Diane D. Matthews, Administrator, Technical Projects. The September 19, 2013 date for receipt of the NFPA 5000 Second Draft Ballot has passed.

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: TO: FROM: Technical Committee on Fire Protection Features Diane D. Matthews, Administrator, Technical Projects DATE: September 20, 2013 SUBJECT: NFPA 5000 Second Draft TC Ballot Circulation The September 19, 2013 date for receipt of the NFPA 5000 Second Draft Ballot has passed. The preliminary Second Draft Ballot Results are as follows: 27 Members Eligible to Vote 4 Ballots Not Returned (J. Castellano, J. Dudley, M. Gencarelli and J. Pasqualone) In accordance with the NFPA Regulations Governing the Development of NFPA Standards, attached are reasons for negative votes for review so you may change your ballot if you wish. Abstentions and affirmative comments are also included. Ballots received from alternate members are not included unless the ballot from the principal member was not received. If you wish to change your vote, the change must be received at NFPA on or before Friday, September 27, Members who have not returned a ballot may do so now. Ballots or changes may be made by going to the following link: NFPA Ballot The return of ballots is required by the Regulations Governing the Development of NFPA Standards.

2 NFPA 101 SAF-FIR FIRE PROTECTION FEATURES CIRCULATION SR-56, New Section after , See SR-56 Not Returned : 4 Affirmative 13 Affirmative with Comment 1 Catherine L. Stashak The Technical Committee spent several hours in discussion and task group work that resulted in this carefully written language. The Technical Committee worked together to achieve language that will make this section more user friendly. It is not taking anything away and it clarifies how equivalency can be achieved pursuant to codecompliant methods. For those of you that did not attend the meeting; please do not automatically vote negative because this is "that same issue". For those principal members that had alternates attending, please discuss this issue with your alternate (if the principal is voting) prior to voting. Negative 9 Kevin D. Morin Ralph D. Gerdes This code change is unnecessary as approval per 1.4 is always an option. In addition, this new text is likely to be in conflict with Building Codes that permit sprinklers for specific designs thus creating additional confusion for the AHJ and design professional. I have voted negatively on this issue for several cycles. The code should not limit the concept of equivalency and possible fire testing of assemblies. Page 1 of 27

3 Jonathan Humble Marshall A. Klein The comments by this individual has been submitted in a "pdf" format to Ms. Diane Matthews at NFPA for SR56. Will Diane Matthews Word file with my detailed comments for negative vote. Jeffrey M. Hugo John F. Devlin This section permits previously approved systems that have been installed properly but eliminates the possibility of new systems that have more installation criteria and oversight than those existing. This section would also prohibit the use of sprinklers to reduce wall and window ratings. The code wording could be incorrectly interpreted to imply that using automatic sprinklers as a means to achieve desired fire resistance rating is not acceptable. This is contrary to Section 1.4 Equivalency of this code which states Nothing in this Code is intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this Code. Andrew F. Weisfield Negative vote. Do not see the need to add language to an already large code book for procedures and provisions already permitted by the code and enforceable by the code (refernces to 1.4 and chapter 5). Do not see where this clarification is needed. There is only one codefied exception that allows the use of sprinklers in NFPA 101, section 8.6.7(1)(c) for atriums. Outside of this section, the use of sprinklers for fire protection rating of windows is only permitted where approved under 1.4 and Chapter 5 as the code is already written. Further clarification is not needed. Wayne D. Holmes There is insufficient substantiation to support this proposed changes Page 2 of 27

4 Brian T. Rhodes Abstain 0 Use of sprinklers does not achieve a fire resistance rating and would require AHJ approval based on current code language. Specifically stating the need for AHJ approval under the equivalency or performance-based methods is not necessary and is inconsistent with other similar conditions in the code. SR-78, Section No , See SR-78 Not Returned : 4 Affirmative 21 Affirmative with Comment 0 Negative 1 William E. Koffel Abstain 1 William J. McHugh, Jr. The methods are described in and Paragraph indicates that some analytical methods need to be approved. Paragraph provides the exposure conditions to be included in the analytical methods. It would be appropriate to say "...shall comply with through " but the current text indicates that each of the four paragraphs describe a method. Alternatively, and probably preferable, would be to format the paragraphs to be consistent with the formatting in NFPA The proposal will need more research on my part before voting affirmative or negative. Page 3 of 27

5 SR-57, New Section after , See SR-57 Not Returned : 4 Affirmative 22 Affirmative with Comment 0 Negative 0 Abstain 1 William J. McHugh, Jr. Labels on doors are very sensitive issues that need further study before allowing a blanket exception to labeling. SR-72, Section No [Excluding any Sub-Sections], See SR-72 Not Returned : 4 Affirmative 23 Affirmative with Comment 0 Negative 0 Abstain 0 Page 4 of 27

