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Environmental Health Plan Review
Questions & Answers

Answers to questions and clarifications are presented below:  


  • Can upfitting of existing, licensed daycares go through plan review as a rehab?
    Rehab will accept "all changes of licenses".  They will not accept an increase in the license or a new license.  This is being addressed now by the Division of Child Development; it is the agency that determines what rehab is allowed to receive.
  • Is the new Daycare form available (electronic copy)?
    Yes and it is posted on the Health Department Website at

Rehab will accept "all changes of licenses".  They will not accept an increase in the license or a new license.  This is being addressed now by the Division of Child Development; it is the agency that determines what rehab is allowed to receive. 



  • Can we have access to "code" to enable us to explain it to owners?
    All State Rules are presently available on the Department website under "Environmental Health/Rules and Regulations".
  • What about differences in State Rules and County interpretations?
    Local health department staff are agents of the state. Local communication with the state is frequent and open. Any perceived differences should be worked out with the party in discussion. The next step is to involve the supervisor, thus following the chain of command as required in a formal appeals process. Hopefully any local problems may be resolved well before that stage.
  • What is the approach to written county variances?
    Mecklenburg County enforces state rules. Any variances are allowed only per a specific rule and should be clearly stated in the regulations. However, some variances may exist. A county must enforce a rule as written, or if some interpretation is allowed, any "variance" must be consistently applied to all customers within that county. (see answer to interpretations question above)
  • What are the rules governing exposed copper pipe?  
    Ideal pipe installations should be concealed within floor, wall, or ceilings. However, exposed piping is acceptable as long as the proper wall and floor separations exist allowing the operator to easily clean the surrounding surfaces. Accepted floor and wall pipe separations are one and six inches, respectively.

Whenever proposed, Mecklenburg County Environmental Health defers to LUESA Plumbing Officials in determining whether exposed copper pipe will be acceptable.

According to Mecklenburg County Code Enforcement Officials all plumbing fixtures and piping will be required to follow Sections 305.1 – 3005.3 (i.e. Protection of Pipes and Plumbing System Components) & Section 308 (i.e. Piping Support Protection) of the NC State Plumbing Code, 2006.

  • Can we get better coordination between State and County regarding water usage tables and water heater requirements, specifically the use of tankless water heaters?
    NCDENR Plan Review Officials have decided that tankless water heating units shall follow established ASHRAE (i.e. American Society of Heating, Refrigerating, and Air Conditioning Engineers) sizing procedures whenever proposed for North Carolina commercial food service establishments. These guidelines are based upon applicable scientific, environmental, and physical factors and can be obtained from the equipment manufacturer upon request. Installed unit(s) shall provide the minimum amount of hot water in a gallon per minute or gallon per hour value (as determined by the manufacturer) based upon number and type of installed water fixtures and inclusion or absence of alternate storage. NOTE: The majority of instantaneous water heaters are not designed by the Manufacturer nor approved by ASHRAE to function as the primary hot water supply source for commercial ware-washing equipment.

Professionals who have concerns or questions regarding the sizing standards of tankless water heaters should contact the Department at f704-336-5505.

  • Can we have a seamless review, regarding Environmental Health and Mechanical?
    Environmental Health Plan Review responsibilities relate to equipment installation and approval; Mechanical Plan Review responsibilities relate to venting and piping per N.C. Amendments of the International Mechanical Code. Environmental Health coordinates regularly with other Trade Examiners in order to ensure that the integrity and consistent application of each rule, regulation, and code is maintained during the review process.
  • Can we have electronic plan submission?
    Present Departmental technology will not yet support electronic document submission, but the agency Director is currently testing software.
  • How can we address common errors associated with plan submission, i.e. specifications, menus, hot water requirements?
    Before submitting plans to LUESA Commercial Plan Review, architects, engineers and designers should visit the Department website at or and obtain the minimum submittal criteria to eliminate future omissions of this nature.  Excel documents are also available on the website for calculating the minimum dry food/refrigeration storage and hot water generator sizing requirements. Helpful links:
  • What about communication between the Health Department and designers?
    Open communication is central to us and we welcome any suggestions as to how this might be improved. The program manager can be reached at 704-336-5565.


