We strongly urge NFPA not to adopt future fire sprinkler amendments impacting Category B animals to the NFPA 150.

Transcription

1 of 43 12/4/ :17 AM Public Input No. 41-NFPA [ Global Input ] We strongly urge NFPA not to adopt future fire sprinkler amendments impacting Category B animals to the NFPA 150. Additional Proposed Changes File Name NFPA_150_public_input_form_ _Animal_Ag_Industry.pdf .pdf NFPA_150_Public_input_letter_ pdf Description Approved Cover Sheet Letter Consideration potentially being given to expanding the fire sprinkler and smoke control requirements of NFPA 150 to include Category B animals should be rejected, per the attached letter from representatives of the animal agriculture industry. Submitter Full Name: John Starkey Organization: U.S. Poultry & Egg Assn. Submittal Date: Fri Jul 12 07:48:40 EDT 2013 Resolution: The committee has not created provisions to require sprinklers in Category B animals. A FR was developed to require sprinklers in only Category A animal facilities and horse facilities. Agricultural livestock animals were omitted from Category A. I, John Starkey, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this form is used. Except to the extent that I may lack authority to make an assignment of content identified above, I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright By checking this box I affirm that I am John Starkey, and I agree to be legally bound by the above and the terms Origin (from sources other than the submitter) Letter was prepared by the 23 industry associations listed in the attached letter.

2 From: Sent: To: Cc: Subject: Attachments: Paul Pressley Monday, July 08, :32 PM proposals and comments Vecchiarelli, Tracy Public Input letter - NFPA Revision Cycle NFPA 150 public input form Animal Ag Industry.pdf; NFPA 150 Public input letter pdf Attached please find the public input form and an accompanying letter on behalf of 23 animal agriculture associations expressing our belief that language proposed during the 2012 revision cycle concerning fire sprinkler and smoke control systems for Category B animals would result in significant technical and operational disruptions and enormous costs, with little actual or observable benefit to the welfare, health, and safety of the animals. The producers of these animals raised for food believe that expanding the requirements for sprinkler and smoke control systems will not significantly reduce the risk of loss to the animals and stress that pre loss prevention efforts are much more effective than post loss control efforts in addressing animal welfare concerns. We strongly urge NFPA not to adopt future fire sprinkler amendments impacting Category B animals to the NFPA 150. We stand ready to work with the NFPA 150 Technical Committee on this and other issues. We thank you for the opportunity to provide this input. Paul W. Pressley Executive Vice President Industry Programs U.S. Poultry & Egg Association 1530 Cooledge Rd. Tucker, GA (Direct) (Mobile) This message is intended only for the addressee(s) and contain information that may be confidential and/or copyrighted. If you are not the intended recipient, please notify the sender by reply and immediately delete this . Use, disclosure or reproduction of this by anyone other than the intended recipient(s) is strictly prohibited. No representation is made that this or any attachments are free of viruses. Virus scanning is recommended and is the responsibility of the recipient. 1

3 July 8, 2013 Amy Cronin, Secretary Standards Council National Fire Protection Association 1 Batterymarch Park Quincy, Massachusetts Re: NFPA 150 Standard on Fire and Life Safety in Animal Housing Facilities 2015 Revision Cycle Public Input Secretary Cronin: The undersigned organizations appreciate the opportunity to submit this letter of public input concerning the 2015 revision cycle for the 150 Standard for Fire and Life Safety in Animal Housing Facilities. Herein, we wish to briefly restate concerns we raised under appeal during the 2012 revision cycle concerning the proposal to require the installation of sprinkler and smoke control systems in animal housing facilities for Category B animals. Members of these organizations own and operate the overwhelming majority of animal housing facilities in the United States that produce or contribute to the production of the livestock and poultry in the United States. These farmers and ranchers are committed to the practice of good animal husbandry and the welfare of the animals in their care. No one feels the loss of their animals more acutely than them, and no one understands the devastating implications of major fires on their operations. No one has more incentive than them to protect the health and safety of their animals, and in the process, their businesses and livelihoods. The farms and ranches owned by the members of these organizations include the overwhelming majority of those that meet the definition of both NFPA Class 1 Facilities, such as livestock, poultry and dairy barns, and the corresponding Category B animal housing facility as defined by NFPA 150. The adoption of an amended NFPA standard expanding the requirement for sprinkler and smoke controls systems for Category B animals including livestock and poultry operations would result in significant technical and operational disruptions and enormous costs, with little actual or observable benefit to the welfare, health, and safety of the animals. These farmers and ranchers will be directly harmed if the NFPA 150 standard is amended in future editions to require fire sprinkler and smoke control systems for Category B animals and they publically oppose any efforts to do so. They seek to retain the current treatment of such facilities in the NFPA 150 standard which allows them to focus efforts on effective pre-loss prevention programs rather than relatively ineffective and expensive post-loss control methods. Our members believe that pre-loss activities such as good housekeeping practices, effective equipment maintenance, and the control of ignition sources in livestock and poultry housing have been effective in controlling the risk of fire.