6 SR-73, Section No , See SR-73 Not Returned : 4 Affirmative 23 Affirmative with Comment 0 Negative 0 Abstain 0 SR-74, Sections , , , See SR-74 Not Returned : 4 Affirmative 22 Affirmative with Comment 1 William J. McHugh, Jr. Negative 0 Abstain 0 Adding labels to dampers with print size makes a lot of sense for post installation inspection and maintenance for the life of the building. Page 5 of 27

7 SR-58, New Section after , See SR-58 Not Returned : 4 Affirmative 13 Affirmative with Comment 2 William J. McHugh, Jr. Currently, the code is silent about the air leakage ratings for firestop products that, when installed to the tested and listed system, become firestop systems. From many perspectives, the air leakage ratings for firestop systems as listed in the proposal provide a quantified value that sets a minimum resistance to smoke and provide guidance. Guidance is given specifiers who then communicate resistance through construction documents. Submittals from contractors can provide quantified values that can meet or exceed those stated by code. For now, the current method gives no guidance to designers, Authorities having jurisdiction, nor contractors about what is acceptable. Catherine L. Stashak Designers, contractors and AHJs have no way to determine acceptability of individual or a complete area of penetration or joint firestops. At some point with enough openings or leakage the barrier is no longer a smoke barrier. This is a logical quantitative approach that is easy for both the designer, contractor, AHJ to use to confirm the smoke barrier will really be a smoke barrier. Negative 7 Page 6 of 27

8 Ralph D. Gerdes Sam W. Francis I have voted negatively on this issue for several cycles. Again, while the technology exists I do not see the need to limit air leakage in this manner. requiring an approved through penetration Firestop System is well beyond adding leak rates to the text or mandating the methods used meet those leak rates Gregory J. Cahanin This change will require the use of proprietary firestop systems when materials used in construction for gypsum and mortar have not been shown to be ineffective. This change will result in increased construction costs with no definable benefit. Marshall A. Klein Jeffrey M. Hugo John F. Devlin Will Diane Matthews Word file with my detailed comments for negative vote. There is no substantiation that a through-penetration of a smoke barrier is needed in a fully sprinklered building. Chapter 8 is general requirements that apply to all other chapters (occupancies) unless specifically amended by the chapter (occupancies). There is no technical justification submitted with the code change proposal that: 1) demonstrates the need to require/confirm maximum leakage rates as a general matter of life safety practice, 2) shows that failure of a through-penetration system to meet this minimum requirement will result in unacceptable life safety consequence. Wayne D. Holmes The proposed requirement creates a burden for which there is no demonstrated need or benefit. There is no evidence of any safety to life hazard created by existing smoke barriers where quantitative leakage limits are not applied. There are no data that supports the premise that the specified quantitative limits are safe limits. Similarly, there are no data that support that leakage in excess of the proposed limits are unsafe. The proposed limits do not take into consideration the volume of compartments which will have a significant impact on smoke concentrations. Abstain 1 Page 7 of 27

9 William E. Koffel In accordance with Standards Council policy, I have abstained from voting on SR-58. SR-75, Section No , See SR-75 Not Returned : 4 Affirmative 22 Affirmative with Comment 0 Negative 1 Vickie J. Lovell I cannot vote to support item (c) found in this proposal, although I could support the rest of the proposal without(c). The TC voted for SR 56 to allow the code official to consider certain conditions on a case-by-case basis when fire rated assemblies could be substituted for a glass wall wetted with sprinklers. This section goes well beyond evaluating the glass wall in an atrium on a case- by case basis and broadly describes conditions for carte blanche approval for such use of glass. However, there are numerous other considerations that this proposal does not address. A glass wall with sprinklers should never be routinely considered as an effective alternative to a fire barrier. SR 56 does not preclude the use of wetted glass as an alternative to a fire barrier in an atrium, so (c) is not needed. Page 8 of 27

10 Abstain 0 SR-59, Section No , See SR-59 Not Returned : 4 Affirmative 18 Affirmative with Comment 0 Negative 5 Robert A. Speed Allowing four communicating floors without some means of controlling smoke or an analysis to show smoke migration is held to acceptable levels is not prudent. Jeffrey M. Hugo There is no technical substantiation that shows multiple unprotected vertical openings in a fully sprinklered building is causing multiple deaths, or the number of openings permits heat to be detrimental to the structural integrity of the building. Likewise, there is no evidence that four levels is a "reasonable" number. This section would also permit occupancy chapters to choose other unsubstantiated numbers of levels. Page 9 of 27

