Specifying a waterless trap seal for a commercial building project requires more than selecting a product. It requires understanding which certifications are mandatory, which codes apply in the project's jurisdiction, and how to document compliance in construction specifications. This article provides a comprehensive reference for architects, engineers, facility managers, and plumbing contractors navigating the certification and code landscape for waterless trap seal devices.
The short answer to "are waterless trap seals code compliant?" is yes, when the product carries the right certifications. But the details matter. Different jurisdictions adopt different plumbing codes, and each code framework has its own requirements for how waterless trap seals are evaluated and approved. Understanding these requirements protects the specifier, the contractor, and the building owner from compliance issues during plan review and inspection.
The two major plumbing code frameworks
The United States has two primary model plumbing codes. Every state adopts one of them (sometimes with local amendments), and the code your project falls under determines which certification pathway applies.
International Plumbing Code (IPC)
Published by the International Code Council (ICC), the IPC is adopted in approximately 35 states. It is the more widely used code framework, particularly in the eastern and central United States. The IPC addresses waterless trap seals in Section 1002.4, which permits "trap seal protection devices" as an alternative to maintaining a water seal through regular use or mechanical means (trap primers).
Under the IPC, a waterless trap seal device must be:
- Tested and listed to ASSE 1072 by an accredited third-party testing laboratory
- Installed in accordance with the manufacturer's instructions
- Listed by a product certification body accredited by ANSI or SCC (Standards Council of Canada)
Uniform Plumbing Code (UPC)
Published by the International Association of Plumbing and Mechanical Officials (IAPMO), the UPC is adopted in approximately 15 states, primarily in the western United States including California, Oregon, Washington, and Nevada. The UPC recognizes waterless trap seals through the cUPC listing process.
A product with a cUPC listing has been tested by IAPMO R&T (or an equivalent accredited laboratory) against the applicable standard (ASSE 1072) and is listed in the cUPC product directory. This listing is the UPC's mechanism for verifying that a product meets the performance requirements of the code.
For specifiers: The simplest way to ensure compliance in any jurisdiction is to specify a product that carries both a cUPC listing and ASSE 1072 certification. This covers both the IPC and UPC code frameworks. Green Drain carries both. See our state plumbing code guide for jurisdiction-specific details.
ASSE 1072: the performance standard
ASSE 1072 is the American Society of Sanitary Engineering performance standard specifically written for waterless trap seal devices. The current version is ASSE 1072-2020. It defines the testing protocols and performance thresholds that a waterless trap seal must meet to be certified.
The standard evaluates the following performance characteristics:
Trap seal integrity
The device must maintain a seal against sewer gas when no water is present in the trap. Testing measures the device's ability to block air passage under both static conditions and varying pressure differentials that simulate real building conditions (stack effect, wind loads, HVAC pressure changes).
Backpressure resistance
The device must maintain its seal under positive pressure from the sewer side (backpressure). This simulates conditions where sewer gas or air is actively pushing against the seal, as can occur during surcharging events or pressure fluctuations in the drainage system.
Flow rate and drainage performance
The device must not significantly impede the flow of water through the drain. Testing measures flow rates to ensure the waterless trap seal does not cause backup or reduce drainage capacity below acceptable levels.
Durability and cycle testing
The device is subjected to repeated open-close cycles to simulate years of use. This verifies that the seal mechanism (in Green Drain's case, the silicone valve) maintains its performance over the expected service life of the device.
Material safety
Materials that contact potable water or drain water must meet toxicity and extraction requirements. For food service applications, this intersects with NSF/ANSI standards (discussed below).
cUPC listing: what it means and why it matters
The letters "cUPC" stand for "certified Uniform Plumbing Code." A cUPC listing is issued by IAPMO R&T (Research and Testing) and indicates that a product has been tested, evaluated, and found to comply with the applicable standards referenced in the Uniform Plumbing Code.
