Report on First Revision June 2014 NFPA 101

Transcription

1 101- Log #62 SAF-BSF Final Action: (9.2.3) Submitter: Doug Hohbein, Northcentral Regional Fire Code Development Committee Recommendation: Revise to read: Commercial Cooking Equipment Operations. Unless prohibited by Chapters 11 through 43, commercial cooking equipment operations shall be in accordance with NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations, unless such installations are approved existing installations, which shall be permitted to be continued in service The requirements of shall be met unless such installations are approved existing installations, which shall be permitted to be continued in service. Substantiation: The word Equipment should be replaced with Operations as NFPA 96 applies to commercial and residential cooking equipment. The phrase Unless prohibited by Chapters 11 through 43 is needed as Chapters 18/19 alter the requirements of and chapter 24 does not apply; as written, is mandatory language applicable to all occupancies. The last stipulation in is an exception and should be placed in a separate paragraph per the MOS. The Code is not currently formatted to prohibit the use of Rather, other sections of the Code specify when compliance with is required. Also see First Revision 101- Log #FR600 (FR 1-NFPA ) Log #348 SAF-BSF Final Action: (9.2.4) Submitter: Chad E. Beebe, ASHE - AHA Recommendation: Revise to read: Ventilating Systems in Laboratories Using Chemicals. Ventilating systems in laboratories using chemicals shall be in accordance with NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, or NFPA 99, Health Care Facilities Code, as appropriate. Substantiation: There is no longer any need to reference NFPA 45 and NFPA 99, The requirements for ventilation of laboratories have been removed from NFPA 99, and users are directed to NFPA 45. " Ventilating Systems in Laboratories Using Chemicals. Ventilating systems in laboratories using chemicals shall be in accordance with NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals. [101:9.2.4]" See First Revision 101- Log #FR631 (FR 2-NFPA ) which incorporates the suggested revision. 1

2 101- Log #325 SAF-BSF Final Action: (9.5) Submitter: Sharon S. Gilyeat, Koffel Associates, Inc. Recommendation: Revise text: 9.5 Rubbish Chutes, Incinerators, and Laundry Chutes Enclosure. Installation and Maintenance. Waste chutes, linen chutes, and incinerators shall be installed and maintained in accordance with NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment, unless such installations are approved existing installations Rubbish chutes and laundry chutes All new waste chutes and linen chutes shall be separately enclosed by walls or partitions in accordance with the provisions of NFPA 82 and Section Inlet openings All new iintake openings serving chutes shall be protected in accordance with NFPA 82 and Section The All new doors of chutes specified in shall open only to a room that is designed and used exclusively for accessing the chute opening The room All new rooms used for accessing the chute opening shall be separated from other spaces in accordance with NFPA 82 and Section The requirements of through shall not apply where otherwise permitted by the following: Existing installations having properly enclosed service chutes and properly installed and maintained service maintained intake openings shall be permitted to have inlets open to a corridor or normally occupied space Rubbish and laundry Waste chutes and linen chutes shall be permitted to open into rooms not exceeding 400 ft 2 (37 m 2 ) that are used for storage, provided that the room is protected by automatic sprinklers Installation and Maintenance. Rubbish chutes, laundry chutes, and incinerators shall be installed and maintained in accordance with NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment, unless such installations are approved existing installations, which shall be permitted to be continued in service. Substantiation: The proposed changes are made to eliminate any conflicts with NFPA 82, to make the terminology standard between the 101 and 82, and to relocate the most significant requirement in the section to the top position. NFPA 101 should start out saying that the design and maintenance shall be in accordance with NFPA 82 and then make changes as required for existing or new if necessary. The only technical change made in the revisions recommended was to eliminate the requirement for new intake rooms to be rated in accordance with 8.7. This would allow a nonrated sprinklered intake room which would contradict NFPA 82. Because most jurisdictions and designers rely on NFPA 82, the protection of these rooms should not be diminished below the requirements in NFPA 82. NFPA 82 now only requires 1-hr intake rooms if sprinkler protected. Several of the proposed revisions appear to be redundant. The proposed use of the term 'all new' throughout the section is inconsistent with the formatting of the remainder of Chapter 9. See First Revision 101- Log #FR607 (FR 4-NFPA ) for terminology revisions for consistency with NFPA 82. 2

