1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M TO: FROM: NFPA Technical Committee on Residential Sprinkler Systems Joanne Goyette DATE: March 16, 2011 SUBJECT: NFPA 13D ROP TC Circulation Ballot (A2012) The March 15, 2011 date for receipt of the NFPA 13D ROP letter ballot has passed. The preliminary ROP ballot results are as follows: 31 Members Eligible to Vote 5 Not Returned (T. Hoover, C. Ketner, S. Rians, H. Shaw, and M. Osburn) In accordance with the NFPA Regulations Governing Committee Projects, 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 Tuesday, March 22, Members who have not returned a ballot may do so now. Such changes should be sent to Joanne Goyette via either to jgoyette@nfpa.org or via fax to You may also mail your ballot to the attention of Joanne Goyette at NFPA, 1 Batterymarch Park, Quincy, MA The return of ballots is required by the Regulations Governing Committee Projects. Attachment: Circulation Explanation Report

2 1 13D (Log # 46 ) Haagensen, D. All viable options to provide fire protection in residential occupancies is worthwhile. However, the submitter is encouraged to address water mist systems for residential occupancies in NFPA 750, as such systems are not within the scope of this Committee. This comment applies to all of the submitter's proposals regarding water mist systems and NFPA 750. O'Brian, M. The submitter has multiple proposals which appear to be outside the scope of the committee. The attempt to provide fire protection in residential occupancies is promising, although appears to be addressed by another standard. 13D-3 1.3, 1.3.1, and (Log # 3 ) Isman, K. This should be flagged for the TCC. It was submitted because it matched NFPA 13, but it was rejected because the language is very bad. It does not belong in NFPA 13D and it should probably be removed from NFPA 13 as well. 13D Dwelling (Log # 89 ) Haagensen, D. The inclusion of townhouses in the scope of NFPA 13D was a major change in scope that the Committee has yet to substantiate. The Committee is also ignoring the major challenges a multi-family structure fire has to a responding fire department trying to provide life safety when compared to the simpler challenge presented by a fire in a detached single-family structure. O'Brian, M. The multi-family townhouse dwellings have fire challenges beyond those addressed in 13d. Orlowski, S. NAHB agrees with the committee's action for rejecting the proposed change to change the scoping requirements of NFPA 13D. National model codes have recognized townhouses as being equivalent to one- and twofamily dwellings since By definition townhouses are one-family dwelling units built in attached groups of three or more with each unit extending from the foundation to the underside of the roof and exposed on at least two sides. Townhouses are required to have a fire resistance-rated wall assembly between the units, the assembly must extend from the foundation to the roof and may not house any plumbing or mechanical ducts or vents in the wall cavity. The model building codes recognize these types of attached dwellings as being the same one- and two-family dwelling units with significant increases to the passive fire resistance requirements to protect the structures on either side of the fire resistance-rated assembly. The proponent is correct that NFIRS does not acknowledge townhouses as one- and twofamily dwellings, but that is not a substantial enough reason to change the scope. As was stated during the technical committee meeting, NFPA reports include townhouses in their fire reports regarding residential home fires and their does not appear to be information that can gleaned from their reports or NFIRS not to permit the NFPA 13D standard as an acceptable sprinkler system in townhouses. For over 25 years, the national model codes have considered townhouses as single family attached dwellings and have been permitted to be constructed under the same building provisions as single family dwellings. Maybe it is time that NFIRS recognizes these buildings for what they are considered under the national model codes. 13D , 4.1.4, 5.2.7, 8.3.2, 8.3.3, A (Log # CP3 )