11 Jonathan Humble I am voting negative as the proposal lacks substantiation for determining the four story limitation for vertical openings created by convenience stairs. At the FIR-TC meetings the discussion about limitations (e.g. story height) seemed to wonder as a result of a lack of objective approach, and lack of historical fire incident data, for determining the allowable story height for this opening. For example, our discussions were about the following: 1.) NFPA , Section 8.6.9, and NFPA , Section , which cites a value of two adjacent stories for convenience openings, 2.) NFPA , Section 8.6.6, and NFPA , Section , which cites a value of not more than three contiguous stories for communicating spaces. 3.) Log in the 2012 cycle and the provisions for escalators. 4.) Atriums. As a result, rather than supporting an arbitrary value I will vote negatively for this proposal. Marshall A. Klein Will Diane Matthews Word file with my detailed comments for negative vote. John F. Devlin There is no technical basis submitted with the code change proposal to support limiting convenience stairs to not more than 4 stories. Is 4 stories too many, or too few?: this limitation is not technically substantiated. Abstain 0 SR-60, Section No , See SR-60 Not Returned : 4 Affirmative 17 Page 10 of 27

12 Affirmative with Comment 0 Negative 6 Robert A. Speed Kevin D. Morin Jonathan Humble See SR-59. The language appears to be different that what I thought the committee input was, which was to be consistent with Section which limits the openings to 4 stories and the size of the opening. NFPA 13 does not limit the size of the opening as the appendix to this section appears to suggest. I am voting negative as the proposal lacks substantiation for determining the four story limitation for vertical openings created by escalators and moving walks. At the FIR-TC meetings the discussion about limitations (e.g. story height) seemed to wonder as a result of a lack of objective approach, and lack of historical fire incident data, for determining the allowable story height for this opening. As a result, rather than supporting an arbitrary value I will vote negatively for this proposal. Marshall A. Klein Will Diane Matthews Word file with my detailed comments for negative vote. Jeffrey M. Hugo There is no technical substantiation that shows multiple unprotected vertical openings in a fully sprinklered building is causing multiple deaths, or the number of openings permits heat to be detrimental to the structural integrity of the building. Likewise, there is no evidence that four levels is a "reasonable" number. This section would also permit occupancy chapters to choose other unsubstantiated numbers of levels. Page 11 of 27

13 John F. Devlin There is no technical basis submitted with the code change proposal to support limiting convenience stairs to not more than 4 stories. Is 4 stories too many, or too few?: this limitation is not technically substantiated and there is no demonstration of an unacceptable risk imposed when an escalator or moving walkway connects more than 4 stories when a building is protected throughout with automatic sprinklers. Abstain 0 SR-77, Section No. A , See SR-77 Not Returned : 4 Affirmative 23 Affirmative with Comment 0 Negative 0 Abstain 0 Page 12 of 27

14 SR-67, New Section after A , See SR-67 Not Returned : 4 Affirmative 15 Affirmative with Comment 1 Catherine L. Stashak The Technical Committee spent several hours in discussion and task group work that resulted in this carefully written language. The Technical Committee worked together to achieve language that will make this section more user friendly. It is not taking anything away and it clarifies how equivalency can be achieved pursuant to codecompliant methods. For those of you that did not attend the meeting; please do not automatically vote negative because this is "that same issue". For those principal members that had alternates attending, please discuss this issue with your alternate (if the principal is voting) prior to voting. Negative 7 Kevin D. Morin Jeffrey M. Hugo Jonathan Humble This code change is unnecessary as approval per 1.4 is always an option. In addition, this new text is likely to be in conflict with Building Codes that permit sprinklers for specific designs thus creating additional confusion for the AHJ and design professional. The annex material conflicts with the code text. The comments by this individual has been submitted in a "pdf" format to Ms. Diane Matthews at NFPA for SR67. Page 13 of 27

15 Marshall A. Klein Will Diane Matthews Word file with my detailed comments for negative vote. Andrew F. Weisfield Negative vote. Do not see the need to add language to an already large code book for procedures and provisions already permitted by the code and enforceable by the code (refernces to 1.4 and chapter 5). Do not see where this clarification is needed. There is only one codefied exception that allows the use of sprinklers in NFPA 101, section 8.6.7(1)(c) for atriums. Outside of this section, the use of sprinklers for fire protection rating of windows is only permitted where approved under 1.4 and Chapter 5 as the code is already written. Further clarification is not needed. John F. Devlin The code wording could be incorrectly interpreted to imply that using automatic sprinklers as a means to achieve desired fire resistance rating is not acceptable. This is contrary to Section 1.4 Equivalency of this code which states Nothing in this Code is intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this Code. Wayne D. Holmes Abstain 0 See comment on negative ballot for SR-56. SR-76, Section No. A , See SR-76 Page 14 of 27