3 101- Log #350 SAF-BSF Final Action: (9.5) Submitter: Joshua Elvove, U.S. General Services Administration Recommendation: *** Include 101_L350_Rec PI #289 *** Substantiation: The purpose of this public input is to make the requirements for chutes contained in NFPA 101 in concert with NFPA 82, which is the governing NFPA standard for chutes. NFPA 101 does not specifically identify requirements for chute discharge rooms and service opening rooms; instead it contains requirements for "inlet openings," a term not recognized by NFPA 82. NFPA 101 also lumps both the chute discharge and service opening rooms under a single requirement ( ) when NFPA 82 treats them differently. I recognize this adds more stringent requirements to NFPA 101, most notably for service opening rooms, but localities that enforce both NFPA 101 and 82 already need to invoke these more stringent requirements so they should be incorporated herein. Note: these requirements are only meant to apply to new construction, hence, the provisions in and through that maintain a number of exceptions for existing chute installations open to the corridor and non-rated service opening rooms as well as an exception for permitting storage in sprinklered service opening and chute discharge rooms that are under 400 sqft. I did not provide exceptions for the enclosure requirements for existing chute discharge rooms given the high risk that chute discharge doors (i.e., those doors at the bottom of the chute that are supposed to close upon activation of the fusible link) will fail to close. If the committee feels that all the changes suggested are too much to implement, especially on a retroactive basis, I encourage the committee to consider some of my suggested changes so the room terminology within the section correlates better with NFPA 82. From NFPA Chute Discharge Rooms General Waste and linen chutes shall terminate or discharge directly into a room having a minimum fire resistance rating not less than that specified for the chute Openings into such a room or compartment shall be protected by approved self-closing fire doors having a minimum fire protection rating not less than specified for the chute Service Opening Rooms General Every service opening shall be in a room or compartment that is separated from the other parts of the building by walls, partitions, floors, and floor-ceiling assemblies having a fire resistance rating of not less than the required rating of the chute enclosure Where service opening rooms are protected by automatic sprinklers, the room shall be enclosed in a minimum of 1-hour construction, and openings shall be protected with 3 4-hour fire-rated doors Openings into such a room or compartment shall be protected by approved self-closing doors that are appropriate for protecting the openings or are of not less than a 1 hour partition rating with a 3 4-hour fire-rated door The size of the service opening room or compartment shall not be less than that required to maintain a minimum mm (6 in.) clearance between the intake opening and the closed service opening room door. The proposed revisions appear to be redundant with NFPA 82 requirements. Alternative approaches might be to extract requirements from NFPA 82 or replace the NFPA 101 requirements with a reference to NFPA 82. Also see 101- Log #FR607 (FR-4 NFPA ). 3

4 9.5 Rubbish Chutes, Incinerators, and Laundry Chutes Enclosure1 Chute Enclosure Rubbish chutes and laundry chutes shall be separately enclosed by walls or partitions in accordance with the provisions of Section Chute Discharge Room Inlet openings serving chutes shall be protected in accordance with Section 8.3 Chutes shall terminate or discharge directly into a chute discharge room used exclusively for accessing the bottom of the chute The chute discharge room shall be separated from other spaces by construction having the same fire resistance rating as the chute enclosure The fire protection rating for openings into chute discharge rooms shall be commensurate for what is required for the chute enclosure The doors of chutes specified in shall open only to a room that is designed and used exclusively for accessing the chute opening 2.4 Existing chute discharge rooms shall be permitted to be used for storage, provided the room does not exceed 400 ft 2 (37 m 2 ) and the room is protected by automatic sprinklers Service Opening Rooms Service opening rooms shall provide access to the chute and be used exclusive for accessing the chute intake doors The room used for accessing the chute opening 3.2 Service opening rooms shall be separated from other spaces by construction having the same fire resistance rating as the chute enclosure Service opening rooms that are sprinkler protected in accordance with Section 9.7 shall be permitted to separated from other spaces by a one hour fire resistance rating The requirements of 3.4 The fire protection rating for openings into service opening rooms shall be commensurate for what is required for the chute enclosure through shall not apply where otherwise permitted by the following: Existing installations having properly enclosed service chutes and properly installed and maintained service openings shall be permitted to have inlets 3.5 The fire protection rating for openings into service opening rooms that are sprinklered in accordance with Section 9.7 shall be permitted to be ¾ hour Existing installations having chutes enclosed in accordance with and service openings that are installed and maintained in accordance with NFPA 82 shall be permitted to have service openings open to a corridor or normally occupied space. Rubbish chutes and laundry chutes shall be permitted to open into rooms not exceeding Existing service opening rooms serving chutes enclosed in accordance with shall be permitted in service opening rooms that meet the requirements of Section Log 350 Rec from Terra PI #289

