased the safety of homeowners saddled with these, apparently unsafe, installations.

I have monitored the CSST installations over time for performance and have made many changes accordingly to the wording in my inspections reports. However, my low opinion of the product has not changed. In fact, it is now my position that I would not have this product in my own home under any circumstances. I also strongly urge any of my clients with CSST piping in their homes to consider the following information and exercise due diligence regarding this product.

This is the current report verbiage I use. It is subject to change as more information comes to me.

The CSST gas lines do not appear to be properly bonded as required by NEC 250.104(B):

(B) Other Metal Piping. Where installed in or attached to a building or structure, a metal piping system(s), including gas piping, that is likely to become energized shall be bonded to the service equipment enclosure, the grounded conductor at the service, the grounding electrode conductor where of sufficient size, or the one or more grounding electrodes used. The bonding jumper(s) shall be sized in accordance with 250.122, using the rating of the circuit that is likely to energize the piping system(s). The equipment grounding conductor for the circuit that is likely to energize the piping shall be permitted to serve as the bonding means. The points of attachment of the bonding jumper(s) shall be accessible.

The CSST gas lines do not appear to be properly bonded as required by IRC G2411.1.1 (310.1.1) CSST. Corrugated stainless steel tubing (CSST) gas piping systems shall be bonded to the electrical service grounding electrode system. The bonding jumper shall connect to a metallic pipe or fitting between the point of delivery and the first downstream CSST fitting. The bonding jumper shall be not smaller than 6 AWG copper wire or equivalent. Gas piping systems that contain one or more segments of CSST shall be bonded in accordance with this section.

The CSST gas lines do not appear to be properly bonded as required by the National Fuel Gas Code (NFPA 54) 7.13.1 Pipe and Tubing Other than CSST. Each aboveground portion of a gas piping system other than CSST that is likely to become energized shall be electrically continuous and bonded to an effective ground-fault current path. Gas piping, other than CSST, shall be considered to be bonded when it is connected to appliances that are connected to the appliance grounding conductor of the circuit supplying that appliance. AND 7.13.2 CSST. CSST gas piping systems shall be bonded to the electrical service grounding electrode system at the point where the gas service enters the building. The bonding jumper shall not be smaller than 6 AWG copper wire or equivalent.

Additionally, the CSST gas lines do not appear to be bonded as per the manufacturer’s installation instructions. Gastite (and others) recommends that all continuous metallic systems be bonded and grounded. The owner should confirm with a licensed master electrician or electrical engineer that each continuous metallic system in a structure has been bonded and grounded by an electrical professional in accordance with local building codes. This should include, but is not limited to metallic chimney liners, metallic appliance vents, metallic ducting and piping, electrical cables, and structural steel. This is a fire and explosion hazard which must be immediately addressed.

Your are strongly urged to have this system inspected and properly bonded by a licensed master electrician or electrical engineer prior to the end of any time periods associated with the purchase of this home.

See: http://www.gastite.com/include/languages/english/downloads/pdfs/TB2008_01.pdf

https://www.texasinspector.com/documents/CSST_Always_Bond.pdf

http://www.aaronsinspections.com/documents/CSST-DANGERS.pdf

https://www.texasinspector.com/documents/CSSTGasPipingPh.1FinalReport.pdf

http://www.kcbd.com/story/19376060/house-fire-leaves-1-dead-1-injured-friday-night

http://ecmweb.com/bonding-amp-grounding/whose-job-it-bond-corrugated-stainless-steel-tubing-csst?eid=forward

http://www.nbcdfw.com/investigations/Safety-of-Corrugated-Steel-Tubing-Investigated-Following-Fires-243014091.html

The CSST gas piping is subject to damage from nail strikes, electrical wiring shorts, lightning strikes, et al. both during and after construction. The entire system is not accessible for a visual inspection and the presence or absence of damage to this piping cannot be ascertained without destructive forensic examination of the house which is beyond the scope of this inspection.

Even when the flow of leaking gas does not cause a fire or explosion, the possibility of gas poisoning is very real.

See: http://www.gas-leak.org/natural-gas-poisoning.php

Concealed hazards may exist. You are strongly urged to have this system leak tested and thoroughly inspected for condition and proper installation by a licensed master plumber with experience both CSST installation and in gas leak detection, as well as the CSST manufacturer, prior to the end of any time periods associated with the sale or purchase of this home.