16 Not Returned : 4 Affirmative 22 Affirmative with Comment 0 Negative 1 Gregory J. Cahanin Abstain 0 Asymmetrical fire assemblies are used to isolate the greater hazard from the remainder of the interior. Shaft walls are a good example of the use of Asymmetrical assembly use. Se UL U408 and UL R1319 in addition to GA File No.s WP 7125 and The language of this revision will not allow this sort of design. Failure of steel framing or fasteners on the lesser side of these assemblies would result in a lower rating. SR-70, Section No. A , See SR-70 Not Returned : 4 Affirmative 16 Affirmative with Comment 1 William J. McHugh, Jr. These annex items give the user of the code guidance about the proper installation and inspection of firestop systems through approved, qualified firestop contractor companies. It also alerts that there are firestop inspection companies who have accreditations available as well. Page 15 of 27

17 Negative 5 Ralph D. Gerdes Jeffrey M. Hugo Marshall A. Klein Wayne D. Holmes The deletion of FM and UL references is not justified, nor wise. This proposal attempts to allow contractors to establish their own standards. This section would require all contractors who install fire stop systems to become accredited. Will Diane Matthews Word file with my detailed comments for negative vote. This code should not appear to be endorsing or promoting a third-party program. John F. Devlin Abstain 1 William E. Koffel I believe citation of FM 4991 and UL qualified contractor firestop program are more appropriate references. The proposed language appears to be an NFPA endorsement of a third-party contractor program, and endorsement I do not believe is appropriate for NFPA standard. In accordance with Standards Council policy, I have abstained from voting on SR-70. SR-69, Section No. A , See SR-69 Not Returned : 4 Affirmative 16 Page 16 of 27

18 Affirmative with Comment 1 William J. McHugh, Jr. Negative 5 Kevin D. Morin Ralph D. Gerdes Marshall A. Klein These annex items give the user of the code guidance about the proper installation and inspection of firestop systems through approved, qualified firestop contractor companies. It also alerts that there are firestop inspection companies who have accreditations available as well. Language is unnecessary. All systems require proper installation to meet the listing criteria. This language seems promotional. The deletion of FM and UL references is not justified, nor wise. This proposal attempts to allow contractors to establish their own standards. Will Diane Matthews Word file with my detailed comments for negative vote. Wayne D. Holmes This code should not appear to be endorsing or promoting a third-party program. John F. Devlin Abstain 1 William E. Koffel I believe citation of FM 4991 and UL qualified contractor firestop program are more appropriate references. The proposed language appears to be an NFPA endorsement of a third-party contractor program, and endorsement I do not believe is appropriate for NFPA standard. In accordance with Standards Council policy, I have abstained from voting on SR-70. Page 17 of 27

19 TO: FROM: Diane Matthews, NFPA Jonathan Humble, AISI (Primary for AISI) DATE: 10 September 2013 SUBJECT: NFPA FIR - Second Revisions SR-56 (101) SR-67 (101 Annex) Humble recommendation: Register my vote as negative on Second Revision items #56 (101), and #67 (101 Annex) The testimony provided at the 2013 TC meetings, the history of this subject, and the results of ballots over the years, demonstrate that the proposed language is neither appropriate nor ready for inclusion into the code Verbal testimony versus substantiation. The testimony and actions by the supporters to this change did yield recognition to something that was first brought out in 2005, that of the impact this proposal would have to NFPA 13. The proposed compromise is to install a sentence into the Annex which stated It is not the intent of this section to prohibit the use of sprinklers in lieu of fire resistance rating where permitted elsewhere by this Code. While the recognition at this meeting of the NFPA 13 provisions is finally appreciated, it is not sufficient for this proposal to pass. It makes it appear that NFPA 13 is merely second class, and requires the user to hunt for the additional requirements that could affect the design. This is not a practical solution, and further supports the position to have these proposals rejected. Further, the verbal testimony also revealed that the rate of incident of use of automatic fire sprinklers as a substitute for fire resistance ratings was not as rampant as advertised. When the FIR committee took the opportunity to poll those supporters of the proposal we soon found the numbers of their experiences were extremely low. I would further point out that the FIR committee has only received one piece of physical evidence in support of a similar proposal, and that was in To date no other physical examples (e.g. Contract document submissions for permit from jurisdictions, etc.) have been submitted to the FIR committee. Unintended Outcome: The outcome of the committee proposal eliminates in all respects the use of automatic fire extinguishing system in relation to Section This compromise solution also has the net effect of disallowing the use an automatic fire extinguishing system for a design which may be submitted under Section 1.4 (Equivalency) or Chapter 5 (Performance Based Option) by de facto as a result of this language being present. Circumvents Due Process in Chapter 1: Chapter one was clearly established as the scoping provisions to oversee and address situations that the AHJ would consider outside of the provisions of the code. By installing language which prohibits this action circumvents that option for the AHJ, and restricts options for the user as provided under related provisions in Chapter 1. This can be demonstrated when viewing Section A1.4.3 which states, in part, the following: Through the rigor of a performance-based design, it can be demonstrated whether a building design is satisfactory and complies with the implicit or explicit intent of the applicable code requirement As a result, since the proposed provision is explicit, the performance option for demonstrating equivalency is no longer available. Page 18 of 27