4 They also believe that the expense and associated risk of sprinkler systems far outweigh the potential benefit. Many, if not most, farms will lack a water supply adequate to support a well-designed sprinkler system, greatly increasing the cost to comply with the standard. The addition of other water sources in livestock housing may inadvertently introduce uncontrolled moisture into the houses, creating vectors of disease and infection (flies, bacteria, others) as well as the simple, greater physiological challenges for wet animals. Maintenance and inspection of sprinkler systems may also create biosecurity risks to these animals. Modern animal agriculture operations have developed and strictly follow biosecurity protocols to minimize the risk that diseases will be transmitted from flock to flock or herd to herd. The single largest such vector is human beings and their vehicles. These protocols commonly dictate who can enter the animal houses, how many days there must be between a visit to another flock or herd, whether they need to shower or otherwise clean themselves before entry, and what they must wear. We also have questions as to the possible biosecurity risks created by the non-potable sprinkler water itself in the case of accidental release. Finally, they question the ability of sprinklers and smoke control systems to actually reduce the loss of livestock in a fire event. While sprinkler systems have always proven to be extremely effective in controlling the spread of fire, the reality is that prior to sprinkler activation, particularly with dry pipe systems, the size of the fire required to activate a single sprinkler head and the amount of smoke generated before and as the sprinklers bring the fire under control are extensive. The activation of the sprinkler heads would be further delayed due to the rapid air movement throughout the housing due to the ventilation requirements in modern production facilities. Before the fire is extinguished many animals will succumb to smoke or smothering or possibly be exposed to toxic products of combustion which may render them unfit for human consumption and therefore require that they be euthanized. Our farmers and ranchers believe that only pre-loss prevention measures can be effective in reducing the loss of animal lives in livestock and poultry housing. For these reasons, we strongly urge NFPA not to adopt future fire sprinkler amendments impacting Category B animals to the NFPA 150. We stand ready to work with the NFPA 150 Technical Committee on this and other issues and encourage you to adopt this course of action. Sincerely, John E. Starkey President U.S. Poultry and Egg Association 1530 Cooledge Road Tucker, Georgia 30084

5 On behalf of National Pork Producers Council 122 C Street, N.W. Suite 875 Washington, D.C American Farm Bureau Federation 600 Maryland Ave, S.W. Suite 1000W Washington, D.C National Turkey Federation 1225 New York Ave, N.W. Suite 400 Washington, D.C National Cattlemen s Beef Association 1301 Pennsylvania Ave, N.W. Washington, D.C Dairy Farmers of America N. Ambassador Dr. Kansas City, MO Upstate Niagara Cooperative 25 Anderson Road Cheektowaga, NY Agri-Mark Inc; P.O. Box 5800 Lawrence, MA Northeast Dairy Farmers Cooperatives 6354 Alderman Drive Alexandria, VA Dairy Producers of Utah 1315 K Street Modesto, CA United Egg Producers 1720 Windward Concourse Suite 230 Alpharetta, GA National Chicken Council th Street, N.W. Suite 930 Washington, D.C National Council of Farmer Cooperatives 50 F Street N.W. Suite 900 Washington, DC National Milk Producers Federation 2101 Wilson Blvd, Suite 400 Arlington, VA Dairylea Cooperative P.O. Box 4844 Syracuse, NY Select Milk Producers 320 West Hermosa Drive Artesia, NM St. Albans Cooperative Creamery 140 Federal Street, St. Albans, VT Dairy Producers of New Mexico PO Box 6299 Roswell, NM Idaho Dairymen s Association 195 River Vista Place Twin Falls, ID Texas Association of Dairymen Virginia Poultry Association P.O. Box P. O. Box 2277 Austin, TX Harrisonburg, VA 22801

6 Washington State Dairy Federation P.O. Box E. Main Street 2 Elma Washington Milk Producers Council S. Euclid Avenue Ontario, CA cc: Tracy Vecchiarelli, NFPA Staff

