International Property Maintenance Code (IPMC) Ground Fault Circuit Interrupter (GFCI) Amendment UpdateCity of Dubuque
City Council
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Copyrighted
October 6, 2025
ITEM TITLE: International Property Maintenance Code (IPMC) Ground
Fault Circuit Interrupter (GFCI) Amendment Update
SUMMARY: City Manager recommending City Council approval of an
ordinance amendment to the property maintenance code
modifying GFCI requirements.
ORDINANCE Amending City Of Dubuque Code Of
Ordinances Title 14 Building And Development, Chapter 1
Building Codes, Article J Property Maintenance Code,
Section 14-1J-2 International Property Maintenance Code
Amendments
SUGGUESTED Receive and File; Motion B; Motion A
DISPOSITION:
ATTACHMENTS:
1. MVM Memo
2. MEMO_IPMC GFCI Amendment Change
3. Property Maintenance Code_08212025
Page 1165 of 1264
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: International Property Maintenance Code Ground Fault Circuit Interrupter
(GFCI) Amendment Update
DATE: September 29, 2025
Interim Housing and Community Development Director Sandi Fowler is recommending
City Council approval of an ordinance amendment to the property maintenance code
modifying GFCI requirements.
On August 15, 2024, the Housing and Community Development Department submitted
a request to amend the International Property Maintenance Code (IPMC) to align its
GFCI requirements with the National Standards for the Physical Inspection of Real
Estate (NSPIRE). NSPIRE is the standard HUD requires for inspections of assisted
housing units, and with those amendments, the IPMC now mirrors NSPIRE.
Following that ordinance change, additional NSPIRE guidance clarified that receptacles
located inside cabinets are not required to be replaced with GFCI receptacles.
In addition, based on feedback from inspectors and landlords, further updates were
requested to:
1. Clarify the definition of "water source" as used in this code section.
2. Define GFCI requirements for laundry appliances.
3. Provide guidance for receptacles located behind refrigerators that are
inaccessible.
Because the state preempts GFCI requirements for 240-volt outlets, that clarification in
the IPMC is also added.
This update does not change National Electrical Code (NEC) requirements for new
construction. It applies only to existing buildings. The intent of the original ordinance
was to ensure that receptacle outlets within six feet of a sink, tub, or shower had GFCI
protection. The original proposed code change was shared with the Dubuque Area
Landlords Association. Their feedback prompted the addition of the clarification for
receptacles located behind refrigerators.
This proposal was taken to the Building Code Advisory and Appeals Board on
September 12, 2025, where the board unanimously supported the proposed change.
Page 1166 of 1264
I concur with the recommendation and respectfully request Mayor and City Council
approval.
v
Mic ael C. Van Milligen
MCVM:sv
Attachment
CC' Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Sandi Fowler, Interim Housing & Community Development Director
Michael Belmont, Assistant Housing and Community Development
Ben Pothoff, Deputy Code Official
Jason Lehman, Assistant City Attorney
I
Page 1167 of 1264
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TO: Michael C. Van Milligen, City Manager
FROM: Sandi Fowler, Interim Housing and Community Development Director
DATE: September 9, 2025
RE: IPMC GFCI Amendment Update
INTRODUCTION
The purpose of this memorandum is to request City Council approval of an ordinance
amendment to the property maintenance code modifying GFCI requirements.
BACKGROUND
On August 15, 2024, our department submitted a request to amend the International
Property Maintenance Code (IPMC) to align its GFCI requirements with the National
Standards for the Physical Inspection of Real Estate (NSPIRE). NSPIRE is the standard
HUD requires for inspections of assisted housing units, and with those amendments,
the IPMC now mirrors NSPIRE.
Following that ordinance change, additional NSPIRE guidance clarified that receptacles
located inside cabinets are not required to be replaced with GFCI receptacles.
In addition, based on feedback from inspectors and landlords, further updates were
requested to:
1. Clarify the definition of "water source" as used in this code section.
2. Define GFCI requirements for laundry appliances.
3. Provide guidance for receptacles located behind refrigerators that are
inaccessible.