20 Adds Qualifier to Test Standard: Modifying ASTM E119, UL 263 and NFPA 251 in this manner is not appropriate. If there is an issue with each of the standards then the proper forum is the standards development process and not the NFPA code development process. To date no substantive information has been provided to this committee to demonstrate that this option has been taken to all the fire endurance standards consensus committees for consideration. This lack of substantive information suggests that there is no issue with the fire endurance standards, and further supports disapproval of the NFPA code change item. Historical: If we look at the travels of this and similar proposals we find that Section has gone through multiple transformations. One could easily conclude that the sheer number of proposals that have been rejected is an indication that the intended concept remains without foundation and therefore has not been met as a result of those substantive transitions and the vote count for each by the TC. See examples below: 2005 ROP, (Log #215): (Proposal to add) Elements and assemblies tested in conjunction with active suppression systems shall not be considered as equivalent. Committee Action: Elements and assemblies tested in conjunction with active suppression systems shall not be considered as equivalent to material fire resistance rating, but shall be permitted to be evaluated on a performance basis. Affirmative 15, Negative ROC, (Log #293): (Proposal to add) Testing of dedicated active3 suppression systems in combination with building elements or assemblies shall not be considered as equivalent to material or assembly fire resistance ratings. Affirmative 13, Negative ROC, (Log #259) (Proposal to add) Elements and assemblies tested in conjunction with active suppression systems shall not be considered as equivalent unless such design incorporating the element or assembly and active suppression system includes supporting documentation, and such design and supporting documentation has been evaluated and approved as part of the performance-based option in accordance with Chapter 5 by the authority having jurisdiction. Affirmative 13, Negative ROC, (Log #268) (Change to read) The fire resistance rating or an element or assembly determined by tests conducted in accordance with NFPA 251 or other approved test methods shall not be allowed to rely on an automatic fire protection system, but shall be permitted to be evaluated as part of a performance-based option in accordance with Chapter 5. Affirmative 11, Negative ROC, (Log #289) (Change to read) In establishing compliance with a specific requirement within this code for an element or assembly to have a specified fire resistance rating, it shall not be permitted to use a fire resistance rating that is determined via a test that simultaneously utilizes active suppression together with an element or assembly that without the active suppression would have a lesser fire resistance rating. Affirmative 12, Negative ROC, (Log #347) (Change to read) Elements and assemblies installed in conjunction with active fire suppression systems in lieu of required fire resistance ratings shall have their alternative fire protection performance evaluated relative to the original requirement for fire resistance. Affirmative 13, Negative 8 Page 19 of 27