7 of 43 12/4/ :17 AM Public Input No. 12-NFPA [ Section No ] This standard shall also apply to existing facilities where any one of the following conditions applies: (1) A change of use or occupancy classification occurs where animals are introduced. (2) A change is made in the subclassification or category of the animals housed. (3) A renovation, modification, reconstruction, or addition is made That affects 50%or more of the total square footage of the facility, or increases the occupied square footage by at least 25%. (4) A building or structure with an animal housing facility is relocated. (5) A building with an animal housing facility is considered damaged, unsafe, or a fire hazard. (6) A property line that affects compliance with any provision of this standard is created or relocated. Any renovation, modification, or reconstruction or addition no matter how minor would prompt application of the new standard to existing structures. The standard as written may deter some building owners from making any modification or repairs in order to avoid application of the standard. Organization: Gallagher Grace Mayer Insurance Submittal Date: Tue Jul 02 16:18:37 EDT 2013 Resolution: FR-1-NFPA Statement: Renovations are not required to comply with new requirements per the Life Safety Code and the Building Code. In this instance, NFPA 150 should not be more restrictive than these Codes. Extensive modifications should trigger compliance with this code. A new annex note was developed to provide guidance on what an extensive modification includes and types of equipment that is excluded. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

8 of 43 12/4/ :17 AM Public Input No. 13-NFPA [ Section No ] In those cases where the authority having jurisdiction determines that the existing situation presents an unacceptable degree of risk, the authority having jurisdiction shall be permitted to apply retroactively any portions of this standard deemed appropriate. This section provides to much authority to the AHJ without the benefit of due process to the property owner. The phrase "unacceptable degree of risk" is ambiguous as each party will have their own "acceptable degree of risk". Organization: Gallagher Grace Mayer Insurance Submittal Date: Tue Jul 02 16:35:24 EDT 2013 Resolution: FR-2-NFPA Statement: The phrase "unacceptable degree of risk" is ambiguous as each party will have their own "acceptable degree of risk". The new language is similar to language in NFPA 1. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

9 of 43 12/4/ :17 AM Public Input No. 2-NFPA [ Section No ] ASTM Publications. ASTM International, 100 Bar Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM E 84, Standard Test Method of Surface Burning Characteristics of Building Material, a ASTM E 1591, Standard Guide for Obtaining Data for Deterministic Fire Models, standards date update Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Thu Dec 27 13:17:56 EST 2012 Resolution: FR-3-NFPA Statement: Update to standards edition date. I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my

10 of 43 12/4/ :17 AM Public Input No. 38-NFPA [ Section No ] Addition. An increase in the building area, aggregate floor area, building height, or number of stories of a structure. [ASCE/SEI 7: : ] It is unclear why the definition in NFPA 150 is being extracted from ASCE/SEI 7 when the definition for the term is located in NFPA The ASCE definition is nearly identical to the definition in NFPA We believe the definition should be extracted from NFPA. Submitter Full Name: Jim Muir Organization: Building Safety Division, Clark County, Washington Affilliation: NFPA Building Code Development Committee (BCDC) Submittal Date: Mon Jul 08 12:52:43 EDT 2013 Resolution: FR-4-NFPA Statement: It is unclear why the definition in NFPA 150 is being extracted from ASCE/SEI 7 when the definition for the term is located in NFPA The ASCE definition is nearly identical to the definition in NFPA We believe the definition should be extracted from NFPA. I, Jim Muir, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this By checking this box I affirm that I am Jim Muir, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my

11 of 43 12/4/ :17 AM Public Input No. 30-NFPA [ Section No ] Fire Resistance Rating. The time, in minutes or hours, that materials or assemblies have withstood a fire exposure as established in accordance with the test procedures of NFPA 251, Standard Methods of Tests of Tests of Fire Resistance of Building Constuction and Materials. [ 220, 2012] tests, or methods based on tests, prescribed by this standard [NFPA 5000]. NFPA 251 has been withdrawn and NFPA 220 now extracts this definition from NFPA ASTM E119 replaces NFPA 251. Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Wed Jul 03 16:21:46 EDT 2013 Resolution: FR-5-NFPA Statement: NFPA 251 has been withdrawn and NFPA 220 now extracts this definition from NFPA ASTM E119 replaces NFPA 251. I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my