5 Existing service opening rooms shall be permitted to be used for storage, provided the room does not exceed 400 ft 2 (37 m 2 ) that are used for storage, provided that the and the room is protected by automatic sprinklers Installation 4 Installation and Maintenance. Rubbish chutes, laundry chutes, and incinerators shall be installed and maintained in accordance with NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment, unless such installations are approved existing installations, which shall be permitted to be continued in service. 101 Log 350 Rec from Terra PI #289

6 101- Log #250 SAF-BSF Final Action: ( (2)) Submitter: Scott J. Harrison, Marioff Inc. Recommendation: Revise text to read as follows: (2) Rubbish chutes and laundry chutes shall be permitted to open into rooms not exceeding 400 ft 2 (37 m 2 ) that are used for storage, provided that the room is protected by automatic sprinklers or water mist systems. Substantiation: Water Mist systems have been approved and installed in many sprinkler applications globally for over 15 years. They have been listed by national and internationally recognized testing laboratories such as: UL (Ordinary Hazard Group 1), FM (Light Hazard Occupancies, Computer Rooms, Subfloors, Special Hazard Machinery & spaces), City of New York (Light Hazard Occupancies, Combustion Turbines, Machinery Spaces), VdS Germany (Light Hazard, Ord Haz Grp I,II parking garages & III selected occupancies, Cable Tunnels), KfV Austria (Light Hazard, Ord Haz Grp I, Combustion Turbines) and other agencies. These listings and installations have demonstrated equivalent fire protection to the authority having jurisdiction (AHJ). The addition of the proposed text will provide the AHJ a clear option to accept water mist systems as equivalent to an approved automatic sprinkler system where the application is listed or approved, thereby allowing construction alternatives without having to prove equivalency or be considered an alternative extinguishing system. The Code already permits the use of alternative systems in There is no need to single out water mist systems, other systems are specified by Table for certain applications Log #351 SAF-BSF Final Action: (9.5.5, , , , , and 9.5.2) Submitter: Joshua Elvove, U.S. General Services Administration Recommendation: Revise to read: Rubbish Waste Chutes, Incinerators, and Laundry Chutes Enclosure Rubbish Waste chutes and laundry chutes shall be separately enclosed by walls or partitions in accordance with the provisions of Section Inlet openings serving chutes Chute intake doors shall be protected in accordance with Section The room used for accessing the chute opening Chute service opening rooms shall be separated from other spaces in accordance with Section The requirements of through shall not apply where otherwise permitted by the following: (1) Existing installations having properly enclosed service chutes and properly installed and maintained service openings shall chute intake doors shall be permitted to have inlets chute intake doors open to a corridor or normally occupied space. (2) Rubbish Waste chutes and laundry chutes shall be permitted to open into rooms not exceeding 400 ft 2 (37 m 2 ) that are used for storage, provided that the room is protected by automatic sprinklers Installation and Maintenance. Rubbish Waste chutes, laundry chutes, and incinerators shall be installed and maintained in accordance with NFPA 82, Standard on Incinerators and Waste and Linen Handling Systems and Equipment, unless such installations are approved existing installations, which shall be permitted to be continued in service. Substantiation: To be consistent with language in NFPA 82. NFPA 82 uses the term waste (and trash ) and doesn t use the term rubbish. NFPA 82 uses the term chute intake doors for accessing chutes. NFPA 82 uses the term Service opening rooms for those rooms that serve to access the chute (i.e., that house the chute intake doors ). Note: if this is to be accepted (or accepted in principle), suggest forwarding this to all the occupancy chapters so they can make similar changes. See First Revision 101- Log #FR607 (FR 4-NFPA ) which incorporates the suggested revisions. 4