3 2 Haagensen, D. This Committee is encouraged to vote negative on this approach of using combustible antifreeze, and cease blindly going through the document revision process without revisiting this issue. If the proposed approach for the use of antifreeze products that are KNOWN TO BE COMBUSTIBLE, and are KNOWN TO HAVE CONTRIBUTED TO OCCUPANT CASUALTIES, is not 100% safe, the fire sprinkler industry risks another black eye down the road - especially after all the property owners have undertaken expensive testing and alterations. There are major concerns with the proposed approach. So far, this industry has spiked concentrations so that there are typically large margins of error with the freeze point of the solution. The effect of the proposed changes is to force the industry to extremely low margins of error with the freeze point of the solution, if any margin of error will exist at all. We are likely to experience an increase in freeze ups with these proposed changes. Secondly, the large margin of error with the freezing points in past practice has allowed the industry to essentially ignore climate data and ignore evaluation of the approach used to determine necessary freeze point. The proposed changes suggest that the industry use the Lowest One-Day Mean Low Temperature data. For a community I recently investigated, the Lowest One-Day Mean Low Temperature data indicates necessary freeze protection to approximately -7.5 degrees Fahrenheit. Using the antifreeze characteristics table in the proposed changes, I could install a 48% glycerine solution (freeze point of 50% glycerine identified at degrees Fahrenheit). When looking at the actual temperature data for this community, the average lowest temperature in the month of January is degrees Fahrenheit, and a popular fire protection antifreeze manufacturer lists the freeze point of their 48% glycerine at approximately -13 degrees Fahrenheit. So the user of NFPA 13D, as proposed, is going to be mislead that there is a significant margin of error on the freeze point, when in reality the system is likely to freeze for this particular community. The research done to-date on this issue can hardly be called extensive given the number of different fire sprinklers on the market and the vast possibilities of system arrangements. It is also noted that many recent buildings were constructed in a manner that habitable areas were protected by sprinkler piping that was installed only within the heated envelope of the building - with no significant cost or architectural implications. Lastly, the proposed approach sends a mixed message about combustible antifreeze products - either 50/40% is safe or it is not. Solutions at the same concentration are not going to magically behave differently being in an existing system versus being in a new system. O'Brian, M. The TIA provided clarification for users of the code in a temporary setting. This change does not address the growing concern over the use of anti-freeze in systems. Pilette, M. Reason, response ( same as ) see TIA 1012, 13 D TC Ballot Results, dated

4 3 Puchovsky, M. I vote negatively for the same reasons that I voted to disagree with TIA No (Log#994). The test reports referenced by the proposal and TIA No (Log #994) indicate the effect of antifreeze concentration, systems pressure and sprinkler orifice size on a fire s heat release rate under certain conditions. These test results are not properly reflected in the proposed revisions to NFPA 13D. The proposal recommends concentrations of antifreeze without the limitations on orifice size and system pressure observed during testing. I am not in agreement with the differences in proposed antifreeze concentration between new and existing systems. Newly introduced antifreeze, whether in an exiting system or new system, will result in the same outcome given the same conditions. Based upon the information put forth, it is not reasonable to subject occupants protected by certain existing systems to a higher life safety risk in exchange for freeze protection of system piping, especially when some existing systems will need to be redesigned in accordance with the proposed revisions anyway. While the Proposal s substantiation indicates that safety factors are considered, discussion and confirmation of the safety factors in an explicit manner are lacking. I am not confident that the changes recommended by the Proposal adequately mitigate the risk posed by antifreeze in sprinkler systems intended primarily for life safety. 