Report of the Committee on Craig C. Campbell, Venting Systems for Cooking Appliances Leonard E. Griffes, David P. Demers, Harry P.

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1 Copyright 2001, NFPA Report of the Committee on Venting Systems for David P. Demers, Chair Demers Associates Inc., MA [SE] Phil Ackland, Phillip Ackland Holdings Ltd., Canada [SE] Bernard P. Besal, Besal Services, Inc., GA [IM] Rep. International Kitchen Exhaust Cleaning Association David R. Bouchard, Fire Consulting Associates Inc., RI [SE] Lawrence J. Capalbo, Flame Gard, Inc., CA [M] Laurence W. Caraway, Jr., Kitchen Klean Inc., NH [IM] Lee C. DeVito, FIREPRO Inc., MA [SE] Robert C. Duncan, Reedy Creek Improvement District, FL [E] David L. Foster, Insurance Services Office, Inc., NY [I] Rod Getz, Getz Fire Equipment, IL [IM] Rep. Nat l Assn. of Fire Equipment Distributors Inc. Charles H. Gibbons, Jr., Lampert, Lee & Associates, WI [SE] Ted W. Giles, Giles Enterprises, Inc., AL [M] Rep. Gas Appliance Manufacturers Association Inc. Donald L. Griffes, NEVTEC, VT [M] Edward J. Hard, Koorsen Protection Services, OH [IM] Gary G. Hopson, AON Risk Services, MI [I] William Klingenmaier, Ansul Incorporated/Tyco, WI [M] Rep. Fire Equipment Manufacturers Association R. T. Leicht, Deleware Fire Marshal s Office, DE [E] Rep. International Fire Marshals Association Steven F. Levin, Royal & Sun Alliance, IL [I] Rep. American Insurance Services Group Philip O. Morton, Gaylord Industries Inc., OR [M] Michael A. O Hara, The MountainStar Group, MN [M] Irina K. Rashfal, Intertek Testing Services, N.A., Inc., GA [RT] Daniel P. Restelli, Underwriters Laboratories Inc., IL [RT] Harry Schildkraut, Cini-Little Int l., Inc., IL [SE] Rep. Foodservice Consultants Society Int l. Christopher R. Schulz, Van-Packer Co., Inc., IL [M] Emmanuel A. Sopeju, Underwriters Laboratories of Canada, Canada [RT] Anthony J. Spata, McDonald s Corporaton, IL [U] Lawrence E. Stahl, Stahl Enterprises Inc., NC [U] Rep. National Restaurant Association Laurie K. Szumla, Lane Fire & Safety, NY [IM] James F. Valentine, Jr., James F. Valentine, Jr., Inc., NJ [SE] Bruce A. Zimmerman, AVTEC Industries Inc., FL [M] Alternates Tammy Lynn Bitting, Van-Packer Co., IL [M] (Alt. to C. R. Schulz) C. Douglas Burnett, Giles Enterprises, Inc., AL [M] (Alt. to T. W. Giles) Craig C. Campbell, Harleysville Insurance Co., PA [I] (Alt. to S. F. Levin) Leonard E. Griffes, NEVTEC Ltd., VT [M] (Alt. to D. L. Griffes) Harry P. Jones, Underwriters Laboratories Inc., IL [RT] (Alt. to D. P. Restelli) Fred E. Kahn, Guardian Power Cleaning of Dallas, Inc., TX [IM] (Alt. to B. P. Besal) Richard Kukla, Robert Rippe & Assoc., MN [SE] (Alt. to H. Schildkraut) Daryl Mirza, Gurnee, IL [SE] (Alt. to P. Ackland) James Shea, Kidde-Fenwal, MA [M] (Alt. to W. Klingenmaier) Staff Liaison: James D. Lake Committee Scope: This Committee shall have primary responsibility for documents on fire safety in the design, installation, and use of exhaust systems (including hoods, grease removal devices, exhaust ducts, dampers, air-moving devices; and auxiliary equipment) for the removal of products of combustion, heat, grease, and vapors from cooking equipment, including the application of associated fire extinguishing systems. This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. This portion of the Technical Committee Report of the Committee on Venting Systems for is presented for adoption. This Report on Comments was prepared by the Technical Committee on Venting Systems for, and documents its action on the comments received on its Report on Proposals on NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations, 1998 edition, as published in the Report on Proposals for the 2001 May Meeting. This Report on Comments has been submitted to letter ballot of the Technical Committee on Venting Systems for Cooking Appliances, which consists of 30 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. 8

2 (Log #CC2) (Entire Document): Accept COMMENT ON PROPOSAL NO: 96-3 RECOMMENDATION: Editorially incorporate accepted proposal materials into the manual of style revised chapters. Ensure that the accepted revisions modify the proposed text as revised. SUBSTANTIATION: Due to an editorial error the Technical Committee accepted editorial changes to comply with the NFPA Manual of Style and Public Proposed changes to the same sections. The Technical committee omitted from the committee action to incorporate the accepted changes into the proposed manual of style revisions. (Log #1) (1-1): Reject RECOMMENDATION: It is suggested that item 2 under the proposed new be modified to read as follows: 2. Facility is protected by automatic sprinklers in accordance with NFPA 13, NFPA 13R, or isolated area sprinklers meeting the provisions of of NFPA 101, Life Safety Code. SUBSTANTIATION: This proposal will provide another sprinkler option that I feel is reasonable for the protection of residential equipment. This is especially true if the cooking is restricted to that not involving frying. I feel that the final safeguard, "Subject to the approval of the Authority Having Jurisdiction", would provide reasonable assurance that the provisions of would not be abused. I feel that the overall committee proposal is a step in the right direction for the use of residential equipment in a variety of settings. COMMITTEE STATEMENT: See Comment 96-5 (Log#5). When only residential equipment is used, sprinkler protection is not necessary. (Log #2) (1-1): Reject RECOMMENDATION: It is suggested that item 4 under the proposed new be