12 of 43 12/4/ :17 AM Public Input No. 40-NFPA [ Section No ] Appropriateness of Safeguards. Every facility shall be provided with means of egress and other fire and life safety safeguards of the kinds, numbers, locations, and capacities appropriate to the individual facility, with due regard to the following: (1) Character of the occupancy, including fire load (2) Capabilities Characteristics and capabilities of both the human and animal occupants and their response to fire protection methods (3) Number of animals and persons exposed (4) Fire protection available (5) Height and type of construction of the facility (6) Other factors necessary to provide animal and human occupants with a reasonable degree of safety (7) Other factors necessary to protect the facility and contents from unacceptable damage Additional Proposed Changes File Name Descriptio NFPA_150_4.2.2_13-34_that_carries_over_concepts_from_Rich_Davis_last_ROC_revision_scanned_signature.pdf Cover Sheet The University of Michigan is grateful that safety concepts of this nature are open for public comment through the NFPA/ANSI process and distributed through its vast network of safety experts and stakeholders. This issue is very important because:: a) many colleges and universities have research and teaching facilities with an abundance animals. b) we share the concern for the safety of human and non-human life. c) many colleges and universities are struggling with insufficient capital and operating budgets that may put this particular life safety concern on a lower rank than priorities affecting human life safety. d) there are may be factors that increase the cost and lower the benefit of sprinklers in facilities that house animals. Some facilities are not heated and subject to freezing. This could result in the increased cost of dry sprinkler systems. The animals will remain caged or otherwise restrained and might be harmed by sprinklers operating on them for long periods. Water might accumulate and cause drowning for smaller creatures or nursing young. Lastly, there may not be sufficient design data to assess the hazard, making design difficult for those who must determine a water application rate. It is noteworthy that there are no known prohibitions against installing sprinklers for all animal groups as an Owner option. Where this document may fail is if its provisions become mandatory without more understanding of how different animals may respond to fire protection regimes. Submitter Full Name: Michael Anthony Organization: University of Michigan Submittal Date: Fri Jul 12 07:16:57 EDT 2013

13 of 43 12/4/ :17 AM Resolution: FR-6-NFPA Statement: Research and experience shows that some animals are sensitive to certain fire protection features such as strobes or horns. Consideration should be given to the animal's response to the fire protection features before they are installed. I, Michael Anthony, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright By checking this box I affirm that I am Michael Anthony, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my

14 of 43 12/4/ :17 AM Public Input No. 39-NFPA [ Section No ] System Design and Installation. Any fire protection system, building service equipment, feature of protection, or safeguard provided for fire and life safety shall be designed, installed, and approved in accordance with applicable NFPA codes and standards. Consideration shall be given to the availability of water in agricultural housing and research facilities remote from municipal water supplies. Additional Proposed Changes File Name NFPA_150_4.2.5_ESC_Proposal_on_Davis_concept_13-34_scanned_signature.pdf Description Approved Cover Sheet This is a practical consideration and bright line language to address it will guide planning, design and O&M activities. Submitter Full Name: Michael Anthony Organization: University of Michigan Affilliation: Evergreen State College Submittal Date: Fri Jul 12 07:14:54 EDT 2013 Resolution: The inclusion of agricultural animals in Category B (see FR 15) should satisfy the submitters intent. Category B animals, other than horses are not required to be sprinklered. Research facilities are included in Category A and should be sprinklered. Water supplies for sprinkler systems are addressed by other codes and standards. I, Michael Anthony, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright By checking this box I affirm that I am Michael Anthony, and I agree to be legally bound by the above and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my

15 0 of 43 12/4/ :17 AM Public Input No. 14-NFPA [ Section No ] Where it is evident that a reasonable degree of safety is provided, any requirement shall be permitted to be modified if its application would be hazardous does not present new hazards under normal occupancy conditions in the judgment of the AHJ. The original wording is confusing, I am not sure of the intent of the committee but this revision may be more appropriate to the original intention Organization: Gallagher Grace Mayer Insurance Submittal Date: Tue Jul 02 16:46:48 EDT 2013 Resolution: FR-7-NFPA Statement: The language was modified to match what is in NFPA 101 section By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

16 1 of 43 12/4/ :17 AM Public Input No. 15-NFPA [ Section No ] In accordance with the disaster/emergency management program, equipment designated as necessary for the evacuation or removal of animals, such as halters and leads, shall be worn by or kept near each animal at all times. from the facility shall be made available. Intended personel and equipment shall be implemented to remove animals as quickly as possible to a safe location when it is safe to do so. This standard may be useful for equestrian facilities but is not appropriate for other types of livestock such as swine, poultry and cattle. Organization: Gallagher Grace Mayer Insurance Submittal Date: Tue Jul 02 16:53:30 EDT 2013 Resolution: FR-8-NFPA Statement: The original may be useful for equestrian facilities but is not appropriate for other types of livestock such as swine, poultry and cattle. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

17 2 of 43 12/4/ :17 AM Public Input No. 16-NFPA [ Section No ] * Independent Review. The authority having jurisdiction shall be permitted to require an a mutually approved, independent third party to review the proposed design and provide an evaluation of the design to the authority having jurisdiction at the expense of the owner. If the cost of the third party review is to be born by the owner then it should be one that is agreed upon with both the owner and the AHJ Organization: Gallagher Grace Mayer Insurance Submittal Date: Tue Jul 02 17:07:16 EDT 2013 Resolution: Annex section A provides sufficient guidance and examples of what qualifications are required for the third party reviewer. Approved is an "official definition" referring to an AHJ's review. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

18 3 of 43 12/4/ :17 AM Public Input No. 18-NFPA [ Section No ]

19 4 of 43 12/4/ :17 AM 7.2.2* Additional Requirements.