13D Antifreeze Sprinkler System, 4.1.4, 5.2.7, 8.3.3, and A (Log # 33 ) Haagensen, D. The approach of the previously issued TIA's (10-1) should have been accepted by the Committee in principal, with changes to address the concerns of: (1) future noncombustible antifreeze solutions and (2) other habitable areas beyond the dwelling unit. Pilette, M. Reason, Response, ( same as ) see TIA 1012, 13 D TC Ballot Results, dated Puchovsky, M. The ban on antifreeze should not be lifted until the proposed revisions to the standard are adequately substantiated. See my reasons for voting negatively on proposal 13D-12 (Log # CP3). Feid, J. There still needs to be additional testing and data collection. The application of the correct ratios is arbitrary and very difficult to verify in the field. This unfortunately is a temporary solution. The standard should discourage sprinkler designs that need antifreeze not encourage it. 13D Premixed Antifreeze Solution (New), 4.1.4, and (Log # 74 ) Puchovsky, M. See my reasons for voting negatively on proposal 13D-12 (Log #CP3). Feid, J. See My on 13D-13 (Log #33). 13D Passive Purge System (Log # 72 ) Johnson, G. A passive purge system has always been a type of stand alone system used to eliminate back-flow prevention. The definition of a MP system is that it is intended to serve both domestic and fire protection needs from one pipe system throughout the dwelling unit. (Reference 13D-15, Log 10). Feid, J. This appears to be a plumbing code/ design requirement. Not how the sprinkler system works. 13D (Log # 71 )

5 4 Orlowski, S. The committee needs to recognize that a majority of the residential fire sprinkler systems are connected to the same waterline that feeds the domestic system with an operating pressure between psi. For those systems that are not connected to the public water utility and work off of a well or a pump and tank, the operating pressures can be adjusted to provide the required flow for the residential fire sprinkler system and work within the limitations of various piping materials. There are no requirements within the 13D standard that requires a fire department connection to the system and it makes no sense to have these higher pressure rating requirements on the piping materials used in the fire suppression system that more than likely will not see any operating pressure above the 80 PSI restrictions that are in place on the domestic service. Skare, E. The submitters substantiation already addresses potential options for controlling the incoming water pressure to 80 psi. Additionally, even if the incoming pressure did exceed 80 psi the listings for thermoplastic fire sprinkler pipe require testing at 5 times the rated pressure, thereby providing more than enough of a safety factor. 13D and (Log # 73 ) Johnson, G. This adds confusion to the definition of a MP system. A passive purge system has always been a type of stand alone system used to eliminate back-flow prevention. The definition of a MP system is that it is intended to serve both domestic and fire protection needs from one pipe system throughout the dwelling unit. (Reference 13D-15, Log 10) Victor, T. A sprinkler system with a single plumbing fixture is not a multipurpose piping system based on the revised definition accepted during the ROP meeting. This action conflicts with the action taken on Proposal 13D-15 Log #10 which supposedly clarifies the definition of a Multipurpose Piping system. 13D and (Log # 62 ) Benn, F. I do not believe 130 psi pipe should be allowed. Haagensen, D. This proposed change will encourage the installation of a Pressure Reducing Valve (PRV) where one is not necessary or there are more sound solutions. The introduction of a PRV introduces a substantial failure point (when considering the typical level of maintenance for an NFPA 13D system), and will increase system costs. Johnson, G. This proposal, as worded, will require the installation of a pressure regulating valve on products that meet 175 at 120 and will substantially increase the cost of a residential sprinkler system. The obvious intention of this proposal is to allow all approved plumbing products into stand alone, however, the reality of the way this is written is that this proposal will allow any material meeting 130 at 120 into stand alone. NFPA does not provide enough guidance to third party listing agencies to keep sub-standard material out of stand alone. The end result will be that MP systems will have superior materials compared to stand alone because they must also meet the plumbing code. Stanley, G. I believe that piping used in stand alone system should listed for 175 psi. Adding a pressure regulating valve and a 80 psi limitation only complicates the system for the homeowner. It is my understanding that pressure regulating valves need to be exercised on a routine basis or they could develop problems. Since 13D systems are not required to be inspected and tested by experienced knowledgeable technicians, and a stand alone system is not connected to any plumbing fixtures, then the pipe and fittings should be listed for a higher pressure (175 psi).