7 101- Log #380 SAF-BSF Final Action: ( ) Submitter: William E. Koffel, Koffel Associates, Inc. Recommendation: Revise to read: * Where a required fire alarm system is out of service for more than 4 hours in a 24-hour period, the authority having jurisdiction shall be notified, and the building shall be evacuated, or an approved fire watch shall be provided for all parties left unprotected by the shutdown until the fire alarm system has been returned to service. Fire alarm system impairment procedures shall comply with NFPA 72, National Fire Alarm and Signaling Code. Substantiation: A similar change was made last cycle to Paragraph regarding sprinkler systems. The intent is to refer to the reference standard, in this case NFPA 72, to identify when impairment procedures need to be implemented and what procedures are to be implemented. See First Revision 101- Log #FR609 (FR 7-NFPA ) which incorporates the suggested revision. 5

8 101- Log #172 SAF-BSF Final Action: ( ) Submitter: Peter A. Larrimer, US Department of Veterans Affairs Recommendation: Delete text: Protection of Fire Alarm System * In areas that are not continuously occupied, and unless otherwise permitted by or , automatic smoke detection shall be installed to provide notification of fire at the following locations: (1 )Each fire alarm control unit (2) Notification appliance circuit power extenders (3) Supervising station transmitting equipment The provisions of (2) and (3) shall not apply to existing alarm systems Where ambient conditions prohibit installation of a smoke detector, a heat detector shall be used. Substantiation: This change will remove the retroactive requirement to install a smoke detector (or a heat detector) above an existing fire alarm control unit since the installation of that detector may not have originally been required by the installation standard and there is no reason to retroactively requrie a detector above an existing control unit. If the installation standard required it at the time of installation, then the detector should be there. Section requires fire alarm systems to be installed in accordance with NFPA 72 unless it is an approved existing system. NFPA 72 has not always required protection of the fire alarm system to be provided. For instance, the 2007 Edition of NFPA 72 allowed the sprinkler exception as follows: NFPA 72 (2007): 4.4.5* Protection of Fire Alarm System. In areas that are not continuously occupied, automatic smoke detection shall be provided at the location of each fire alarm control unit(s), notification appliance circuit power extenders, and supervising station transmitting equipment to provide notification of fire at that location. Exception No. 1: Where ambient conditions prohibit installation of automatic smoke detection, automatic heat detection shall be permitted. Exception No. 2: Fully sprinklered buildings shall not require protection in accordance with In addition, prior to the 2007 Edition, the requirement to protect the notification appliance circuit power extenders and supervising station transmitting equipment was not included in NFPA 72. Since all new systems will have to meet the requirements of NFPA 72 and approved existing installations don t, this will eliminated the need to extract this material from NFPA 72. In addition, the only reason that reads the way it does is that the fire alarm code can t mandate any device to protect itself other than fire alarm devices. It is hard to understand why the Life Safety Code would want to permit one heat detector to protect the fire alarm system when the Life Safety Code could use a room full of heat detectors with water behind them (known as sprinklers) to actually protected the unit and initiate the signal. Acceptance of this proposal would also be in line with the retroactivity clause of NFPA 72 that reads as follows: 1.4 Retroactivity Unless otherwise noted, it is not intended that the provisions of this document be applied to facilities, equipment, structures, or installations that were existing or approved for construction or installation prior to the effective date of the document In those cases where it is determined by the authority having jurisdiction that the existing situation involves a distinct hazard to life or property, retroactive application of the provisions of this document shall be permitted. Note that it is also the intent to delete the annex note associate with this section. See First Revision 101- Log #FR608 (FR 9-NFPA ) which incorporates the suggested revision. 6

