A Pool Remodel Permit Quietly Requires a Suction-Outlet Upgrade
The resurfacing scope says plaster and tile. The permit itself says upgrade the suction outlets to antientrapment grates.
You're bidding a pool resurface. The scope is plaster and tile — maybe new coping, a fresh waterline. Nothing about the plumbing. So the estimate covers surface prep, materials, and labor, and everyone moves on.
Then the permit comes back with a line about the suction outlets.
Here's the thing: in California, that line isn't the plan checker freelancing. It's Health & Safety Code §115928.5, and it attaches the requirement to the permit, not to the scope of your work. Pull a building permit to remodel or modify an existing pool, and the suction outlets come up for a mandatory upgrade — even if your crew never touches the plumbing.
Verified against the statutory text reprinted in CRC Appendix CI (HSC §115928.5, §115928, §115921), 2025 edition effective January 1, 2026.
What §115928.5 actually says
The section is short and blunt. “Whenever a building permit is issued for the remodel or modification of an existing swimming pool, toddler pool or spa, the permit shall require that the suction outlet or suction outlets … be upgraded so as to be equipped with antientrapment grates, as specified in the ANSI/APSP-16 performance standard” — or a successor standard designated by the federal Consumer Product Safety Commission.
Read the trigger carefully. It's “whenever a building permit is issued for the remodel or modification” — not “whenever the plumbing is altered.” The permit is the switch. That's why a resurfacing job with no drain work can still carry the grate requirement, and it's why the section names toddler pools and spas right alongside full-size pools.
It's not the new-pool rule, and it's not the barrier menu
Two neighbors in the same appendix get confused with this one.
§115928 governs new pools and spas — that's where you find the two-circulation-outlets-per-pump rule and the requirement that new suction outlets carry antientrapment grates. §115928.5 is the retrofit cousin: it reaches into an existing pool the moment a remodel permit issues.
And it is not the “two of seven drowning-prevention features” menu — that's §115922, the enclosure-and-alarms side of the Act, which we covered in the above-ground pool barrier post. A remodel can trigger both sections at once, but they're separate requirements pointing at different hardware. This one is about what's at the bottom of the pool, not the fence around it.
What the grate requirement means on the ground
The Act defines a “suction outlet” as “a fitting or fixture typically located at the bottom or on the sides of a swimming pool that conducts water to a recirculating pump” — your main drains, in plain terms. The upgrade swaps older or non-compliant covers for grates designed, in the statute's words, to “prevent physical entrapment” and avoid a suction hazard to bathers. The ANSI/APSP-16 standard the section names is the American National Standard for suction outlet fitting assemblies; its current edition is published as ANSI/APSP/ICC-16. The Act defines an ANSI/APSP standard as one accredited by ANSI and published by the pool-and-spa professionals' association.
Practically, that's a real line on the bid — the grates themselves plus the labor to pull and reset the outlet covers. Discovering the requirement at final, after the plaster's cured, is the expensive way to learn it.
This isn't a 2026 surprise
The suction-outlet upgrade is not new. §115928.5 was amended by AB 2114 (Stats. 2012, ch. 679), effective January 1, 2013 — and the word amended tells you the requirement was already on the books before then. What's new is only the packaging: the 2025 California Residential Code reprints the whole Swimming Pool Safety Act (HSC §§115920–115929) as mandatory text in Appendix CI, effective January 1, 2026 — so the requirement now sits in the code book a plan checker actually opens.
One caveat worth stating on anything touching safety hardware: the appendix itself notes these provisions are subject to local government modification, and advises verifying local requirements when you apply for a permit. Whether a given resurface is treated as a “remodel or modification” is a call your building department makes — so confirm before you finalize the bid. This isn't legal advice; it's where to look.
What CrossBeam does with it
CrossBeam reads a pool permit's scope and flags when a remodel or modification pulls in the §115928.5 suction-outlet upgrade, so the antientrapment grates land in the estimate instead of at final inspection. It's the kind of permit-triggered requirement that's easy to miss when the drawings show nothing but plaster and tile.