modified to read as follows: 4. The residential equipment is restricted to cooking not involving the frying of foods. Facility is not an Assembly Occupancy. SUBSTANTIATION: I feel that restricting the type of cooking is more important than restricting the occupancy classification. There are small assembly occupancies other than "church and meeting halls" where residential equipment can be reasonably safeguarded as provided for in the proposed I feel that the final safeguard, "Subject to the approval of the Authority Having Jurisdiction", would provide reasonable assurance that the provisions of would not be abused. I feel that the overall committee proposal is a step in the right direction for the use of residential equipment in a variety of settings. COMMITTEE STATEMENT: See Comment 96-4 (Log# 4). There are other potentially hazardous cooking operations. (Log #4) (1-1): Reject RECOMMENDATION: Delete text as follows: 4. Facility is not an Assembly Occupancy. SUBSTANTIATION: If "residential" type equipment presents no significant hazard, such evaluation shouldn t be affected by the type of occupancy at which it is found. That is, if there is a reduced level of hazard due the size and limited usage of the equipment, how is the hazard increased merely because the occupancy is a Place of Assembly? In fact, in the proposed annex section, the exception specifically indicates that it applies to "church and meeting halls", which are Places of Assembly. COMMITTEE STATEMENT: The life safety risk associated with assembly occupancies requires protection. Keeping the text gives examples of when protection is needed. (Log #5) (1-1): Accept RECOMMENDATION: Delete text as follows: 2. Facility is protected by automatic sprinklers in accordance with NFPA 13 or NFPA 13R. SUBSTANTIATION: If "residential" type equipment presents no significant hazard, such evaluation shouldn t be affected by the level of building protection that is provided. That is, if there is little chance of a problem erupting within this equipment when the building is sprinklered, how are the chances of a problem increased just because the building is not sprinklered. (Log #32) (1-1): Accept in Principle in Part SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Reject the committee proposal and revise A-1.1 to read: A.1.1 The application of this standard is concerned with the potential fire hazard of cooking operations, irrespective of the type of cooking equipment used and whether used in public or private facilities. This standard is also intended to include residential cooking equipment where used for purposes other than residential family use, such as employee kitchens or break areas and church and meeting hall kitchens, regardless of frequency of use. Because this standard cannot address specific installations, the judgment should be made by the authority having jurisdiction. This judgment should take into account the type of cooking being performed, items being cooked and the frequency of cooking operations. This standard applies to cooking operations where grease laden vapors are produced and accumulated. Cooking operation even in commercial operations that only heat items that do not produce grease laden vapors are not required to comply with this standard. Examples of operations that may not require compliance with this standard are: Day care centers warming bottles and lunches, Churches and meeting operations that are not cooking meals that produce grease laden vapors, and employee break rooms where food is warmed. SUBSTANTIATION: As proposed in the Committee Proposal it is more confusion than currently worded. It also is not consistent with the current standard and requires fire protection that is not currently required within 96. The proposed text better clarifies the intent of the standard without adding the confusing language. COMMITTEE ACTION: Accept in Principle in Part. Do not accept the rejection of the committee proposal. 9

3 Replace the proposed annex to A with the following sentences: "This judgment should take into account the type of cooking being performed, items being cooked and the frequency of cooking operations. Examples of operations that may not require compliance with this standard are: Day care centers warming bottles and lunches, therapy cooking facilities in healthcare, Churches and meeting operations that are not cooking meals that produce grease laden vapors, and employee break rooms where food is warmed. " COMMITTEE STATEMENT: The committee felt the flexibility in the application of this standard was by the authority having jurisdiction and was necessary and the rejection of the original proposal was not justified. (Log #38) (1-1): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee, 96-5 RECOMMENDATION: We are not sure what the intent of these two proposals are. They are inconsistent with each other. SUBSTANTIATION: The wording on these proposals is inconsistent with each other. We are not sure of what the committee s intent is when these two proposals are combined. As currently proposed there are two sets of requirements that were accepted by the Technical Committee dealing with the same text. COMMITTEE STATEMENT: Inconsistencies with Manual of Style will be addressed in the paste up stage. No specific wording was submitted. (Log #17) (1-1.4): Reject RECOMMENDATION: It is suggested that item 2 under the proposed new be modified to read as follows: "2. Facility is protected by automatic sprinklers in accordance with NFPA 13, NFPA 13R, or isolated area sprinklers meeting the provisions of