20 5 of 43 12/4/ :17 AM In addition to the requirements of 7.2.1, the allowable number of stories above grade where the animal housing facilities are permitted and the allowable area per story of animal housing facilities shall not exceed the limits set forth in Table The values in Table for sprinklered facilities shall apply to facilities protected throughout with an approved, electrically supervised automatic sprinkler system in accordance with Section 9.2. Table Allowable Facility Height and Areas Construction Type I (442) I (332) II (222) II (111) II (000) III (211) III (200) IV V (111) V (000) Sprinklered or Nonsprinklered Category A Animals Category B Animals Category A Animals Category B Animals Category A Animals Category B Animals S N S N S N S N S N S N S N S N S N S N Class 1 Facilities Stories UL NP UL NP 12 NP 6 NP 4 NP 6 NP 4 NP 6 NP 4 NP 3 NP Area (1000 UL NP UL NP UL NP 75 NP 46 NP 57 NP 38 NP 72 NP 36 NP 18 NP ft 2 ) Stories UL UL UL UL Area (1000 UL 90 UL 90 UL ft 2 ) Class 2 Facilities Stories UL NP UL NP 12 NP 5 NP 3 NP 5 NP 3 NP 5 NP 4 NP 2 NP Area (1000 UL NP UL NP UL NP 43 NP 25 NP 37 NP 25 NP 41 NP 28 NP 18 NP ft 2 ) Stories UL UL UL UL Area (1000 UL 45 UL 45 UL ft 2 ) Class 3 Facilities Stories UL NP UL NP 12 NP 4 NP 3 NP 4 NP 3 NP 4 NP 3 NP 2 NP Area (1000 UL NP UL NP UL NP 31 NP 19 NP 28 NP 19 NP 30 NP 23 NP 12 NP ft 2 ) Stories UL UL UL UL Area (1000 UL 45 UL 45 UL ft 2 ) For SI units, 1 ft = m, 1 ft 2 = m 2. S: Sprinklered. Allowable facility height in feet and allowable number of stories above grade in facilities protected with an automatic sprinkler system as specified in N: Nonsprinklered. Allowable facility height in feet and allowable number of stories above grade in facilities not protected with an automatic sprinkler system as specified in UL: Unlimited. NP: Not permitted. Note: Within each subclassification, Stories refers to the allowable number of stories above grade where the animal housing facilities are permitted to be located; Area refers to the allowable area per story.

21 6 of 43 12/4/ :17 AM This table does not provide enough information for those not familiar with Construction Types. An explanation should be provided to help the user understand the Roman Numeral and numerical designation. As most livestock facilities are single story structures it may be helpful to start with a table showing single story structures and a second table for multiple story's. Organization: Gallagher Grace Mayer Insuance Submittal Date: Tue Jul 02 17:31:42 EDT 2013 Resolution: The submitter did not suggest any changes to the table. Annex note A was revised to reference documents where the construction classifications are better described. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

22 7 of 43 12/4/ :17 AM Public Input No. 21-NFPA [ Section No ] Stalls, cages, and enclosures housing one or more animals shall allow space for each animal to express all species-typical postures, social adjustment, behaviors, and movements. lie down fully on its side and easily stand back up. The animal should also have adequate room to lie down without having to lie on other animals or on raised feeders. I believe the existing standard is beyond the scope of the committee. There are other entities and authorities from each industry or group that are better prepared to address this issue. Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 14:39:26 EDT 2013 Resolution: FR-10-NFPA Statement: Animal enclosure size requirements are outside the scope of this document. Research is not available to support the required behavioral needs of every animal species. Section was modified to restrict animal enclosures from interfering with egress. The original language in was moved to an annex note to provide one example of egress interference. Section was not modified. Current annex section 7.3 should be removed. A new annex to section A was created from the current section By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

23 8 of 43 12/4/ :17 AM Public Input No. 22-NFPA [ Section No ] Animals shall be able to lie down with limbs extended in a normal manner without obstruction from enclosure sides or having to extend feet through feeder doors or bars. My recommended changes to would eliminate the need for this paragraph. Alternativly the second sentence of my changes to could replace the current sentence. Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 14:52:50 EDT 2013 Resolution: FR-10-NFPA Statement: Animal enclosure size requirements are outside the scope of this document. Research is not available to support the required behavioral needs of every animal species. Section was modified to restrict animal enclosures from interfering with egress. The original language in was moved to an annex note to provide one example of egress interference. Section was not modified. Current annex section 7.3 should be removed. A new annex to section A was created from the current section By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