21 2008 ROC, (Log #264) (Add new section) * The fire resistance rating of an element or assembly determined by tests conducted in accordance with NFPA 251 or other approved test methods shall not be established using a liquid to cool the test specimen during the fire exposure, unless the option of using such cooling is an explicit option allowed by the test standard. Affirmative 11, Negative 9, Abstain ROC, (Log #261) (Add new section) : * The fire resistance rating of an element or assembly determined by tests conducted in accordance with NFPA 251 or other approved test methods shall not be allowed to rely on an automatic fire protection system unless evaluated as an equivalency in accordance with Section 1.4 or as part of a performancebased option in accordance with Chapter 5. Affirmative 11, Negative 9, Abstain ROC, (Log #340) (Reconsider original or ) Affirmative 11, Negative 9, Abstain ROC, (Log #268) (Add new section) The fire resistance rating of an element or assembly determined by tests conducted in accordance with NFPA 251 or other approved test methods shall not be allowed to rely on an automatic fire protection system unless evaluated as an equivalency in accordance with Section 1.4 or as part of a performancebased option in accordance with Chapter 5. Affirmative 11, Negative 9, Abstain ROC, (Log #113) (New Section) Under the prescriptive fire resistance requirements of this Code, determination of the fire resistance rating of structural elements, components and building assemblies in shall be established without the use of automatic fire suppression systems in accordance with the fire exposure, procedures, and acceptance criteria specified in ASTM E119 or UL 263. (TC Recommendation as follows) (New language to follow scoping paragraph) * The fire resistance rating of an element or assembly shall not rely on an automatic fire extinguishing system (Reject) Affirmative 13, Negative ROC, (Log #112) 2010 ROC, (Log #188) 2010 ROC, (Log #302) (Reconsideration) (Add new section) The fire resistance rating of an element or assembly determined by tests conducted in accordance with NFPA 251 or other approved test methods shall not be permitted to rely on an automatic fire protection system, unless evaluated as an equivalency in accordance with Section 1.4 or as part of a performancebased option in accordance with Chapter 5. (Committee Recommendation: above) (Reject) Affirmative 13, Negative (Reject) Affirmative 13, Negative (Reject) Affirmative 13, Negative ROC, (Log #4) (Add new section) Determination of the fire resistance rating of structural elements and building assemblies in shall be independent of automatic fire suppression systems unless evaluated as an equivalency in accordance with Section 1.4 or as part of a performance-based option in accordance with Chapter 5. (Committee Recommendation: above) (Accept in Principal ) Affirmative 14, Negative 7 Page 20 of 27

22 2012 First Draft (Formerly ROC) NFPA 101 FR400 (Log #200) and FR401 (Log #211 Annex) (Add the following) The fire resistance rating of an element or assembly determined by tests conducted in accordance with NFPA 251 or other approved test methods shall not be permitted to rely on automatic fire suppression systems unless evaluated as an equivalency in accordance with Section 1.4 or as part of a performance-based option in accordance with Chapter 5. (Add the following) A8.1.3 NFPA 251, ANSI/UL 263, and ASTM E119 are nationally recognized methods of determining fire resistance of building elements and assemblies. Assemblies tested in accordance with these fire-resistance test standards provide passive fire protection. The test procedures set forth in these Standards make no provision for testing automatic fire suppression systems or water sprays in conjunction with structural members or assemblies tested in vertical or horizontal fire resistance furnaces. Such evaluations can only be done via the Alternative protection methods procedures in Section 1.4, or by evaluation as a performance-based option in Chapter 5. FR400 Affirmative 13, Negative 9, Abstain 1 FR401 (Annex) Affirmative 13, Negative 10, Abstain 1 (END) Page 21 of 27

23 MARSHALL A. KLEIN & ASSOCIATES, INC. FIRE PROTECTION BUILDING CODE ENGINEERS CONSULTANTS 6815 Autumn View Drive Eldersburg, Maryland Fax: Memorandum TO: Diane D. Matthews, NFPA FROM: Marshall Klein DATE: September 11, 2013 SUBJECT: Second Draft Ballot for the 2015 NFPA101 Fire Protection Features Committee Please accept my affirmative ballots for the above noted Committee except for the following NEGATIVE actions on the following items: SR#56 (New Section ) & SR#67 (New Annex Note A ) SAF- FIR Record my vote as NEGATIVE See my detailed comment below. SR#58 (New Sections and ) SAF-FIR Record my vote as NEGATIVE See my detailed comment below. SR#59 (Section ) SAF-FIR Record my vote as NEGATIVE See my detailed comment below. ( (5) SR#60 (Section ) SAF-FIR Record my vote as NEGATIVE See my detailed comment below. SR#70 (Section A ) SAF-FIR Record my vote as NEGATIVE See my detailed comment below. SR#69 (Section A ) SAF-FIR Record my vote as NEGATIVE See my detailed comment below. Detailed Comment on SR#56 & SR#67SAF-FIR: Certain special interest groups have attempted for the past four (4) code cycles to get wording in the Chapter 8 of the Code that would appear to clarify the intent of the Code that sprinkler protection is not part of the referenced fire test protocol. Existing Page 22 of 27