of NFPA 101, Life Safety Code." SUBSTANTIATION: This proposal will provide another sprinkler option that I feel is reasonable for the protection of residential equipment. This is especially true if the cooking is restricted to that not involving frying. I feel that the final safeguard, "Subject to the approval of the Authority Having Jurisdiction", would provide reasonable assurance that the provisions of would not be abused. I feel that the overall committee proposal is a step in the right direction for the use of residential equipment in a variety of settings. COMMITTEE STATEMENT: See Committee Action on Comment 96-2 (Log# 1). (Log #18) (1-1.4): Reject RECOMMENDATION: It is suggested that item 4 under the proposed new be modified to read as follows: "4. The residential equipment is restricted to cooking not involving the frying of foods." Facility is not an Assembly Occupancy. SUBSTANTIATION: I feel that restricting the type of cooking is more important than restricting the occupancy classification. There are small assembly occupancies other than "church and meeting halls" where residential equipment can be reasonably safeguarded as provided for in the proposed I feel that the final safeguard, "Subject to the approval of the Authority Having Jurisdiction", would provide reasonable assurance that the provisions of would not be abused. I feel that the overall committee proposal is a step in the right direction for the use of residential equipment in a variety of settings. COMMITTEE STATEMENT: See Committee Action taken on Comment 96-4 (Log# 4). There are other potentially hazardous cooking operations. (Log #24) ( ): Accept in Principle SUBMITTER: Glen Edgar, Selkirk Inc. COMMENT ON PROPOSAL NO: RECOMMENDATION: Revise text to read as follows: "Horizontal ducting support systems for non-listed grease duct systems larger than 24 in. in any dimension shall be designed for the weight of the ductwork plus pounds at any point in the duct systems." SUBSTANTIATION: The original proposal should exempt listed grease duct systems because their supports have already been evaluated per the Standard for Grease Ducts, UL1978. UL1978 incorporates a factor of safety of 4 which is fairly common in a variety of safety standards and would seem adequate and appropriate to address the expressed concern over adequacy of supports for personnel entry for cleaning and inspection. The proposed change of the 1000 pound reference to 800 pounds is based upon such factor of safety. The inclusion of the reference to 24 in. is intended to address the comments of the committee member who voted against the proposal. Such comments are legitimate and appropriate. COMMITTEE ACTION: Accept in Principle. Revise to read as follows: "Horizontal ducting support systems for non-listed grease duct systems 24 in. and larger in any cross-sectional dimension shall be designed for the weight of the ductwork plus pounds at any point in the duct systems." COMMITTEE STATEMENT: The cross sectional dimension clarifies that the 24 in. does not apply to length of the duct. A 24 in. duct was included in the requirement. (Log #39) ( ): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: RECOMMENDATION: Reject the original proposal. SUBSTANTIATION: We agree with the negative from Mr. Stahl. This is overly restrictive in all systems and there has been no technical justification or loss history to support this change. COMMITTEE STATEMENT: The committee feels a duct hanger strength requirement is necessary. (Log #20) ( ): Reject SUBMITTER: Kenneth M. Elovitz, Foxboro, MA COMMENT ON PROPOSAL NO: RECOMMENDATION: Delete the prohibition against butt welds. 10

4 SUBSTANTIATION: This requirement was introduced to the standard in The justification at the time was "Butt welds are virtually impossible to properly align, and to weld in a grease tight manner." That statement is simply not true. Large industrial ducts like those used for electrostatic precipitators and pipes as big as a man used for high pressure gas transmission lines are field welded gas and liquid tight every day. The prohibition against butt welded ducts is simply one (former) committee member s design preference. Requirements that do not have scientific or engineering basis undermine the authority and integrity of the standard. Moreover, the three joint designs permitted in the standard create opportunities for grease to accumulate in joints and pockets. Butt welded duct does not have that problem. COMMITTEE STATEMENT: The committee feels that common practice and field experience to get a continuous liquid tight seal with a butt weld is not reliable. (Log #6) (5-2.1): Reject 3 RECOMMENDATION: Reject the original proposal and the Committee Action and return text to that which appears in the 1998 edition of the Standard. SUBSTANTIATION: In accordance with the Committee s Statement, the change was being made "awaiting the final ASHRAE report" that would substantiate the change. In the absence of the report, the Committee would be making a change without substantiation. As of date, the report has not been made available. Adopting new material without having documentation available for public review, scrutiny, and comment is a violation of NFPA s Code-Making process. COMMITTEE STATEMENT: The ASHRAE report does exist at this time. The report is ASHRAE report 1033 RP. AFFIRMATIVE: 28 NEGATIVE: 1 EXPLANATION OF NEGATIVE: LEICHT: I oppose the action of the Committee on this issue, not necessarily on any technical basis, but on a "procedural" basis. The substantiation by the submitter states