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CSI Division 22, MasterFormat

Division 22 Plumbing Closeout Documentation Requirements

Plumbing closeout covers more document types than most GC PMs expect, and the requirements vary by system, jurisdiction, and project type. Here's what you need, why it matters, and what gets rejected.

Quick Reference: What You Need to Collect

Every document required in a Division 22 Plumbing closeout package, including who provides it and when it applies.

Document Applies
Domestic Water Pressure Test Certificate Always
Sanitary/Storm Piping Test Certificate Always
Backflow Preventer Certified Test Report Always
Water Heater Startup/Commissioning Report Always
Water Heater Warranty Registration Confirmation Always
Plumbing Fixtures O&M Manuals Always
Fixture Schedule (As-Built) Always
Medical Gas Purity Test and Verifier Certification Healthcare and clinical projects only
Grease Interceptor Installation Documentation Commercial kitchen projects

Plumbing closeout looks simpler than mechanical or electrical, but it has some of the most jurisdiction-specific requirements of any trade. Backflow preventer testing requirements vary by state and sometimes by municipality. Medical gas documentation requirements are heavily regulated by ASSE and NFPA. Water heater warranty obligations differ by manufacturer and installation type.

As a GC PM, the challenge with Division 22 is that the documents come from multiple parties who don't know they need to coordinate: the plumbing contractor, a licensed cross-connection tester (who is often a separate company), the water heater manufacturer's authorized startup technician, and on healthcare projects, an ASSE 6000-certified medical gas verifier.

Start requesting plumbing closeout documents at rough-in completion, not at the end of the project. Backflow testing and water heater warranty registration have time dependencies that can't be rushed.

Required Deliverables: Detailed

What each document is, why it's required, and what to watch for. Written for the GC PM collecting documents from multiple subs and engineers.

Pressure Test Certificates: Domestic Water

Documentation of hydrostatic pressure testing of the domestic water piping system. Per the International Plumbing Code, new water piping must be tested at not less than the working pressure plus 50 PSI (minimum 100 PSI) for a minimum of 15 minutes. The test must be witnessed and documented.

PM

Pressure test documentation is often performed during rough-in but the paperwork is not retained for closeout. Require your plumbing sub to provide formal test certificates, not just verbal confirmation.

Pressure Test Certificates: Sanitary and Storm Piping

Separate test documentation for sanitary and storm drainage piping. Typically a hydrostatic test or air test per IPC/UPC requirements. Often completed during rough-in but the documentation is not collected for closeout.

PM

Domestic water test certs are usually available; sanitary and storm certs are frequently missing. Ask specifically for all three separately.

Backflow Preventer Certified Test Reports

Each backflow prevention device must be tested at installation by a tester certified under the local jurisdiction's cross-connection control program, typically ASSE 1013 certification. The test report includes the device serial number, test date, tester name and certification number, and pass/fail result.

PM

This test cannot be performed by the plumbing contractor unless they hold the cross-connection tester certification separately. Most plumbers do not. A separate scheduling step is required.

Water Heater Commissioning and Startup Report

For commercial water heaters, most manufacturers require a factory-authorized startup to activate the warranty, particularly for larger storage and instantaneous water heaters. The authorized technician documents the startup parameters, flue gas readings, and setpoint configuration.

Sub

Failure to complete a factory-authorized startup often voids the 10-year warranty and reduces coverage to 1–2 years. Confirm startup requirements with the manufacturer before installation is complete.

Water Heater Warranty Registration

Written confirmation that the water heater warranty has been registered with the manufacturer under the owner's name and project address. Some manufacturers require online registration within 30 days of installation. The confirmation document belongs in the closeout package.

Plumbing Fixtures O&M Manuals

Operations and maintenance documentation for all major plumbing equipment, including faucets, flush valves, mixing valves, water heaters, pumps, pressure-reducing valves, and other specialty items. Should reference the specific model numbers installed, not generic categories.

Fixture Schedule (As-Built)

Updated fixture schedule reflecting what was actually installed, including manufacturer, model, finish, and location. If substitutions were made from the specified products, the approved substitution documentation should be attached.

PM

A schedule that lists the specified products but not the installed products is not an as-built; it's the design documents. Confirm the schedule reflects what was actually installed.

Medical Gas Documentation (Healthcare Projects)

For projects with medical gas systems, NFPA 99 and ASSE 6000 require verification by a certified and independent medical gas verifier. Required documentation includes: gas purity test results by outlet, system pressure test results, zone valve operation, alarm system test, and the verifier's ASSE 6000 Level 4 certification. The verifier must be completely independent from the installing contractor.

PM

Medical gas documentation is among the most strictly regulated in commercial construction. ASSE 6000 Level 4 verifiers are rare; schedule them months in advance on healthcare projects.

Governing Standards

The codes and standards that define what's required in a Division 22 Plumbing closeout package. Reference these when an owner or architect pushes back.

IPC (2021) International Plumbing Code

Primary plumbing code adopted in most jurisdictions. Chapter 3 governs general regulations and testing requirements.

UPC (2021) Uniform Plumbing Code

Alternative to IPC, adopted in California and other western states. Different testing procedures apply; confirm which code your jurisdiction uses.

ASSE 1013 Reduced Pressure Principle Backflow Preventers

Performance standard for RPZ backflow preventers. Local cross-connection control programs reference ASSE standards for tester certification.

ASSE 6000 (2020) Professional Qualifications Standard for Medical Gas Systems Personnel

Establishes the certification levels for personnel installing, inspecting, testing, and verifying medical gas systems. Level 4 verification is required at project completion.