24 2012 NFPA 101 Section and 2012 NFPA 5000 Section state that fire resistance of structural elements and building assemblies meet with the test procedures set forth in NFPA 251, ASTM E119, UL 263, or other approved test method or analytical methods approved by the authority having jurisdiction. The proponents for this clarification of the Code appear to think that if such code proposals are rejected, then the SAF-FIR committee has somehow sanctioned unlimited use of sprinklers in lieu of fire rated assemblies. This is not true and is only self serving for those who attempt to apply such a rationale. The only codified exception to NFPA 101 Section in Chapter 8 is in Section 8.6.7(1)(c) [or see related NFPA 5000 Section (1)(b)] that deals with atrium walls, which has been in the NFPA 101 Code s atrium section since the inclusion of the atrium requirements in the 1981 edition of that Code. Aside from this atrium wall exception, the literal text of Chapter 8 requires compliance with the above noted test standards, unless approval is obtained from the authority having jurisdiction through use of the other approved test method or analytical methods approved by the authority having jurisdiction provision under Section , or Section 1.4, Equivalency [or see related NFPA 5000 Section 1.5], or as part of a performance-based option in Chapter 5. Any and all of these potential alternatives are required to be under the review and approval of the local authority having jurisdiction, not the SAF-FIR committee. This procedure for alternatives is already permitted under the Code, has always been permitted under the Code, and according to the proponent of these code proposals, would not change. This again begs the question under the Second Draft stage: Why are we adding this new section and its associated annex note to these Codes? Isn t the code book fat, or heavy, enough without adding more superfluous sections stating the obvious? It appears, based on the Second Revision Committee Statements, that the Committee believes that most code users are not sharp enough to realize that the fire test standards relating to determining fire ratings of building assemblies do not include sprinkler protection. However, where is the technical justification with any supporting fire data or life safety loss documentation that justifies adding this new section or annex note showing that such text is required, or even needed, in the Code? The Codes are clear, under existing NFPA 101 Section and NFPA 5000 Section , for the criteria for fire rated building assemblies. The Codes are clear, under existing NFPA 101 Section 1.4 (or NFPA 5000 Section 1.5) and Chapter 5, on what is the responsibility of the authority having jurisdiction. These code proposals add nothing of substance to the Code except to add confusion on where the line of authority lies with the code official responsible for enforcing the Code. If the Committee believes code officials need additional guidance on application of certain sections of the Code, then the commentary in the Handbook is the proper place for such explanations. Listed below are about a dozen fire test standards that are referenced in NFPA 101 and/or NFPA 5000 that provide test results for some type of fire resistance measurement without any testing protocol for the relationship between passive and active fire protection. Therefore, if these proposed Second Revisions are truly needed for proper application of the Code requirements, should not the same type of Second Revisions be added for the Page 23 of 27

25 same dubious reason to the following sections of the NFPA 101 Code (NFPA 5000 has the same related sections but for brevity I have not listed the NFPA 5000 counterparts)? One only needs to review this new proposed section and annex note and fill in the appropriate blanks for the particular standard as shown below for the following 49 sections of the Code. I am sure if I had more time I could come up with numerous other sections in the Code as well. New Sections and Annex Notes modeled after the ones in SR#56 (New Section ) & SR#67 (New Annex Note A ) SAF-FIR: Proposed New Section in 49 sections of Code: For other than existing, previously approved assemblies, assemblies utilizing fire sprinklers in lieu of complying with a required fire resistance rating for {Fill in the type of assembly being protected} shall only be permitted where approved by the authority having jurisdiction in accordance with Section 1.4 or Chapter 5. Proposed New Annex Note in 49 sections of Code: Standards referenced by this Code, {Fill in any NFPA Standard(s) below along with related UL and ASTM related Standards}, currently do not have any criteria for the incorporation of fire sprinklers in the test procedures for determining a fire resistance rating. There are test reports that evaluate the performance of assemblies that incorporate sprinklers as part of an assembly. The intent of this section clarifies that such testing should not assign a fire resistance rating to the assembly. However, this section does permit an evaluation of the fire performance of such assemblies for consideration by authorities having jurisdiction when considering an alternative to an assembly tested in accordance with traditional fire resistance test methods, per Section 1.4 or Chapter 5. It is not the intent of this section to prohibit the use of sprinklers in lieu of a fire {Fill in the type of test such as fireresistance, door, floor, wall covering, etc.} rating where permitted elsewhere by this Code. Based on the above noted wording, on could add above New Section and Annex Note to the following NFPA 101 code sections to clarify that the following referenced standards do not have testing protocol for active fire protection systems: 1. NFPA 251, Standard Methods of Tests of Fire Resistance of Building Construction and Materials : Can add such annex note to NFPA 101 Sections , , , , , (1) & (4) and Page 24 of 27