For waterless trap seals, the cUPC listing process involves:
- Product testing against ASSE 1072 at an accredited laboratory
- Factory inspection to verify manufacturing quality control
- Ongoing surveillance including periodic re-testing and unannounced factory audits
- Listing in the cUPC product directory, which is the reference document used by plumbing inspectors to verify product compliance
A cUPC listing is not a one-time certification. It requires ongoing compliance, annual renewal, and periodic re-evaluation. If a manufacturer changes materials, design, or manufacturing processes, the listing must be updated through additional testing.
For plumbing inspectors, the cUPC listing is the primary verification tool. When an inspector sees a product installed in a drain, they can look up the product in the cUPC directory to confirm it is listed and approved. Products without a cUPC listing may be rejected during inspection in UPC jurisdictions.
NSF/ANSI certifications
NSF/ANSI 2: Food Equipment
NSF/ANSI 2 is the standard for food equipment materials, design, fabrication, and performance. A waterless trap seal with NSF/ANSI 2 certification has been evaluated for use in food service environments, including restaurants, commercial kitchens, food processing facilities, and institutional dining.
This certification verifies that the materials used in the device are safe for contact with food-related drainage, that the device can be cleaned and maintained in accordance with food safety requirements, and that it does not harbor bacteria or create conditions that compromise food safety.
For restaurant and food service projects, NSF/ANSI 2 certification is often a specification requirement from the health department or the project's food service consultant.
NSF/ANSI 61: Drinking Water System Components
While less commonly relevant to floor drain applications, NSF/ANSI 61 certifies that materials in contact with potable water do not leach contaminants above safe levels. This may be relevant in applications where the waterless trap seal is installed in a drain that also receives potable water overflow or where the local jurisdiction requires NSF 61 compliance for all plumbing components.
HACCP International certification
HACCP (Hazard Analysis and Critical Control Points) International is a food safety certification body that evaluates products for use in food handling and processing environments. HACCP International certification goes beyond material safety to evaluate whether a product supports or undermines the food safety management system.
For a waterless trap seal, HACCP International certification verifies that:
- The device contributes to the food safety environment by blocking pest entry and sewer gas
- Materials are food-safe and resistant to cleaning chemicals used in food service
- The device can be inspected, cleaned, and maintained without specialized tools
- The device does not create harborage points for pests or bacteria
Green Drain holds HACCP International certification, which is particularly relevant for food processing facilities, commercial kitchens, and any project where HACCP compliance is a design requirement.
CE Mark (European conformity)
The CE Mark indicates conformity with European health, safety, and environmental requirements. For waterless trap seal devices, the CE Mark is required for products sold and installed in the European Union and European Economic Area.
Green Drain's CE Mark certification covers compliance with the relevant European directives for construction products. For international projects or buildings designed to meet both U.S. and European standards, the CE Mark provides additional compliance coverage.
Green Drain's certification portfolio
Green Drain holds 13 certifications and 3 patents. This certification portfolio is the broadest in the waterless trap seal category and covers every major code framework and industry-specific requirement.
Key certifications include:
- cUPC listing (IAPMO R&T) for UPC code compliance
- ASSE 1072-2020 for IPC code compliance
- NSF/ANSI 2 for food service applications
- HACCP International for food safety environments
- CE Mark for European compliance
- WaterMark (Australia) for APAC projects
- DVGW (Germany) for German market compliance
The full list, with certificate numbers and testing laboratory details, is available on our Certifications page.
How to specify waterless trap seals in construction documents
For architects and engineers writing plumbing specifications, the following guidance ensures that waterless trap seals are properly documented for plan review and inspection.
Division 22 specification language
Waterless trap seals are specified in Division 22 (Plumbing) of the construction specification. The product should be called out in Section 22 13 00 (Facility Sanitary Sewerage) or Section 22 40 00 (Plumbing Fixtures), depending on the specifier's preference and the project's specification structure.