NFPA 99 (2021) Health Care Facilities Code

Governs medical gas system installation and verification requirements in healthcare settings.

Why Division 22 Packages Get Rejected

These are the specific issues that cause owner rejection, AHJ refusal, or retainage holds. Each one is documented with the root cause and how to prevent it.

Backflow preventer test performed by uncertified tester

Local cross-connection control ordinances require backflow testing by a tester certified under the local program, not just any licensed plumber. Certifications are typically issued by the local water purveyor or state agency and are separate from the plumber's license. A test performed by someone without the cross-connection tester credential must be redone.

PM

Ask for the tester's certification number on the test report. Verify it against your local water purveyor's certified tester list; many publish this list online.

Sub

Do not attempt to perform backflow testing unless you hold the specific cross-connection tester certification for the jurisdiction. Schedule a licensed tester as part of your closeout plan.

Water heater warranty voided by lack of authorized startup

Commercial water heater manufacturers including A.O. Smith, Bradford White, Rheem, and others require factory-authorized startup to activate the extended warranty. Without this, the warranty defaults to the standard 1-year labor and materials warranty, or may be voided entirely. The owner will ask when they have a water heater failure in year 2.

PM

Before submitting closeout, confirm that all commercial water heaters had authorized startup. Ask your plumbing sub: 'Is the 10-year warranty active on all water heaters?' If they can't answer with documentation, it may not be.

Pressure test certificates only cover domestic water, sanitary and storm missing

GC PMs often ask for pressure test documentation and receive the domestic water test cert. Sanitary and storm piping is tested separately during rough-in and the documentation is frequently not retained. Owners expect all piping system test results in the package.

PM

Request test certs for all three systems separately: domestic water, sanitary, storm. Do this at rough-in completion, not at project end; the plumber is much more likely to have the paperwork current.

Fixture schedule reflects specified products, not installed products

If the plumbing contractor submitted an as-built fixture schedule that lists the original specifications rather than what was installed, it is not an as-built document. Any substitutions made during construction, approved or otherwise, must be reflected with the installed product's information.

PM

Compare the fixture schedule to the submittals. If any submittal was for a substituted product, the fixture schedule should list the substitute.

Medical gas verifier not independent from installing contractor

ASSE 6000 Level 4 verification requires the verifier to be independent from the installing contractor. A verifier employed by or affiliated with the medical gas installer does not satisfy this requirement. The verification must be redone by a truly independent verifier.

PM

On healthcare projects, establish the medical gas verifier as a separate contract with a firm completely independent from your medical gas sub before construction begins.

Relevant CSI Spec Sections

The MasterFormat specification sections that govern Division 22 Plumbing closeout. Pull these from the project spec to confirm exact requirements for your project.

22 0800
Commissioning of Plumbing Systems

Governs commissioning scope, testing requirements, and documentation deliverables for plumbing systems.

22 1113
Facility Water Distribution Piping

Installation and testing requirements for domestic water distribution.

22 1313
Facility Sanitary Sewerage

Sanitary drainage system requirements including testing.

22 3400
Fuel-Fired Domestic Water Heaters

Water heater installation requirements including startup and commissioning documentation.

Closeout Checklist: Division 22 Plumbing

Use this checklist when collecting documents from your subs and engineer. Print or save as PDF for your project files.

Piping System Testing

Backflow Prevention

Water Heating Equipment

Fixtures and Equipment

Medical Gas (Healthcare Projects)

Pro Tips: What Experienced PMs Do Differently

The things that don't appear in the spec but that experienced GC PMs know from hard experience. These are the insights worth sharing.

Schedule the backflow tester before the plumbing final inspection, not after.

Many jurisdictions require the backflow test report as part of the plumbing inspection sign-off. If you wait until after the inspector visits to schedule the tester, you'll have to schedule a re-inspection. Some jurisdictions have 4–6 week inspection backlogs.

Water heater authorized startup must happen before the building is occupied, not after.

Once the building is occupied and the water heater is in service, many manufacturers will no longer honor the startup requirement or will only offer a reduced warranty period. The startup window is typically within 30–60 days of installation, before the unit is put into full service.

Jurisdiction-specific backflow certification requirements are not standardized.

ASSE certification is a national standard, but your local water purveyor may require their own program-specific certification in addition to or instead of ASSE. Call your local water utility before scheduling the tester to confirm what credentials they accept.

Frequently Asked Questions

Questions GC PMs and subcontractors ask most often about Division 22 Plumbing closeout.

Who pays for the backflow preventer test: the owner or the contractor?
In most commercial contracts, the backflow test is included in the plumbing contractor's scope at acceptance. Ongoing annual testing (required by most jurisdictions after the first year) is typically the owner's responsibility. Confirm the contract scope, and make sure your subs understand what's included.
What if we installed different fixtures than what was specified?
Approved substitutions should have accompanying RFI or submittal approval documentation. If a substitution was made without formal approval, that's a contractual issue separate from closeout. For closeout purposes, document what was installed and include any approval documentation you have.
We don't have medical gas on this project. Is there anything special for domestic water only?
For a project without medical gas, the main Division 22 closeout focus is pressure test certs (all three systems), backflow testing, water heater commissioning, and equipment O&M manuals. No ASSE 6000 verifier is required; that's specific to medical gas systems.
Can the plumbing contractor self-certify the backflow preventer test?
No. Cross-connection control testing requires a separately certified tester; the plumbing license alone is not sufficient in virtually any jurisdiction. Some plumbers hold both licenses, but you must verify that on the test report by checking their cross-connection tester certification number.

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