24 9 of 43 12/4/ :17 AM Public Input No. 20-NFPA [ Section No ] Animal housing facilities shall be separated with a 2 1 -hour fire resistance-rated enclosure from hazardous areas, including, but not limited to, feed rooms, tack rooms, vehicle or equipment storage rooms, blacksmith shops, kitchens, mechanical equipment rooms, and electical rooms and emergancy generators or similar areas. I beleive a 1 hour rated sepeartion is adequate for this standard. The addition of elecrical rooms and emergancy generators is more reflective of modern livestock facilities Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 14:33:57 EDT 2013 Resolution: Many of these spaces including feed rooms and vehicle storage rooms are considered high hazard and should continue to be protected with 2 hour rated separation. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

25 0 of 43 12/4/ :17 AM Public Input No. 19-NFPA [ Section No ] * Category A. Category A animals that can be safely egressed to a holding area, without human contact, shall have adequate means of egress provided. Category A animals encompasses livestock such as swine, dairy, and beef cattle. It is not possible to have large numbers of livestock safely egress with or with out human intervention. In most cases livestock will not move to unfamiliar area willingly. Organization: Gallagher Grace Mayer Insurance Submittal Date: Tue Jul 02 17:45:40 EDT 2013 Resolution: This section only requires Category A animals that can safely be egressed to comply with the egress requirements. It would not include livestock animals. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

26 1 of 43 12/4/ :17 AM Public Input No. 23-NFPA [ Section No ] Two means Two means of egress for human and animal occupants, as a minimum, shall be provided in every facility, section, and area where size, occupancy, and arrangement endanger occupants attempting to use a single means of egress that is blocked by fire or smoke. I suggest ommting "area" as this implies that every area including small rooms or storage areas would require more than one exit Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 14:58:22 EDT 2013 Resolution: The current language is consistent with most building codes and should not be modified. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

27 2 of 43 12/4/ :17 AM Public Input No. 24-NFPA [ Section No ] In animal housing facilities not sprinklered in accordance with Section 9.2, exit travel distance shall not exceed 75 exceed 300 ft (23 m) from any point in the facility. The 75 foot distance is impractical and far more restrictive than other standards for human occupancy. Most jurisdictions use the NFPA 40 for Special Purpose Industrial Occupancy for animal agriculture facilities. Under the NFPA the standardis 300 ft. Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 15:09:19 EDT 2013 Resolution: FR-16-NFPA Statement: Livestock facilities are more comparable to an industrial type facility. The travel distance requirements from NFPA 101 for industrial facilities is 200 ft. A new section was added to allow for 200 ft of travel distance for livestock facilities. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

28 3 of 43 12/4/ :17 AM Public Input No. 25-NFPA [ Section No ] In animal housing facilities sprinklered in accordance with Section 9.2, exit travel distance shall not exceed 100 exceed 400 ft (30 m) from any point in the facility. This standard is far more restrictive than other standards for human occupancy. Most jurisditctions use the NFPA 40 standards for Special Purpose Industrial Occupancy for aniamal agriculture structures that standard calls for 400ft to exit for sprinklered facilities Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 15:15:09 EDT 2013 Resolution: FR-16-NFPA Statement: Livestock facilities are more comparable to an industrial type facility. The travel distance requirements from NFPA 101 for industrial facilities is 200 ft. A new section was added to allow for 200 ft of travel distance for livestock facilities. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

29 4 of 43 12/4/ :17 AM Public Input No. 27-NFPA [ Section No ] Extinguishers in accordance with shall have a minimum 2-A:10-B:C rating and shall be not more than a 50 a 75 ft (15.2 m) travel distance from any point within the animal housing facility. in special purpose or general occupancy areas. Livestock areas not typicly occupied by humans shall have a minimum 2-A:10:B:C extinguisher located at each exit. In animal agriculture structures such as hog farms and dairies many areas are not occupied by humans that can make use of the extinguishers. In modern livestock facilities such as these there are little no combustible materials, minimal electrical systems, and no fuel sources. Due to the large span of these facilities and the size of the animals there is no practical locations to mount the extinguishers. Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 15:57:40 EDT 2013 Resolution: FR-23-NFPA Statement: In animal agriculture structures such as hog farms and dairies many areas are not occupied by humans that can make use of the extinguishers. In modern livestock facilities such as these there are little no combustible materials, minimal electrical systems, and no fuel sources. Due to the large span of these facilities and the size of the animals there is no practical locations to mount the extinguishers. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