26 2. NFPA 252, Standard Methods of Fire Tests of Door Assemblies, 2008 edition. Can add such annex note to NFPA 101 Sections , , & Table NFPA 253, Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source, 2006 edition. Can add such annex note to NFPA 101 Section NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, 2006 edition. Can add such annex note to NFPA 101 Section NFPA 257, Standard on Fire Test for Window and Glass Block Assemblies, 2007 edition. Can add such annex note to NFPA 101 Sections , , , , , and NFPA 259, Standard Test Method for Potential Heat of Building Materials, 2008 edition. Can add such annex note to NFPA 101 Section NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls, 2007 edition. Can add such annex note to NFPA 101 Sections , , (5) and (5). 8. NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth, 2006 edition. Can add such annex note to NFPA 101 Sections , , , (6). 9. NFPA 288, Standard Methods of Fire Tests of Floor Fire Door Assemblies Installed Horizontally in Fire Resistance Rated Floor Systems, 2007 edition. Can add such annex note to NFPA 101 Section NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, 2004 edition. Can add such annex note to NFPA 101 Sections , , , , (1), (4a), (1), (4), and (e). 8NFPA 703, Standard for Fire Retardant Treated Wood and Fire-Retardant Coatings for Building Materials, 2009 edition. Can add such annex note to NFPA 101 Sections , (3) and (a). Page 25 of 27

27 11. ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, Can add such annex note to NFPA 101 Sections , , , , , (4)(b), and (4)(b). Detailed Comment on SR#58 SAF-FIR: No technical justification showing life and/or fire losses has been provided to require leakage rate for smoke barriers above and beyond what is already required under the Code. If such fire data were provided and was justified, it would appear that such a requirement would be made applicable to existing building installation that have been clearly exempted by the new proposed Section in NFPA 101. Any new building that requires smoke barriers is required by the Code to be sprinklered, so why is it then necessary for new buildings that are sprinklered and not for previously approved existing buildings with existing smoke barriers that may not be sprinklered. Maybe the logical question that should be asked is that if the fire data were to show that in sprinklered buildings over the past 40 years that the Code required such smoke barriers and there was no major fire or life loss, then are smoke barriers really needed in such sprinklered buildings? Until the proponents of these code revisions can answer that question, I see no technical justification to add another burdensome requirement to the Codes. Detailed Comment on SR#59 SAF-FIR: No technical justification showing life and/or fire losses has been provided to limit the application of NFPA 101 Section (5) and NFPA 5000 Section (5) to new construction not more than 4 contiguous stories since it was previously permitted for all new and existing sprinklered buildings. If such fire data was provided and was justified, it would appear that such a requirement would be made applicable to previously approved existing building installation that have been clearly exempted by existing Section (2) in NFPA 101. Any new building that may have open convenience stairs is required by the Code to be sprinklered, so why is it then necessary for new buildings that are sprinklered to be limited in the number of open floors, and not for existing sprinklered buildings with existing open convenience stairs? Detailed Comment on SR#60 SAF-FIR: No technical justification showing life and/or fire losses has been provided to limit the application of NFPA 101 Section (3) and NFPA 5000 Section (2) to new construction not more than 4 contiguous stories since it was previously permitted for all new and existing sprinklered buildings. If such fire data were provided and was justified, it would appear that such a requirement would be made applicable to previously approved existing building installations that have been clearly exempted by existing Section (2) in NFPA 101. Any new building that may have open escalators or moving walkways is required by the Code to be sprinklered, so why is it then necessary for new buildings that are sprinklered to be limited in the number of open floors, and not for existing sprinklered buildings with existing open escalators or moving walkways? Page 26 of 27

28 Detailed Comment on SR#70 SAF-FIR AND Detailed Comment on SR#69 SAF-FIR on joints: The Committee Revisions and Statements for all four revisions (SR#70 & SR#69 in SAF- FIR and SR#81 & SR#83 in BLD-FIR) are identical for the annex notes on firestops and joints by stating: Proposed text further clarifies the use of third party programs or contractors with regards to the installation and maintenance of firestop systems. These four (4) revisions deleted the reference to FM 4991, Standard for Approval of Firestop Contractors, and the UL Firestop Contractor Program, and replace it with 3 paragraphs of wording that appears to be just promotional endorsement and advertisement supporting the hiring of firestop contractors and their associates to do the installation and inspection of such activities on a project. There was no technical justification supporting these revisions, and replacing the references to the FM and UL Standards with the new text only appears to be self serving to a particular special interest group(s). The existing annex notes should be retained with the existing text that references the FM & UL Standards, and if such explanatory language is needed to support the pretext that supposedly only third party independent companies can do such installations and inspections than that is material for consideration for placement in the commentary in the NFPA 101/5000 Handbooks. (File: 610 Laptop:C:\Documents and Settings\Marshall Klein\My Documents\My Old Laptop Documents\My NFPA Committee Work Files\NFPA 101\NFPA Cycle\Fire Protection Features\Second Draft\Second Draft Ballot for NFPA 101_5000 for FIR from Marshall Klein REV1.doc) Page 27 of 27