that the documentation that supports the proposal was never provided to the Committee. As of the end of October 2000, long after the Public Comment closing date, a printed copy of the report in question was not available to the public from ASHRAE. As of November 15, 2000, the report is still not available through an "Internet" means. At the ROC meeting of the Committee, a single copy of a preliminary draft of the report was made available to the submitter just 30 minutes prior to the deliberation on this issue. As with any research paper, the document is lengthy (well over 100 pages), and as such it could only be reviewed in a cursory manner. Although no technical issues were obvious to this reader in this short amount of time, the conclusions of the report seemed to be based on a number of conditions; grease droplet size, density, temperature, etc. Since the Committee had little, if any opportunity to review the report, it is likely that the public, especially enforcers and users, had NO opportunity to review it. Therefore, since the cornerstone of NFPA s process is consensus, I contend that rejecting the comment is in violation of NFPA s goal and intent. (Log #15) (6-1): Reject 8 RECOMMENDATION: Add wording, in order to involve the authority having jurisdiction in the exception from the rule, as follows: "Dampers shall not be installed in exhaust ducts or exhaust duct systems. Exception: Where permitted by the authority having jurisdiction, dampers specifically listed for such use or required as part of a listed or approved device or system may be installed. SUBSTANTIATION: The rule is that there be no dampers in the exhaust. The authority having jurisdiction should not be prevented by the Committee from exercising his prerogative of approving or not approving an exception to the rule. Specifically, some authorities having jurisdiction want to allow the listed dampers or dampers in listed devices or systems only in listed "water-wash" type exhaust systems. The primary purpose of requiring the exhaust to continue running is to entrain cooler air thus reducing the chance of reignition of the cooking surfaces. COMMITTEE STATEMENT: The intent of the committee is expressed in Section and and the listing of the hood. (Log #8) (7-2.5): Accept COMMENT ON PROPOSAL NO: RECOMMENDATION: Add a portion of the original proposal that the committee deleted entirely when the full proposal was Accepted in Principle. d. Sealing of valves and approved weekly recorded inspection SUBSTANTIATION: Sealing of valves, when coupled with weekly recorded inspections, is a valid method of supervising fire protection valves. In fact, some feel that it supervises the valve better than a mere lock since a lock method does not require any routine verification that the lock is in place or if the valve is even open. By inspecting the valve, it will be verified at least weekly, that the valve is open. (Log #9) (7-2.5): Accept COMMENT ON PROPOSAL NO: RECOMMENDATION: Add to the original proposal as follows: Water Valve Supervision. Valves controlling the water supply to listed fixed baffle hood assemblies and/or automatic fire extinguishing systems shall be listed indicating type valves and shall be supervised open by one of the following methods: SUBSTANTIATION: The fire protection industry recognizes that the use of indicating type valves greatly reduces the chances of a critical water supply valve being impaired unnoticed. Other standards that address valves in water supplies to fire protection systems mandate the valves be of the listed indicating type. COMMITTEE STATEMENT: Supervision of the valves is satisfactory for an acceptable level of reliability. (Log #3) (7-5.1): Accept in Principle COMMENT ON PROPOSAL NO: RECOMMENDATION: Amend the accepted revised text to read as follows: A readily accessible means of manual activation shall be located as determined by the authority having jurisdiction so that fire involving the cooking equipment or the exhaust system will not prevent access to the means of manual activation. located between 1067 mm and 1219 mm (42 in. and 48 in.) above the floor, located in a path of exit or egress from the area of risk, and clearly identify the hazard protected. 11

5 SUBSTANTIATION: There is a need for the text to deal with the location of the means of manual activation in relation to the fire risks. Being that the activation of the suppression system is the primary action to be taken by staff to deal with a fire emergency, it is important that the means of manual activation be so located that staff will not be placed at risk in attempting to activate the system or will not take the needed action because of fear the manual means is too close to the risk. The AHJ, the system installer, and those expected to activate the system need committee guidance as to where such means need to be located in relation to the hazard. The submitter in offered some reasonable distances, however, the committee saw fit to reject the lesser figure as being "overly restrictive" for small cooking facilities. There is a need for the committee to reconsider the matter. It was felt best to address the matter by offering a proposal based on text already accepted by the committee. COMMITTEE ACTION: Accept in Principle. Revise to read as follows: "A readily accessible means for manual activation shall be located between 1067 mm and 1219 mm (42 in. and 48 in.) above the floor, be accessible in the event of a fire, be located in a path of egress, and clearly identify the hazard protected" COMMITTEE STATEMENT: It is