30 5 of 43 12/4/ :17 AM Public Input No. 28-NFPA [ Section No. 9.5 ] 9.5 Lightning Protection. Where lightning protection is required by this standard for the animal housing facility, lightning protection shall be in accordance with NFPA 780, Standard for the Installation of Lightning Protection Systems. Most modern livestock raising facilities are steel buildings, and are bonded and grounded. Electrical systems installed in accordance with NFPA 70 are grounded systems. Lightning Arrestors are redundent in these structures and have no functional value. Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 16:11:13 EDT 2013 Resolution: FR-18-NFPA Statement: Lightning requirements are mandated by local building codes. Where required, NFPA 780 should be referenced. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

31 6 of 43 12/4/ :17 AM Public Input No. 29-NFPA [ Section No ] Smoking shall be prohibited except in designated safe areas in animal housing facilities. As improperly discarded smoking materials are a major cause of structural fires, smoking should not be allowed in animal housing facilities or associated structures. Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 16:18:03 EDT 2013 Resolution: FR-19-NFPA Statement: As improperly discarded smoking materials are a major cause of structural fires, smoking should not be allowed in animal housing facilities or associated structures. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

32 7 of 43 12/4/ :17 AM Public Input No. 31-NFPA [ Section No ] Detached noncombustible trash containers located no less than 20ft from any animal housing structure, for other than animal waste, shall be provided and a frequent removal program shall be established. While it is important that waste containers be provided, they should also be located away from the structure to prevent the spread of fire to the building should one occur in the waste conatianer Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 16:21:58 EDT 2013 Resolution: FR-20-NFPA Statement: While it is important that waste containers be provided, they should also be located away from the structure to prevent the spread of fire to the building should one occur in the waste conatianer By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

33 8 of 43 12/4/ :17 AM Public Input No. 32-NFPA [ Section No ] Electrical systems and appliances shall be installed in accordance with the requirements of NFPA 70, National Electrical Code. Animal Agriculture Facilities will be in accordance with Artical 547 for Agricultural Buildings Agricultural Buildings are subject to the Artical 547 standards in many jurisdisctions and is approriate for this standard Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 16:27:21 EDT 2013 Resolution: FR-21-NFPA Statement: Agricultural Buildings are subject to the Article 547 standards in many jurisdictions and is appropriator for this standard. A new annex note was developed to address this. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

34 Public Input No. 8-NFPA [ Section No. 9.8 ] 9.8 Special Requirements for Category A Animals Sprinkler Systems. Animal housing facilities with Category A animals or horses shall be sprinklered throughout in accordance with Section Smoke Control Systems. Animal housing facilities with Category A animals or horses shall have a smoke control system unless modified as approved by the AHJ * Smoke control systems shall be installed, inspected, tested, and maintained in accordance with NFPA 92, Standard for Smoke Control Systems, or nationally recognized standards, engineering guides, or recommended practices The engineer of record shall clearly identify the intent of the system, the design method used, the appropriateness of the method used, and the required means of inspecting, testing, and maintaining the system Acceptance testing shall be performed by a special inspector in accordance with the following: (1) Special inspections and tests shall be performed to verify the operation of the smoke control system in its final condition for acceptance by the AHJ. (2) The design documents shall provide the procedures and methods to be used and items subject to special inspections and tests. (3) The special inspector shall submit an inspection and test report to the AHJ and registered design professional in responsible charge Smoke Control System Operation Smoke control systems shall be automatically activated by sprinkler waterflow, smoke detection, or other approved detection systems in accordance with NFPA 72. Smoke control systems shall remain operational throughout the emergency Means for manual operation of smoke control systems shall be provided at an approved location * Areas Requiring Human Attendance. With the approval of the AHJ, surgical, procedure, and treatment areas where the animals are anesthetized or otherwise require human attendance shall be designed, constructed, and maintained with a defendin-place strategy to allow continued human attendance to minimize the unnecessary loss of animal life * Additional Safeguards. For animal housing facilities with Category A animals, the AHJ shall be permitted to require additional safeguards necessary to protect animal occupants that cannot be safely evacuated. The horse is not an expendable animal but highly prized during its lifetime for its usefulness and value to humans. Fire consumes the lives of horses more frequently than any other animal dying from fire, based on anecdotal evidence compiled over the last four years. During that time, and taking into account only the more widely publicized commercial stable fires, over 250 horses have died from fire in commercial stables, including 35 horses on June 20th, 2013 in Rossville, GA. This proposal extends sprinkler protection and smoke control beyond Category A animals to horses only and, given the scope of the document, this would apply primarily to newly constructed, commercial horse stables. NFPA 150 was originally written in response to racetrack stable fires and was written specifically for the protection of horses and their handlers in those types of facilities. However, with the document expanding its scope to all 9 of 43 12/4/ :17 AM