6 5 Victor, T. A pressure regulating valve should not be added to a 13D system unless a means is provided to properly test it, including the installation of pressure gauges on either side of the valve. In addition, a requirement needs to be added in the text of 13D to have this device inspected and tested in accordance with NFPA 25, including the frequency of the test and the test method with pass/fail criteria. A pressure regulating valve on a 13D system is a failure point that cannot be ignored and must be tested to ensure proper operation during a fire event. 13D (Log # 60 ) Johnson, G. ASTM F876 allows for a range of PEX materials. Not all of the materials that meet F876 are suitable for fire sprinkler systems. ASTM has recently created designation codes to classify all of the different PEX materials using a designation range from 5006 (the best) to 0006 (untested) should not be allowed in fire sprinkler systems. 13D , (Log # CP7 ) Bell, K. For clarity purposes, the terminology used throughout NFPA 13D for the different types of test connections should be consistent with NFPA 13. For example, the connection used to test a water flow alarm should be referenced as an "alarm test connection" and the connection used to test a pre-action system or dry system should be referenced as a "system test connection." 13D and (Log # 17 ) Feid, J. I was not convinced that sufficient data or research supports the proposal particularly when one of the reason for substantiation is that is provides for the installer to have reduced inventory. 13R systems with residential type sprinklers are understood to provide a different level of protection for the occupants. 13D (Log # 64 ) Orlowski, S. The current provisions found in the NFPA 13D standard makes the disapproval of this proposal seem contradictory at best. According to Section 4.6 smoke alarms shall be provided in accordance with NFPA 72, so if this standard requires smoke alarms to be provided it doesn't make sense that if smoke alarms are not present then a local waterflow alarm shall be provided. There is not a single nationally recognized model building code that does not require smoke alarms in all new one- and two- family dwelling or townhouse. As far as the comments made during the TC meeting regarding international adoption of the NFPA 13D standard, again if you look at section 4.6 smoke alarms are required. It has been discussed at great length during the technical committee meeting, that one of the major reasons for wanting to install waterflow alarms on residential sprinkler systems is to warn the occupant that the system is flowing water in the event that the system has activated in the absence of a fire event. According to a report published by Professor James Milke with the University of Maryland ( 20Detectors%20and%20Sprinklers%20in%20Residential%20and%20Healthcare%20Facilities.pdf), smoke alarms detect and operated in 95% of the reported fires, where only 5% of the fires reported in homes equipped with smoke alarms were too small to active the smoke alarm. Using the same performance guidelines used to assess smoke alarms, it was determined that automatic suppression systems detected and operated in 46% of the reported fires, while 54% of the systems did not activate since the fires were too small to activate the sprinkler. According to tests conducted by NIST and reported in TN-1455, smoke alarms activated within 40 seconds from the point of ignition and the residential sprinklers activated within 140 seconds of the ignition of the fire. Smoke alarms are proven to be faster at detecting, alerting, and notifying occupants that there is a fire, requiring a local waterflow alarm on a residential fire suppression system is redundant and not essential to life safety.

7 6 13D (Log # 66 ) Benn, F. I believe Flow Switches should be required. 98% of areas requiring residential sprinkler systems. per NFRF, require Flow Switches. Home insurance companies give much better credits on insurance rates if Flow Switches are installed. Deegan, T. Water flow alarms add significant value at a small cost. They should be included on all systems. Feid, J. It is important to have a signal produced when water is flowing in a sprinkler system. Unchecked it could result in significant damage. The political consequences of such a requirement do not have merit. The consequences for the homeowner are more important. Grove, J. As noted by submitter, fire sprinkler systems need waterflow alarms, even for NFPA 13D systems. Haagensen, D. Most jurisdictions that have enacted sprinkler ordinances to-date have included a requirement for a water-flow alarm. Many are missing the point that a water-flow alarm is beneficial when the fire sprinkler system has done what it is supposed to do - activate in case of a fire. There are documented fires where the waterflow alarm alerted non-occupants of a fire, and the fire department has been notified and responded to limit the water damage after the fire was extinguished by the fire sprinklers. The requirement to install a waterflow alarm can cost-effectively benefit the public image of residential fire sprinklers. The purpose for the waterflow alarm requirement has nothing to do with system leakage, which is related to the quality of the installation and is no more likely than with unmonitored domestic plumbing systems. Isman, K. Johnson, G. All fire sprinkler systems need waterflow alarms. Local water flow alarms should be required on all sprinkler systems to prevent water damage. Schwab, P. Smoke detectors do provide advanced warning and should activate prior to the fire sprinkler system. However, smoke detectors are not provided in all of the areas of the dwelling unit that sprinklers are. The cost of providing the alarm is minimal. Stanek, S. All sprinkler systems should have a flow switch. Substantial water damage will occur without notification of sprinkler waterflow. Stanley, G. Fire sprinkler systems need a water flow alarm to help protect the homeowner in the event of a fire. This alarm would alert the immediate public to a fire event inside the home and increase life safety for a minimal cost.