difficult to prescribe a numeric distance from the hazard that the manual activation is to be located as some distances may be physically impossible to meet in some locations. The intent is to have the manual activation accessible in the event of the fire. (Log #16) (7-5.1): Reject COMMENT ON PROPOSAL NO: RECOMMENDATION: Delete Exception No. 1. SUBSTANTIATION: The original proposal to the 1994 edition appears in A98-ROP as Proposal (Log #22) and was Accepted in Principle by the Technical Committee at their meeting in San Antonio in March The Committee Statement references the action on (Log #CP1). However, (Log #CP1) includes additional wording in the form of Exception No. 1 which dissents form the principle that was supposingly Accepted. No additional substantiation was provided. The intent of the original proposal was to provide true redundancy in that an impairment of any portion of either the automatic mode or the manual mode would not cause the impairment of the other. The present Exception would allow a fault (such as a hang-up in a turnbuckle) between the manual activation means and the control head or releasing to prevent the ability to activate the system by either mode. COMMITTEE STATEMENT: The requirement is consistent with NFPA 17A, Standard for Wet Chemical Extinguishing Systems. For clarification, the comment was to delete of Proposal (Log #CP28). (Log #19) (7-5.1): Accept in Principle COMMENT ON PROPOSAL NO: RECOMMENDATION: Amend the accepted revised text to read as follows: "A readily accessible means of manual activation shall be located as determined by the authority having jurisdiction so that fire involving the cooking equipment or the exhaust system will not prevent access to the means of manual activation, located between 1067 mm and 1219 mm (42 in. and 48 in.) above the floor, located in a path of exit or egress from the area of risk, and clearly identify the hazard protected." SUBSTANTIATION: There is a need for the text to deal with the location of the means of manual activation in relation to the fire risks. Being that the activation of the suppression system is the primary action to be taken by staff to deal with a fire emergency, it is important that the means of manual activation be so located that staff will not be placed at risk in attempting to activate the system or will not take the needed action because of fear the manual means is too close to the risk. The authority having jurisdiction, the system installer, and those expected to activate the system need committee guidance as to where such means need to be located in relation to the hazard. The submitter in offered some reasonable distances, however, the committee saw fit to reject the lesser figure as being "overly restrictive for small cooking facilities". There is a need for the committee to reconsider the matter. It was felt best to address the matter by offering a proposal based on text already accepted by the committee. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: See Committee Action taken on Comment (Log# 3). (Log #36) (7-5.1): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: RECOMMENDATION: Add to the end of to read: A readily accessible manual actuation device shall be located between 1067 mm and 1219 mm (42 in. and 48 in.) above the floor, at or near a means of egress from the cooking area, a minimum of 3 ft and a maximum of (20 ft) 6096 mm from the kitchen exhaust system in a location acceptable to the authority having jurisidiction. SUBSTANTIATION: There needs to be guidance on the location of manual activation devices. The intent is to provide the manual device in a safe location away from the cooking hazards. The proposal was looking for 10 ft minimum which the committee felt would not adequately address small kitchens, the proposed wording clarifies that all kitchens should be able to meet the 3 ft minimum and also permits the authority having jurisdiction to approve the location of the manual activation device. Ready access to the manual activation to activate the system should be done in a location that is a safe distance from the hazard taking into account the many configurations of kitchens. COMMITTEE STATEMENT: The Committee Action on Comment (Log#3) addresses the location. (Log #14) (8-2.2): Reject COMMENT ON PROPOSAL NO: RECOMMENDATION: Insert the following requirements between proposed and Exhaust air volumes for single island canopy and double island canopy types hoods shall be at least 300 CFM per linear foot of cooking equipment and at least 150 CFM multiplied by the square foot cross sectional area of the hood; whichever is greater Where solid fuel equipment is used under single island canopy and double island canopy type hoods, exhaust air volumes shall be at least 300 CFM multiplied by the square foot cross sectional area of the hood Exhaust air volumes for hoods other than single island canopy or double island canopy types shall be at least 300 CFM per linear foot of cooking equipment and at least 100 CFM multiplied by the square foot cross sectional area of the hood; whichever is greater Where solid fuel equipment is used under hoods of other than the single island canopy or double island canopy type, exhaust air volumes shall be at least 200 CFM multiplied by the square foot cross sectional area of the hood. 12