See: http://www.nfpa.org/Assets/files/AboutTheCodes/54/GTI21323_Final.pdf

Research suggests that, at a minimum, and in addition to proper installation and bonding, the installation of lightning protection systems as per NFPA 780 and gas excessive flow valves (EFVs) may be essential in the presence of CSST, though not the end of due diligence. Finally, replacement of the CSST with threaded steel gas piping may be the only method certain of avoiding the risks involved with this product.

http://www.tracpipe.com/CSST_Gas_Pipe_Products/AutoTrip_EFV_Automatic_Gas_Shut_Off_Valve/

http://www.homesafety1st.com/files/excess_flow_data_sheet.pdf

CSST was deemed by a jury to be a defective product. See:

http://www.subrogationrecoverylawblog.com/2010/10/articles/products-liability/csst-1/jury-rules-that-csst-is-a-defective-product-in-landmark-case/

http://www.cozen.com/cozendocs/Outgoing/alerts/2010/Subrogation_102810.pdf

ATTENTION: FIRE AND EXPOSION HAZARD!

Based upon the evidence currently available, it is this inspector’s opinion that the CSST gas piping may be unsafe even if installed as per the manufacturer’s installation instructions.

You are strongly urged to consider having this system completely replaced with threaded steel gas piping prior to the end of any time periods associated with the purchase of this home and, more importantly, prior to occupying this home. Additionally, the owner of this home should be advised to immediately vacate the home and have the system either made safe (if possible) or replaced with threaded steel piping prior to moving back in.

Engineer in Hell

An engineer dies and reports to the pearly gates. St. Peter checks his dossier and says, “Ah, you’re an engineer — you’re in the wrong place.”

So, the engineer reports to the gates of hell and is let in. Pretty soon, the engineer gets dissatisfied with the level of comfort in hell, and starts designing and building improvements. After awhile, they’ve got air conditioning and flush toilets and escalators, and the engineer is a pretty popular guy.

One day, God calls Satan up on the telephone and says with a sneer, “So, how’s it going down there in hell?”

Satan replies, “Hey, things are going great. We’ve got air conditioning and flush toilets and escalators, and there’s no telling what this engineer is going to come up with next.”

God replies, “What??? You’ve got an engineer? That’s a mistake — he should never have gotten down there; send him up here.”

Satan says, “No way. I like having an engineer on the staff, and I’m keeping him.”

God says, “Send him back up here or I’ll sue.”

Satan laughs uproariously and answers, “Yeah, right. And just where are YOU going to get a lawyer?”