8 7 Van Walraven, E. I agree with the original submitter that: Fire sprinkler systems need waterflow alarms. It is irresponsible to design a fire sprinkler system that does not produce some sort of signal when water is flowing in the system. There also is material supporting this concept as stated in the annex of the 2010 edition of NFPA 13D section A.7.6 The local waterflow alarm is intended to be a single alarm audible from the outside of the building. It can be mounted on the outside of the home or within the building close to the outside. This should not limit its use to prevent interior or remote notification. Interconnection with a smoke alarm or remote monitoring might improve notification, but is considered too costly to mandate for every system installed in accordance with this standard. It is not the intent of this standard to require central station monitoring or a fire alarm system. An exterior alarm can be of benefit in areas where a neighbor could alert the fire department or to enhance the ability for an assisted rescue by a passerby. We have had instances where the notification devices alerted the neighbors of water flow and the fire department was in turn dispatched lessening the impact of flowing water. There are very economical and cost effective methods available to the home owner and contractors to achieve this for both interior and exterior notification. Also as stated elsewhere many jurisdictions already require some form of audible notification for fire sprinkler systems, this provision would provide necessary notification and consistency in the standard. Orlowski, S. See Comment on 13D-57 (Log #64). 13D (Log # 18 ) Benn, F. See my Explanation of on Proposal 13D-58 (Log #66). Deegan, T. Water flow alarms add significant value at a small cost. They should be included on all systems. Feid, J. It is important to have a signal produced when water is flowing in a sprinkler system. Unchecked it could result in significant damage. The political consequences of such a requirement do not have merit. The consequences for the homeowner are more important. Grove, J. As noted by submitter, fire sprinkler systems need waterflow alarms, even for NFPA 13D systems. Isman, K. See my Explanation of on Proposal 13D-58 (Log #66). Schwab, P. Smoke detectors do provide advanced warning and should activate prior to the fire sprinkler system. However, smoke detectors are not provided in all of the areas of the dwelling unit that sprinklers are. The cost of providing the alarm is minimal. Stanek, S. See my Explanation of on Proposal 13D-58 (Log #66). Stanley, G. Fire sprinkler systems need a water flow alarm to help protect the homeowner in the event of a fire. This alarm would alert the immediate public to a fire event inside the home and increase life safety for a minimal cost. Orlowski, S. See Comment on 13D-57 (Log #64).