6 SUBSTANTIATION: The intent of the Comment is to provide the enforcer some means of enforcing specific requirements. The present language is vague and not specific. The above values mirror the exact values that are currently being used in the industry. If the industry standard is under review (as had been indicated by the Committee Statement in Proposal 96-44; Log #11 of the May 2001 ROP), then there is no reason why the present values can t be added into this document at this time. As research proves that different values are warranted, a future proposal, or even a Tentative Interim Amendment, can be generated. During the debate within the Committee, the statement was made that specific values are not needed in this document since the Fire Official doesn t scrutinize this portion of an installation, the mechanical code inspector does. This is not true. Regulation differs from jurisdiction to jurisdiction. In some jurisdictions, there is no mechanical code inspector and the Fire Official enforces his entire fire code, which usually includes NFPA 96. In other jurisdictions, the Fire Official will do all inspections except the actual building construction, which is done by the Building Official. It should also be noted that the term "Authority Having Jurisdiction" is not restricted to a fire official. For instance, an insurance agent may be an AHJ but is certainly not bound to adopt and/or enforce a Mechanical Code. Traditionally, the insurance industry adopts the NFPA standards. Finally, NFPA has established that their long-term goal is to provide cods for the entire "built environment" without the need to depend on standards outside of the NFPA process. As such, it would seem necessary that we provide specific criteria within our Standard without reliance on obscure and imprecise language that forces the user to explore other publications. COMMITTEE STATEMENT: The committee felt that current ongoing research has not yet developed requirements or guidance that adequately addresses this issue. (Log #7) (9-1.2): Reject 6 RECOMMENDATION: Revise text as follows: Where the authority having jurisdiction requires an exhaust system component that incorporates a damper and where specifically listed for such use or where required as part of a listed device or system, dampers in exhaust ducts or exhaust duct systems shall be permitted. SUBSTANTIATION: Just because there are exhaust hoods listed that incorporate dampers is not a reason to permit them without some justification. The primary purpose of requiring the exhaust to continue running after extinguishing system actuation is to continue to entrain cooler air thus reducing the chance of reignition of the cooking surfaces. In eight weeks, this writer experienced three instances where a damper in an installation that would have allowed a listed exhaust hood without a damper, inadvertently closed. As a result, heat built up and caused the fire extinguishing system to actuate although there was no fire. Not only was the owner faced with the cost of the recharge of the extinguishing system, reset of the hood and the massive clean-up but also the loss of business...all as a result of something that didn t have to be. COMMITTEE STATEMENT: See Committee Action on Comment (Log#15). (Log #26) (9-1.2): Reject 6 RECOMMENDATION: It is suggested that be made an exception to 9.1.1, which prohibits dampers. COMMITTEE STATEMENT: Inconsistent with the Manual of Style which eliminated (Log #37) (9-2): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: RECOMMENDATION: Reconsider the proposal and accept. SUBSTANTIATION: We agree with the negative comment by Mr. Leicht and the original proposal should be accepted. COMMITTEE STATEMENT: This committee feels that the added safety device is overly restrictive and is not needed. If a problem does exist in the field, this issue should be brought to the committee s attention. (Log #27) (9-2.2): Reject 6 RECOMMENDATION: It is suggested that be made an exception to 9.2.1, which prohibits dampers. (Log #28) ( and ): Reject 6 RECOMMENDATION: It is suggested that and be made an exceptions to , which prohibits lighting units in concealed spaces. Is needed? (Log #29) ( and ): Reject RECOMMENDATION: It is suggested that and be made exceptions to , which requires simultaneous automatic operation. 13

7 (Log #33) (10-4.1): Reject SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise text to read as follows: 10.4 Fuel Shutoff Upon activation of any fire-extinguishing system for a cooking operation, all sources of fuel and electric power that produce heat to all equipment requiring protection by that system and all other electrical equipment within the protected area shall automatically shut off. SUBSTANTIATION: All electrical equipment under the hood should have its power disconnected in the event of a fire extinguishing system activation. Electrical equipment can also be a fire source. There has been much discussion on the conductivity of Class K extinguishers and with requiring the electrical equipment shutdown this hazard should be prevented. COMMITTEE STATEMENT: The committee is not aware of any electrical hazards when the fire suppression system is activated. (Log #30) (10-4.2, and ): Reject RECOMMENDATION: It is suggested that , and be made exceptions to , which provides for the shut off of certain equipment under hoods. (Log #CC5) ( ): Hold RECOMMENDATION: Add text to read as follows: The reset mechanism for the shut off device shall be at a location in direct line of sight with the cooking equipment. ANNEX: The intent is so that the fuel shut off device cannot be manually reset from a remote location. Controls may need to be closed, pilot lights lit and thermostats turned down. SUBSTANTIATION: COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The