Ten Things You Don’t Know About the Texas Inspector

1. The Texas Inspector (dba Aaron Miller) is a former residential remodeling contractor and custom home builder. For 20 years he constructed and renovated homes and light commercial buildings in the North Central Texas area. 
2. The Texas Inspector, Aaron D. Miller, ACI, CEI, CMI, CPI, CRI, MTI, RCI  is the most certified residential inspector in North Central Texas.
   1. International Code Council (ICC) Residential Combination Inspector 5082671-R5
   2. International Code Council (ICC) Residential Building Inspector 5082671-B1
   3. International Code Council (ICC) Residential Electrical Inspector 5082671-E1
   4. International Code Council (ICC) Residential Mechanical Inspector 5082671-M1
   5. International Code Council (ICC) Residential Plumbing Inspector 5082671-P1
   6. American Society of Home Inspectors (ASHI) Certified Inspector No. 203652
   7. National Association of Home Inspectors (NAHI) Certified Real Estate Inspector, CRI 200353
   8. International Association of Certified Home Inspectors (INACHI), Certified Professional Inspector No. NACHI05060294
   9. Master Inspector Certification Board, Certified Master Inspector
   10. Texas Association of Real Estate Inspectors, Advanced Inspector, Emeritus
   11. Texas Professional Real Estate Inspectors Association (TPREIA) Master TPREIA Inspector (MTI)
   12. Texas Real Estate Commission (TREC) Professional Inspector 4336
   13. Texas Department of Agriculture, Structural Pest Control Service Registered Business No. 11379
   14. Texas Department of Agriculture, Structural Pest Control Service Certified Applicator No. 40247
   15. HUD 203K Consultant D0981
   16. Exterior Design Institute (EDI/EIMA) EIFS Third Party Inspector and Moisture Analyst (CEI) MA TX-29
   17. Post-Tensioning Institute Level One Certificate for Unbonded Prestreesed Post-Tensioned Concrete Installer No. 320054833
   18. CertainTeed® Master Shingle Applicator
   19. Building Officials Association of Texas (BOAT)
   20. Texas Residential Construction Commission (TRCC), Registered Builder No. 16229
   21. Texas Residential Construction Commission (TRCC), Registered State Third-Party Dispute Resolution Inspector No. 1350
   22. City of Garland, Texas Building and Fire Codes Board Member
   23. Texas Real Estate Commission (TREC) Inspector Core Instructor, Texas Standards of Practice/Legal/Ethics Update, ICE Electives
   24. International Distance Education Certification Center, Certified Distance Education Instructor (CDEI) 67923
   25. McKissock Education, LP, Instructor of Record for the State of Texas
3. The Texas Inspector has been a full-time Texas home inspector for more than 16 years. Working 60-hour weeks brings that near a total of 45,000 hours on the job, allowing for the occasional vacation. No matter which of the prevailing theories regarding what it takes to achieve expertise, i.e. 10,000 hours vs. 10 years, Aaron has achieved expertise in spades.
4. The Texas Inspector is a cabinet maker by trade. Attention to detail is the hallmark of any cabinet maker. That same concentrated focus is applied to each inspection performed.
5. The Texas Inspector is a true consumer advocate. In his signature exceedingly plainspoken style, he tells it exactly like it is regardless of the consequences. When spending multiple hundreds of thousands, or millions of dollars on a home, who needs BS? This has often gotten him into hot water with his licensing and certification agencies who find that too much truth being spoken about their industries is not good for business. The Texas Inspector is your advocate and the only one watching your back in the home buying process.
6. The Texas Inspector has won the prestigious Angie’s List Super Service Award every year since 2007 and is slated to win it again this year. The people have spoken, and that says it all.
7. The Texas Inspector has more than 10,000 satisfied clients (with a couple, OK maybe a few more, exceptions).
8. The Texas Inspector does not cater to builders or their agents, or real estate agents.
9. The Texas Inspector uses the most up-to-date technology during home inspections to include special investigative cameras, precision altimeters, moisture meters, et al.
10. He presently lives in Garland, TX, with his wife over 30 years, cats, a koi pond in the midst of a small forest garden, and a couple of thousand books.

What Does Code Certification Entail?

When you are buying or selling a house you will hear a lot of discussion about the building codes. Many homeowners are unclear as to what the significance of these codes is. That uncertainty extends to home builders and real estate professionals as well. So, let’s take a minute to discuss these.

Builders and real estate agents often mistakenly think (and sometimes deceitfully espouse) that the codes are in place to insure quality construction. Nothing could be further from the truth.

Simply put, building codes are the worst that you can build a building by law. You read that right. Building a building strictly to the codes, and not more, will not guarantee a durable, high quality building. The codes only seek to insure that a building is reasonably safe.

Most home buyers expect homes that have greater durability, performance, and quality than the building codes alone dictate in their minimum requirements. Contrast that with the fact that home builders are only required to build to the minimal requirements of the codes and the municipal inspectors inspect for compliance only with these minimal codes. This is the point at which the proverbial stuff hits the fan.

Let’s go a bit further down the rabbit hole, shall we? The Texas Real Estate Commission licenses home inspectors. They not only do not require that these licensed inspectors know anything about the building codes, they specifically exclude any requirement for such knowledge in their published standards of practice for professional inspectors.

Now let’s put this in perspective, if we can. Homeowners expect and demand quality, durable homes. The municipalities and their inspectors only require that the builders build to the bare minimum standards, insuring neither quality nor durability. The independent inspectors the state of Texas foists upon the homeowners are not even required to be familiar with the minimal requirements. What’s wrong with this picture?

Your only hope in assuring a safe, well-constructed home is to hire a professional inspector who is certified in the building codes and has extensive home construction experience. Code certification consists of becoming intimately familiar with the massive amount of information contained in the building codes, sitting for a battery of examinations, and then maintaining proficiency in this knowledge by continuing education.

The International Residential Code is a 904-page volume which contains an extensive list of referenced standards.

The International Building Code is a 690-page volume which also contains an extensive list of referenced standards.

The National Electrical Code, NFPA 70, is an 870-page volume which also contains an extensive list of referenced standards (see Annex A, Product Safety Standards).

These are the core references any inspector of new or existing homes must be intimately familiar with in order to achieve and maintain competence as an inspector.

And, did I mention that each of these codes is significantly rewritten every three years? Hence the requirement to constantly study the codes in order to maintain certification. 

In short, if your inspector is not code certified he is unable to perform a competent inspection.