9 101- Log #146 SAF-BSF Final Action: ( ) Submitter: Vince Baclawski, National Electrical Manufacturers Association (NEMA) Recommendation: Revise to read: Where required by another section of this Code, single-station and multiple-station smoke alarms shall be in accordance with NFPA 72, National Fire Alarm and Signaling Code, unless otherwise provided in , , or , or Substantiation: This proposal is intended to reduce nuisance alarms attributed to locating smoke alarms or smoke detectors in close proximity to cooking appliances and bathrooms in which steam is produced. The proposed provisions are based on the findings in the Task Group Report - Minimum Performance Requirements for Smoke Alarm Detection Technology - February 22, 2008 and are consistent with similar requirements included in the 2010 edition of NFPA 72. Section already requires smoke alarms to be installed in accordance with NFPA 72, which theoretically describes where alarms should and should not be installed. As a convenience to the code user, requirements on where smoke alarms should not be installed in proximity to permanently installed cooking appliances and steam producing bathrooms will be included in this section. See First Revision 101- Log #FR615 (FR-12-NFPA ) which incorporates the suggested revision Log #259 SAF-BSF Final Action: ( ) Submitter: Wayne D. Moore, Hughes Associates, Inc. Recommendation: Add a new as follows: Smoke alarms shall not be used as a substitute for automatic smoke detection where required by Chapters 11 through 43. Substantiation: There continues to misapplication of installers and architects using smoke alarms as a cheaper version of monitored smoke detection. Smoke alarms are designed for residential applications specifically to awaken those in a bedroom of a 1-2 family home of the sleeping room of any of the other residential occupancies. There are being misapplied in corridors and other locations. See First Revision 101- Log #FR615 (FR-12-NFPA ) which incorporates the suggested revision. 7

10 101- Log #146a SAF-BSF Final Action: ( and (New) ) Submitter: Vince Baclawski, National Electrical Manufacturers Association (NEMA) Recommendation: Add new section to read: Smoke alarms shall comply with the following requirements: 1.Smoke alarms installed between 10 ft and 20 ft of a stationary or fixed cooking appliance shall be photoelectric technology or be ionization technology equipped with an alarm-silencing means. 2.Smoke alarms shall not be installed less than 10 ft from a permanently installed cooking appliance. 3.Photoelectric smoke alarms shall be allowed to be installed between 6 feet and 10 feet of a permanently installed cooking appliance when the 10 ft area of exclusion would prohibit the placement of a smoke alarm required by other sections of the code Smoke alarms shall not be installed within a 3 feet from a door to a bathroom that contains a shower or tub. Renumber to Substantiation: This proposal is intended to reduce nuisance alarms attributed to locating smoke alarms or smoke detectors in close proximity to cooking appliances and bathrooms in which steam is produced. The proposed provisions are based on the findings in the Task Group Report - Minimum Performance Requirements for Smoke Alarm Detection Technology - February 22, 2008 and are consistent with similar requirements included in the 2010 edition of NFPA 72. Section already requires smoke alarms to be installed in accordance with NFPA 72, which theoretically describes where alarms should and should not be installed. As a convenience to the code user, requirements on where smoke alarms should not be installed in proximity to permanently installed cooking appliances and steam producing bathrooms will be included in this section. See First Revisions 101- Log #FR615 (FR-12-NFPA ) and 101- Log #FR632 (FR-30-NFPA ) which incorporate the PI by extracting applicable text from NFPA Log #298 SAF-BSF Final Action: ( ) Submitter: Wayne D. Moore, Hughes Assoc., Inc. Recommendation: Add a New to read as follows: Smoke alarms shall not be used as a substitute for automatic smoke detection where required by Chapters 11 through 43. Substantiation: There continues to misapplication of installers and architects using smoke alarms as a cheaper version of smoke detection. Smoke alarms are designed for residential applications specifically to awaken those in a bedroom of a 1-2 family home of the sleeping room of any of the other residential occupancies. There are being misapplied in corridors and other locations. See First Revision 101- Log #FR614 (FR-13-NFPA ), which deletes