committee will need to study this issue further. (Log #31) ( and ): Reject RECOMMENDATION: It is suggested that and be made exceptions to (Log #40) (10-5.5): Accept in Part RECOMMENDATION: It is suggested that be revised as follows and that be made an exception to : "The means for manual activation actuator(s) shall be mechanical and or shall not rely on electrical power for activation in accordance with Section COMMITTEE ACTION: Accept in Part. Do not accept the recommendation on making and exception. In the recommendation, only change "actuator(s)" to "activation". (Log #34) (10-6.1): Reject SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise to read: Upon activation of an automatic fire-extinguishing system, an audible alarm or visual indicator in the vicinity of the protected area shall be provided to show that the system has activated. SUBSTANTIATION: It is unclear what the intent of this section is. Is it for the notification of the building occupants or to notify personnel in the area of the cooking operation? The proposed wording clarifies that the alarm or indicator is to notify personnel in the establishment that the system has been discharged and requires servicing. Potentially, an owner could resume operations after cleanup without putting the fire protection system back in service. The system could appear perfectly normal and even have a current inspection tag. COMMITTEE STATEMENT: Existing equipment already provides notification of activation of the equipment. (Log #35) (10-8.1): Reject SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise to read: Hoods containing automatic fire-extinguishing systems throughout the hood are considered protected areas; therefore, these hoods are not considered obstructions to overhead sprinkler systems and shall not require floor coverage underneath. 14

8 SUBSTANTIATION: As currently worded parts of the hood could be unprotected based on the type of equipment installed. The elimination of the sprinkler system in this instance could be detrimental to the building. As proposed you could not take the obstruction exception without the entire hood being protected by a fire extinguishing system. Many times the hood is larger than the cooking appliances and other equipment is under the hood that does not require protection. The proposed language clarifies when the exception can be applied. COMMITTEE STATEMENT: Existing requirement addresses the issue of sprinkler obstruction. Sequence number not used. (Log #CC9) (11-2.1): Hold RECOMMENDATION: Revise to read as follows: An inspection and servicing of the fire extinguishing system and listed exhaust hoods containing a constant or fire activated water system shall be made at least every 6 months by properly trained, qualified and certified persons(s) or company. SUBSTANTIATION: Certification is an important component of inspecting and servicing the fire extinguishing system. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: New material. (Log #11) (11-2.4): Accept RECOMMENDATION: Delete the final phrase in the sentence Fusible links (including... where required by the manufacturer to ensure proper operation of the system. SUBSTANTIATION: No requirement is expected to ensure (or guarantee) anything! It is not the intent of the Standard to establish the individual purpose of each specific requirement. This is outside the parameters of the Manual of Style. If there is a need to provide additional guidance by expressing the reasons why particular requirements are in the Standard, it should be expressed in the Appendix. (Log #CC7) (11-2.5): Accept RECOMMENDATION: Revise to read as follows: " The year of manufacture and the date of installation of the fusible links shall be marked on the system inspection tag. The tag shall be signed or initialed by the installer." Renumber existing SUBSTANTIATION: This will correlate with NFPA 17A. (Log #CC6) (11-3 and ): Hold RECOMMENDATION: Revise as follows: "11.3 Inspection of Exhaust Systems The entire exhaust system shall be inspected for contamination from grease-laden vapors by a properly..." SUBSTANTIATION: This defines the parameters of inspection by certified people. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: New material. (Log #12) ( ): Reject RECOMMENDATION: Delete the word "certified" by a trained, and qualified and certified company or person(s) acceptable to the authority having jurisdiction... SUBSTANTIATION: The word "certified", in this context, is subjective. It is not specified who provides the certification, when the certification took place, or how the certification was acquired. Since it is the duty of the AHJ to approve vendors, materials, and methods used within his jurisdiction, it is not necessary to require the company or person(s) to be both acceptable to the AHJ and certified. Since the AHJ determines what certifications, if any are necessary in his jurisdiction, the additional word "certified", is superfluous. For instance, if an AHJ feels that a business owner is trained and qualified to do this work but not necessarily certified by anyone, then the Standard should not limit or impede him from exercising his prerogative to render such a judgment. COMMITTEE STATEMENT: Certification is an important component of the inspection process. (Log #25) (11-4 and A (New)): Reject SUBMITTER: Glen Edgar, Selkirk Inc. COMMENT ON PROPOSAL NO: RECOMMENDATION: Revise text to read as follows: 11-4 "Exhaust Systems for Solid Fuel Cooking. Where a hood is not required, in buildings where the duct system is 3 2 stories or less in