Finally, because the state preempts GFCI requirements for 240-volt outlets, we also
seek to add that clarification in the IPMC
DISCUSSION
This update does not change National Electrical Code (NEC) requirements for new
construction. It applies only to existing buildings. The intent of the original ordinance
was to ensure that receptacle outlets within six feet of a sink, tub, or shower had GFCI
protection.
The original proposed code change was shared with the Dubuque Area Landlords
Association. Their feedback prompted the addition of the clarification for receptacles
located behind refrigerators.
Page 1168 of 1264
This proposal was taken to the Building Code Advisory and Appeals Board on
September 12, 2025, where the board unanimously supported the proposed change.
RECOMMENDATION
I respectfully request the City Council approve the amended ordinance adopting these
changes to the International Property Maintenance Code
Prepared By: Michael Belmont, Assistant Housing and Community Development
Director
cc: Ben Pothoff, Deputy Code Official
Crenna Brumwell, City Attorney
Jason Lehman, Assistant City Attorney
2
Page 1169 of 1264
Prepared by: Crenna M. Brumwell, Esq. 300 Main Street Suite 330 Dubuque IA 52001 563 589-4381
ORDINANCE NO. 38- 25
AMENDING CITY OF DUBUQUE CODE OF ORDINANCES TITLE 14 BUILDING AND
DEVELOPMENT, CHAPTER 1 BUILDING CODES, ARTICLE J PROPERTY
MAINTENANCE CODE, SECTION 14-1J-2 INTERNATIONAL PROPERTY
MAINTENANCE CODE AMENDMENTS
NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF
DUBUQUE, IOWA:
Section 1. Section 14-1 J-2 of the City of Dubuque Code of Ordinances is hereby
amended to read as follows:
14-1J-2: INTERNATIONAL PROPERTY MAINTENANCE CODE AMENDMENTS:
The following additions, deletions, modifications, or amendments of the International
Property Maintenance Code, 2021 edition, adopted in section 14-1 J-1 of this article to
read as follows:
Section 605.2. Receptacles. Amended to read:
605.2. Receptacle outlets shall be provided in compliance with this section.
605.2.1 Requirements. Every habitable space in a dwelling shall contain not less
than one receptacle outlet. Every bathroom shall contain not less than one
receptacle outlet. All receptacle outlets shall have the appropriate faceplate cover
for the location.
605.2,2 Personal protection. Every laundry area shall contain not less than one
grounding type receptacle outlet or a receptacle outlet with ground fault circuit
interrupter (GFCI) protection. All receptacle outlets within six feet (6') of a sink,
tub or shower shall have ground fault circuit interrupter (GFCI) protection.
Exceptions: 1. 240 volt receptacle outlets.
2. Receptacle outlets within a cabinet
3. Inaccessible receptacle outlets behind a refrigerator or freezer.
Section 2. This ordinance shall take effect upon publication.
Passed, approved, and adopted this 6th day of October, 2025.
Brad M. �Cav , Mayor
Attest:
Trish L. Gleason, Assistant City Clerk
EFFECT OF AMENDMENT
14-1J-2: INTERNATIONAL PROPERTY MAINTENANCE CODE AMENDMENTS:
The following additions, deletions, modifications, or amendments of the International
Property Maintenance Code, 2021 edition, adopted in section 14-1J-1 of this article to
read as follows:
Section 605.2. Receptables. Amended to read:
605.2. Receptacle outlets shall be Drovided in comDliance with this section.
605.2.1 Requirements. Every habitable space in a dwelling shall contain not less
than one receptacle outlet. Every bathroom shall contain not less than one
receptacle outlet. All receptacle outlets shall have the appropriate faceplate cover
for the location.
605.2.2 Personal protection. Every laundry area shall contain not less than one
grounding type receptacle outlet or a receptacle outlet with ground fault circuit
interrupter (GFCI) protection. All receptacle outlets within six feet (6') of a sink,
tub or shower shall have around fault circuit interrupter (GFCI) Drotection.
Exceptions: 1. 240 volt receptacle outlets.
2. Receptacle outlets within a cabinet.
3. Inaccessible receptacle outlets behind a refrigerator or freezer.
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