  • Can you condense the Environmental Health Components on a plan to help expedite the EH review process?
    The DEHNR Regional Environment Health Specialist suggests that before submitting plans, you review the pool plan review checklist and note the sheets/pages where responses would be found.  The Mecklenburg County Environmental Health Plans Examiner requests that plans group all pool information together (i.e. 911 phone, rest rooms, equipment room, and chemical room together on one sheet so the information can be easily found).
  • Clarify the differences between remodel and repair.  When is plan review required?  What if the change is for overall improvement of circulation?
    Plans are required when pipes, hydraulics or pool and/or bottom/slope is/are changed.
  • What qualifies as "light colored" with respect to pool finish?
    N.C. DEHNR uses a "gray scale".  If the value is less than 50% black, it is approved.  A state pool plan review employee makes this determination.
  • What are the requirements concerning decorative features?  
    A 5-feet clear walkway is required.  With respect to "funbrellas," they are decorative features that can be allowed on a pool deck as long as a minimum five feet of clearance remains around one side of the feature.
  • Please comment on the use of skimmers for feature suction.  
    The rules require that suction outlets to pumps other than the recirculation pump shall be provided with two drains with "T" connection piping. Skimmers have not been considered for use since they are only capable of handling 20-30 gpm.
  • Please comment on manufactured gutter systems and required inlet locations.
    The state has rarely had to disapprove a Paddock gutter system; however, the requirement that no part of the pool be more than 25 feet from an inlet does apply to Paddock pools.
  • How do rules apply to islands intended for aesthetic purposes?
    All islands must meet minimum deck requirements, unless the state rules otherwise.
  • What happens if a builder changes some aspect of the chemical storage room, or all specifications not available to pool contractor?
    Chemical storage is expected to meet Pool Rules at the time of final evaluation for issuance of pool permit.
  • How should backwash be handled?
    In Mecklenburg County , the Health Department determines how backwash/discharge to the ground is handled after consulting with other programs, including, but not limited to Water Quality and Groundwater and Wastewater Services.  
  • Discuss the difference(s) between/among an interactive play attraction vs. wading pool vs. swimming pool. 
    Interactive pools that are wading pools (i.e. no more than two feet deep) are required to be fenced separately from deeper swimming pools.  The state has asked for fences at children's activity pools that are a little deeper, but clearly designed for use by children.  Pools that include a swimming area more than three feet deep are not required to have separate fences.  Interactive features on the deck are required to be fenced separately from a swimming pool. The direction of flow is significant. Interactive features included within the perimeter of a swimming pool with zero-depth entry are considered a part of the swimming pool and those that drain separately are not.  Those that are part of the pool are not required to be fenced separately, while those that are separate from the pool are required to be fenced apart from the pool.
  • Explain the appeals process.  
    Any challenge regarding an employee, plan review, interpretation, etc. should always be addressed very systematically. The preference is to satisfactorily address any issue with the initial parties. However, the chain-of-command is necessary to initiate a formal appeal process. Mecklenburg County Environmental Managers desire to be involved before any action is attempted at the state level. The proper chain of command following the initial contact is the supervisor, manager, Health Director, then Regional Environmental Specialist (state).
  • Explain zero entry pools preferences.
    The water must be mixed adequately, this is approved on a case by case basis.  There is a preference to have gutters and returns.
  • Please clarify the swimming pool rope requirement at 24 in. or 3 ft. depth.
    Rope is required to separate the child area from the swimming pool proper.  Environmental Health Plan Review staff suggests also placing anchors at 24 in. depth area if this is before the required anchors at the deeper pool area.

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