9 8 Sigler, M. The TC was correct in rejecting this proposal. The successful adoption of fire sprinkler provisions within residential codes was based on the promises that such systems could be installed cost effectively and without system malfunctions. However, by adding water flow alarms to all sprinkler systems, without any data to substantiate such costs, will most likely not be looked upon favorably by the court of public opinion. Furthermore, the argument that water flow alarms are necessary to alert neighbors of not only a potential fire, but a possible malfunction, is not valid. For one, the decibel level of interconnected smoke alarms is more than sufficient to alert neighbors. Second, mandating water flow alarms to alert a neighbor of a system malfunction is reaching considering that there is more of a likelihood of a toilet overflowing, and causing damage, than a sprinkler system malfunctioning. 13D (Log # CP9 ) Schwab, P. I agree that this language is long overdue and will benefit the end user. I am however concerned that (1) does not take into account flat beamed or soffitted ceilings. This is a very common finish used in single family construction. I hope that the FPRF undertakes additional testing for this scenario or the committee adds rules specifically addressing these ceiling configurations. 13D (Log # 30 ) Feid, J. It is important to have AHJ approval for devices that are used beyond the listing. There are too many alternatives that simply would not be acceptable in any ones mind. Haagensen, D. The proposed language is necessary so that installers/designers are not given `carte blanche'. The current language of the standard removes the ability of the AHJ to reject proposals that are absurd and not technically substantiated. The language is in direct conflict with the traditional NFPA document approach to alternate/new technologies, which require technical substantiation and AHJ approval. O'Brian, M. The language as proposed is necessary to avoid poor installation practices and gain approval from the AHJ when work is performed outside the listing. 13D (Log # 22 ) Schwab, P. This is not an accept in principle. The proposal encompasses beamed ceilings both flat and sloped. The committee should provide rules for flat beamed ceilings as well in 13D-67 (Log #CP9). 13D x (New) (Log # 93 ) Schwab, P. This new section also does not limit the area to 15 SQ FT total for the dry areas. One could conceivably have multiple shadow areas in the protection area of a single sprinkler which could seriously impact the ability of the sprinkler to maintain tenability in the compartment. There was also no test data submitted in the 13R proposal. 13D , , , , (Log # CP16 )

10 9 Schwab, P. In rooms/compartments of this size a designer can do a separate calculation for the maximum spacing allowed for the particular sprinkler used. Generally this will not be as demanding as the calculation for the larger living areas with water demands up to 2 sprinklers. If the committee is contemplating allowing a sprinkler to be spaced 12 feet from a wall they should lift the 400 SQ. FT. maximum requirement and allow the manufacturers to pass the listing tests with that extended spacing. 13D (Log # 45 ) Haagensen, D. See explanation for vote on Proposal 13D D (Log # 51 ) Haagensen, D. See explanation for vote on Proposal 13D D and A (Log # 52 ) Haagensen, D. See explanation for vote on Proposal 13D D-85 Table 8.4.4(c), 8.4.4(d) (Log # CP10 ) Haagensen, D. The change is unnecessary and editorially incomplete. 13D (Log # 63 ) Johnson, G. Fuel fired equipment in the attic should be protected. 13D (New) (Log # 91 ) Deegan, T. Given the intent to eliminate sprinklers to protect fuel fired equipment in such cases, I believe its important to provide notification. The suggested follow up with NFPA 72 should be pursued. 13D (Log # 1 ) Haagensen, D. Concerned about the ramifications of using this exception with multiple qualifying `compartments' that are adjacent to each other. O'Brian, M. Deleting the section appears to create a gap in the area and have multiple ceiling pockets in a home. 13D (Log # 28 ) Haagensen, D. Concerned about the ramifications of using this exception with multiple qualifying `compartments' that are adjacent to each other. O'Brian, M. See comments to 13d D-94 Chapter 9 (new) (Log # CP14 )

11 10 Puchovsky, M. Antifreeze as currently proposed should not be used to protect piping from freezing in NFPA 13D applications. See my reasons for voting negatively on proposal 13D-12 (Log #CP3). 13D-104 A (Log # CP20 ) Skare, E. There is no technical justification for avoiding flow switches with delays, which are common on multipurpose systems. 13D-108 A (Log # 53 ) Benn, F. Should be changed to allow the use of any Anti-Freeze listed and approved for CPVC pipe. Deegan, T. I agree with the committees action to eliminate reference to PB pipe. References to glycerine only should be expanded to include other listed antifreeze solutions. References to CPVC pipe should be expanded to include all non-metallic pipes.