11 101- Log #251 SAF-BSF Final Action: ( ) Submitter: Scott J. Harrison, Marioff Inc. Recommendation: Add text to read as follows: Where the building is protected by a water mist system in accordance with , and table , the area of the fire alarm zone shall be permitted to coincide with the allowable area of the water mist system. Substantiation: Water Mist systems are installed in equivalent sprinkler applications. Water mist sprinkler heads are spaced in similar areas of protection configurations. The fire alarm zone should be monitoring the same protection area as the mist system coverage just as with a sprinkler system. This is not original material; its reference/source is as follows: Some text was extracted from NFPA 101 paragraph See First Revision 101- Log #FR633 (FR-23-NFPA ) which incorporates the suggested revision Log #252 SAF-BSF Final Action: ( ) Submitter: Scott J. Harrison, Marioff Inc. Recommendation: Add new text to read as follows: Unless otherwise prohibited elsewhere in this Code, where a building not exceeding four stories in height is protected by an automatic water mist system in accordance with 9.7.3, the water mist system shall be permitted to be annunciated on the fire alarm system as a single zone. Substantiation: Water Mist systems are installed in equivalent sprinkler applications. Water mist sprinkler heads are spaced in similar areas of protection configurations. The fire alarm zone should be monitoring the same protection area as the mist system coverage just as with a sprinkler system. This is not original material; its reference/source is as follows: Some text was extracted from NFPA 101 paragraph See First Revision 101- Log #FR606 which incorporates the suggested revision Log #253 SAF-BSF Final Action: ( ) Submitter: Scott J. Harrison, Marioff Inc. Recommendation: Add new text to read as follows: Where the building is protected by an automatic sprinkler or water mist system in accordance with 9.7 the sprinkler or water mist system shall be permitted to be annunciated on the fire alarm system as a single zone. Substantiation: Water Mist systems are installed in equivalent sprinkler applications. Water mist sprinkler heads are spaced to protect the same areas as sprinkler systems. Where a water mist system is installed in lieu of an automatic sprinkler system, it should be annunciated on the fire alarm system in the same manner as a sprinkler system. This is not original material; its reference/source is as follows: Some text was extracted from NFPA 101 paragraph The language on which the PI is based ( and ) is limited to residential sprinkler systems in accordance with NFPA 13R and NFPA 13D. The source language recognizes "birdcage" designs in which it is impractical to annunciate sprinkler water flow on a floor-by-floor basis. No substantiation was provided to support that such designs are applicable to water mist systems. 9

