1312.4 .1(Mechanical Code) - Shutoff valves may be accessibly located inside or under an appliance when such appliance can be removed without removal of the shutoff valve.
It is commonly interpretted by my plumber, and the inspectors that he has come accross, that a gas valve for a range needs to be in the adjacent cabinet. Most range and dryer manufacturers specify locations for gas supply locations behind their units. A dryer with a countertop over it is a harder nut to crack. In my book these appliances can be removed "without removal of the shutoff valve" if there is a long enough flex line. A person that could not wrestle a free standing range out would probably also not be able to get down into the back of a cabinet to the shutoff valve. How many typical homeowners would remember that it is there? Do ranges fail and need a quick shut off to extinguish a fire? Maybe a dryer would. I am not sure that I like this stringent interpretation of this code.
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Kelowna Residential
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Kelowna Interior Design