The specification should include:
- Product description: Waterless trap seal device, one-way silicone valve type
- Applicable standard: ASSE 1072-2020
- Listing requirement: cUPC listed by IAPMO R&T
- Material: Medical-grade silicone valve, [specify body material per size]
- Sizes: Available in 2", 3", 4", and 6" to match existing drain body sizes
- Additional certifications: NSF/ANSI 2 (for food service), HACCP International (where applicable)
- Acceptable manufacturer: Green Drain, Inc., or approved equal meeting all listed certifications
Specification tip: When writing "or approved equal" language, list all required certifications explicitly. This prevents substitution with products that may have fewer certifications. A product that carries cUPC but not NSF/ANSI 2 is not an equal in a food service project. See our Specifications page for downloadable spec language and cut sheets.
Drawing notation
On plumbing drawings, waterless trap seals should be noted at each floor drain location where they are specified. A common approach is to use a symbol or keynote at each drain with a reference to the specification section. Include the trap seal device in the plumbing fixture schedule with size, model, and specification reference.
Submittals
During the submittal phase, the contractor should provide:
- Product data sheets with all dimensions and materials
- cUPC listing certificate showing current listing status
- ASSE 1072-2020 test report from an accredited laboratory
- NSF/ANSI 2 certificate (for food service projects)
- HACCP International certificate (where specified)
- Installation instructions
Common questions from plan reviewers and inspectors
When a project includes waterless trap seals, plan reviewers and plumbing inspectors sometimes raise questions, particularly if they have not encountered the product before. Here are the most common questions and the documentation that answers them.
"Is this product approved for use in this jurisdiction?"
Provide the cUPC listing certificate and reference the applicable code section (IPC 1002.4 or the equivalent UPC section). The state plumbing code guide on our website identifies which code each state has adopted and the specific section that permits waterless trap seals.
"Does this replace the P-trap?"
No. A waterless trap seal is installed in addition to the existing P-trap. It provides a secondary seal that remains functional when the water in the P-trap evaporates. The P-trap remains in place and continues to function as the primary seal when water is present.
"What about backflow prevention?"
A waterless trap seal is not a backflow prevention device and should not be specified as one. It is a trap seal protection device that prevents gas, odor, and pest passage. Backflow prevention is addressed by separate devices and code sections.
Frequently asked questions
Are waterless trap seals code compliant?
Yes, when properly certified. Waterless trap seals that carry a cUPC listing and ASSE 1072 certification are recognized by both the International Plumbing Code (IPC) and the Uniform Plumbing Code (UPC). Green Drain is cUPC listed, ASSE 1072-2020 certified, and accepted by plumbing authorities in all 50 U.S. states. Always verify that the specific product you are specifying carries current, valid certifications from an accredited testing laboratory.
What is ASSE 1072?
ASSE 1072 is the American Society of Sanitary Engineering performance standard for waterless trap seal devices. The current version, ASSE 1072-2020, defines testing requirements for trap seal integrity, backpressure resistance, evaporation protection, flow rate, and durability. Products that pass ASSE 1072 testing have been verified by an independent laboratory to maintain a reliable seal without water under standardized conditions.
What certifications should a trap seal have?
At minimum, a waterless trap seal should carry a cUPC listing (required for code compliance in the U.S. and Canada) and ASSE 1072 certification. For food service applications, NSF/ANSI 2 and HACCP International certification provide additional assurance. For international projects, CE Mark (European conformity) and WaterMark (Australia) may be required. Green Drain carries 13 certifications covering all of these standards.
Do waterless trap seals meet IPC requirements?
Yes. The International Plumbing Code (IPC) Section 1002.4 allows trap seal protection devices as an alternative to traditional water-based trap seals. Products must be tested and listed to ASSE 1072 by an accredited laboratory. Green Drain meets this requirement through its cUPC listing and ASSE 1072-2020 certification. The IPC is adopted in approximately 35 states.