12 101- Log #471 SAF-BSF Final Action: ( ) Submitter: Jeffrey M. Hugo, National Fire Sprinkler Association, Inc. Recommendation: Revise to read: Sprinkler piping serving not more than six sprinklers for any isolated hazardous area shall be permitted to be connected directly to a domestic water supply system having a capacity sufficient to provide 0.15 gpm/ft 2 (6.1 mm/min) throughout the entire enclosed area or assembly. An indicating shutoff valve, supervised in accordance with or NFPA 13, Standard for the Installation of Sprinkler Systems, shall be installed in an accessible, visible location between the sprinklers and the connection to the domestic water supply. Substantiation: The concept of an isolated hazardous area has not been defined in the Code. The use of the term hazardous area, as defined by section clarifies that the user can protect any hazardous area with a maximum of six sprinklers from the domestic system. The Code has been interpreted as only allowing those hazardous areas listed in the X sections of the occupancy chapters to use the connection to the domestic system. Acceptance of this proposal will clarify that this provision is not limited to the hazards listed in X Any partial sprinkler system, including one protecting windows or walls should be permitted to be connected to the domestic system as long as it meets the requirements of See First Revision 101- Log #FR612 (FR-32-NFPA ) which deletes the term 'isolated' as proposed, but does not add the term 'or assembly' as it is not the Code's intent to permit such installations for the protection of windows or wall assemblies Log #245 SAF-BSF Final Action: ( ) Submitter: Scott J. Harrison, Marioff Inc. Recommendation: Add text to read as follows: (New) Automatic water mist systems designed and installed according to NFPA 750 to make use of an alternative permitted by this Code shall be considered required systems and shall meet the provisions of this Code that apply to required systems. Substantiation: Water Mist systems have been approved and installed in many sprinkler applications globally for over 15 years. They have been listed by national and internationally recognized testing laboratories such as: UL (Ordinary Hazard Group 1), FM (Light Hazard Occupancies, Computer Rooms, Subfloors, Special Hazard Machinery & spaces), City of New York (Light Hazard Occupancies, Combustion Turbines, Machinery Spaces), VdS Germany (Light Hazard, Ord Haz Grp I,II parking garages & III selected occupancies, Cable Tunnels), KfV Austria (Light Hazard, Ord Haz Grp I, Combustion Turbines) and other agencies. These listings and installations have demonstrated equivalent fire protection to the authority having jurisdiction (AHJ). The addition of the proposed text will provide the AHJ a clear option to accept water mist systems as equivalent to an approved automatic sprinkler system where the application is listed or approved, thereby allowing construction alternatives without having to prove equivalency or be considered an alternative extinguishing system. This is not original material; its reference/source is as follows: Some text was extracted from NFPA 101 paragraph The Code does not contain alternatives based on the installation of water mist systems. 10

13 101- Log #34 SAF-BSF Final Action: ( ) NOTE: This proposal appeared as Comment (Log #248) which was held from the A11 ROC on Proposal a. Submitter: Ignatius Kapalczynski, CT Office of State Fire Marshal Recommendation: Reconsider. Substantiation: Alternative fire suppression systems are generally provided for one of two reasons: 1) for the protection of equipment that is sensitive to damage by water 2) for fires adversely affected by the application of water The first condition is not a life safety concern and should not be a consideration. The second condition is addressed by other standards. Adding clarifies protected throughout an approved sprinkler system. Protected throughout by an approved sprinkler system, refers to a system in accordance with NFPA 13. NFPA 13 lists areas where sprinkler protection may be omitted. These should be the only areas that this chapter recognizes. The commentary to IFC which states Although the use of an alternative extinguishing system allowed by 904, such as a carbon dioxide system or clean-agent system, would satisfy the requirements of Section 903.2, it would not be considered an acceptable alternative for the purpose of exceptions, reductions of other code trade-offs that would be applicable if an automatic sprinkler system were installed recognizes the value of a sprinkler system in accordance with NFPA 13. If ICC recognizes NFPA 13 as the standard for the installation of sprinkler systems, NFPA 101 should. To accept a clean agent fire extinguishing system as an equivalent to automatic sprinklers for the purpose of life safety would not be an even exchange. Just one example of this is duration. Total flooding fire suppression for a clean agent extinguishing system involves the discharge of a clean extinguishing agent that is typically required to provide protection within the design envelope for a minimum ten to twenty minute period. The average required duration for an automatic sprinkler system protecting an ordinary hazard occupancy is 60 minutes. There is ongoing debate as to whether water mist and other alternative extinguishing systems are equivalent to automatic sprinkler systems. Such determination should be case-specific and evaluated by the AHJ Log #527 SAF-BSF Final Action: (9.9.2 and 9.9.3) Submitter: John Hamilton, International Certification Board Recommendation: Revise to read: The special inspector's relevant experience in the design, installation, and testing of the fire protection systems being tested shall be documented. This section should say that the special inspector is a registered mechanical engineer or a person certified by a Nationally recognized organization The design documents shall provide the procedures and methods to be used and items subject to special inspections and tests. Or follow a national standard for testing like SMACNA procedural guides. Substantiation: Many areas of the country do not know what a special inspector is. This alleviates that issue and gives them proper direction. The public input does not include specific code revisions. Registered design professionals other than mechanical engineers could meet the required qualifications of special inspectors as determined by the AHJ. The term 'nationally recognized organization' is not defined and types of certifications are not specified. 11