35 0 of 43 12/4/ :17 AM animals, horses have been relegated to Category B, which encompasses a wide array of animals that do not receive the required sprinkler or smoke control protection afforded to Category A animals. However, horses require this type of protection as they are a highly valuable animal both commercially and therapeutically, and most often die from fire at a time when no humans are on hand to rescue them. Sprinkler and smoke control protection would give horses a fighting chance during the time it takes for handlers and fire service personnel to respond and come to their aid. Submitter Full Name: Joe Scibetta Organization: N/A Submittal Date: Mon Jun 24 15:01:39 EDT 2013 Resolution: FR-11-NFPA Statement: This revision extends sprinkler protection and smoke control beyond Category A animals to horses only and, given the scope of the document, this would apply primarily to newly constructed, commercial horse stables. NFPA 150 was originally written in response to racetrack stable fires and was written specifically for the protection of horses and their handlers in those types of facilities. However, with the document expanding its scope to all animals, horses have been relegated to Category B, which encompasses a wide array of animals that do not receive the required sprinkler or smoke control protection afforded to Category A animals. However, horses require this type of protection as they are a highly valuable animal both commercially and therapeutically, and most often die from fire at a time when no humans are on hand to rescue them. I, Joe Scibetta, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this By checking this box I affirm that I am Joe Scibetta, and I agree to be legally bound by the above and the terms

36 1 of 43 12/4/ :17 AM Public Input No. 17-NFPA [ Section No ] Sprinkler Systems. Animal housing facilities with Category A animals shall be sprinklered throughout in accordance with Section 9.2. This blanket statement is not practical or feasible in most livestock production facilities. In most cases sprinkler systems would be totally ineffective due to numerous issues such as: lack of adequate water supplies in rural areas most fires occur in overhead areas such as attic spaces rather than the livestock floor areas that are non combustible the area normally protected by sprinklers systems is primarily non combustible materials such as concrete and steel modern free stall dairy barns contain almost no combustible materials Organization: Gallagher Grace Mayer Insurance Submittal Date: Tue Jul 02 17:17:56 EDT 2013 Resolution: FR-11-NFPA Statement: This revision extends sprinkler protection and smoke control beyond Category A animals to horses only and, given the scope of the document, this would apply primarily to newly constructed, commercial horse stables. NFPA 150 was originally written in response to racetrack stable fires and was written specifically for the protection of horses and their handlers in those types of facilities. However, with the document expanding its scope to all animals, horses have been relegated to Category B, which encompasses a wide array of animals that do not receive the required sprinkler or smoke control protection afforded to Category A animals. However, horses require this type of protection as they are a highly valuable animal both commercially and therapeutically, and most often die from fire at a time when no humans are on hand to rescue them. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms

37 2 of 43 12/4/ :17 AM Public Input No. 33-NFPA [ Section No ] Sprinkler Systems. Animal housing facilities with Category A animals shall be sprinklered throughout in accordance with Section 9.2. This standard is to broad as sprinkler systems in most livestock raising facilities are not feasible or of no practical benefit. In most rural areas there is not a large enough source of water. In a normal sprinkler systems the discharge is to the occupied space, the occupied space in most of these facilities is non combustible as the floor is concreste the ceiling and fixtures are metal and many of the walls are concrete and wood framing with metal liners. Most of the structure fires occur in the attic space not protected by sprinklers. Most modern free stall dairy barns are steel framed, with metal roof panels. concrete floors and metal headstalls. Many dairies use sand bedding and those that use composed materials are keep the bedding to damp to readily burn. Organization: Gallagher Grace Mayer Insurance Submittal Date: Wed Jul 03 16:41:15 EDT 2013 Resolution: FR-11-NFPA Statement: This revision extends sprinkler protection and smoke control beyond Category A animals to horses only and, given the scope of the document, this would apply primarily to newly constructed, commercial horse stables. NFPA 150 was originally written in response to racetrack stable fires and was written specifically for the protection of horses and their handlers in those types of facilities. However, with the document expanding its scope to all animals, horses have been relegated to Category B, which encompasses a wide array of animals that do not receive the required sprinkler or smoke control protection afforded to Category A animals. However, horses require this type of protection as they are a highly valuable animal both commercially and therapeutically, and most often die from fire at a time when no humans are on hand to rescue them. By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above and the terms