14 101- Log #32 SAF-BSF Final Action: (A ) NOTE: This proposal appeared as Comment (Log #172) which was held from the A11 ROC on Proposal Submitter: Kenneth E. Isman, National Fire Sprinkler Association Recommendation: Insert a new annex note to as follows: A There are typically two different ways that extinguishing systems other than fire sprinkler systems are used. The first is when the entire building is protected with one of these alternate systems. When this is the case, the exceptions, reductions and alternative code provisions that are offered as options when fire sprinkler systems are installed should not be granted to the other extinguishing system unless the other system has demonstrated the same temperature control during a fire and reliability of operation as a fire sprinkler system. Reliability of operation needs to extend to the long-term use of the other system and an analysis of the reliability of the component parts. Some component of other extinguishing systems can show reliability data from their use in systems outside of fire protection where they get exercised on a regular basis, but acceptance on this basis is cautioned because many mechanical parts that sit for a long time without being exercised, as fire protection systems need to do, may not have the same reliability. A reliability analysis should also take into account inspection, testing and maintenance criteria and the likelihood of a building owner knowing and understanding what needs to be performed to keep the other system operational. The second manner in which other systems are used as alternatives to fire sprinkler systems are in individual rooms or spaces of otherwise sprinklered occupancies. Here the Authority Having Jurisdiction needs to use some judgment in the application of exceptions, reductions and alternative code provisions that are offered for sprinklered occupancies. The permission to utilize such exceptions, reductions and alternative code provisions far from the space with the other fire protection system should be granted. Closer to the space with the alternate system, exceptions, reductions and alternate code provisions for sprinklers could be granted if the system was analyzed as discussed above and found to be equivalent to a fire sprinkler system. Substantiation: After experiencing the discussion from the SAF-BSF committee and several of the occupancy committees, it is clear that something needs to be said in the Life Safety Code about this subject. But a blanket ban on using the sprinkler trade-ups, or a blanket statement that you can always use the sprinkler trade-ups, does not seem to work either way. Some judgment needs to be used depending on the type of alternative system proposed and the extent to which it is substituting for the sprinkler system. Some of these alternative systems are very good fire protection agents with a good history. Others are just coming to the market place and are using equipment that has not traditionally been used in fire protection systems and we just don t know how well they will work in the long-run. The annex note seemed to be the best way to provide guidance to AHJ s for now. See First Revision 101- Log #FR635 (FR-31-NFPA ) which incorporates the proposed annex language. 12

15 101- Log #296 SAF-BSF Final Action: (A (New) ) Submitter: Vickie J. Lovell, InterCode Incorporated Recommendation: Add new text to read as follows: A As smoke control systems become more elaborate and building systems become more integrated, it is essential to utilize individuals who are trained and qualified for inspection and testing such systems. Acceptable qualifications for acceptance testing and follow up testing for maintenance of smoke control systems are ultimately determined by the authority having jurisdiction. However, comprehensive study programs that result in certifications to inspect smoke control systems are available from third party organizations. In addition to passing the dedicated study programs pertaining to smoke control systems, eligibility criteria to become certified to inspect and test smoke control systems in third party programs should include a college/university degree in engineering with experience in HVAC installation or design work, associate degree in HVAC with at additional experience in HVAC installation or design work, or a certified testing and air balancers with extensive experience in HVAC installation or design. Substantiation: Section states that the acceptance testing for a smoke control system shall be performed by a special inspector in accordance with 9.9. However, section simply states that the special inspectors relevant experience related to the inspection and testing of the fire protection system (in this case the smoke control systems) shall be documented. It provides no guidance as to what appropriate credentials might be for that scope of work. This annex proposal provides information that may be useful to the authority having jurisdiction to determine the appropriate qualifications. The AHJ determines the required qualifications for special inspectors. The Code does not specify education requirements for other inspection, testing, or maintenance personnel. 13