height and horizontal runs are less than 40 ft in length, a duct complying with Chapter 4 shall be provided." "If a hood is used in buildings where the duct system is 3 2 stories or less in height and horizontal runs are less than 40 ft in length, the duct system shall comply with Chapter 4." * "Exhaust Systems for Solid Fuel Cooking Stories in Height or Greater or with horizontal runs in excess of 40 ft. A listed or approved grease duct system or a duct/chimney constructed as for a high heat appliance per NFPA 211 shall be provided." (Proposed new paragraph in Appendix) A Exhaust Systems for Solid Fuel Cooking. - 3 Stories in height or greater or with horizontal runs in excess of 40 ft. These types of installations present a particularly difficult and dangerous situation for fire fighters. In such installations the ducts are more difficult to clean thus fires have been more prevalent. Often the fire in such duct is very difficult to fight and the fire protective barrier may fail. By limiting the type of duct to that which has demonstrated an ability to withstand such extreme fire conditions, an appropriately higher factor of safety is achieved. SUBSTANTIATION: The committee action on the original proposal was indicated as "Accept in Principle" but actually seems much more like "Accept in Principle in (small) Part" or "Reject", 15

9 since the proposal was modified considerably. The committee proposal to also allow an "approved" grease duct fails to address the issue originally raised, puts the responsibility back on the AHJ and could result in the continued use of something which has a record of failing in the applications in question. The proposed revision puts the location of the change in requirements back to that originally proposed and also addresses the original proponent s issue more completely. Fires in tall (or extremely long horizontal) grease ducts associated with solid fuel burning appliances can be extremely severe. In many areas of the country, small local Fire Departments may not have the equipment/capability to fight such fires effectively. The new proposal addresses much of the original proponent s concern by suggesting the duct system needs to be, in effect a "high heat chimney" (as the original proponent suggested) or a listed grease duct complying with UL This will increase the level of safety for these, worst case installations. We believe listed grease ducts can be included because they have demonstrated the ability to "pass" a 2000 F internal fire test exposure for 30 minutes while protecting surrounding combustible construction and sustaining no permanent damage. (Evidence of permanent damage/failure includes buckling, bowing, distortion, broken welds, etc.) It is a well-known fact that generic, welded systems are unable to sustain these types of high temperature exposure without severe damage/failure. It is believed that the inclusion of a paragraph in the Appendix providing further explanation will assist in both clarifying the need for such additional requirements/limitations as well as increase an awareness of the need for same. COMMITTEE STATEMENT: The recommendation was more restrictive without more substantiation. (Log #13) (11-4.1): Reject RECOMMENDATION: Delete the word "certified" by a trained, and qualified and certified company or person(s) acceptable to the authority having jurisdiction... SUBSTANTIATION: The word "certified", in this context, is subjective. It is not specified who provides the certification, when the certification took place, or how the certification was acquired. Since it is the duty of the AHJ to approve vendors, materials, and methods used within his jurisdiction, it is not necessary to require the company or person(s) to be both acceptable to the AHJ and certified. Since the AHJ determines what certifications, if any are necessary in his jurisdiction, the additional word "certified", is superfluous. For instance, if an AHJ feels that a business owner is trained and qualified to do this work but not necessarily certified by anyone, then the Standard should not limit or impede him from exercising his prerogative to render such a judgment. COMMITTEE STATEMENT: Certification is an important component of the cleaning process. (Log #CC1) (11-5, , and ): Hold COMMENT ON PROPOSAL NO: 96-6 RECOMMENDATION: Add a new section to the end of the new Chapter 11 [(Comment 96-6 (Log #CP29) entitled "Procedures for the Use and Maintenance of Equipment" to read as follows: 11.5 Cooking Equipment Maintenance An inspection and servicing of the cooking equipment shall be made at least annually by properly trained and qualified persons Cooking equipment shall have high limit devices inspected and if found defective be serviced or replaced in accordance with manufacturer s recommendations Cooking equipment that has a tendency to collect grease below the surface such as griddles or char boilers shall be inspected and if found with grease accumulation cleaned by properly trained and certified person. SUBSTANTIATION: There is a need to address the maintenance of the cooking equipment to prevent fires. The cooking equipment should be maintained in order for the high temperature limit switch to work properly as well as other safety features. Note: Supporting material available for review upon request at NFPA headquarters. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: New material. (Log #22) (Chapter 12): Accept SUBMITTER: Howard Hopper, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: RECOMMENDATION: Update references to read as follows: Other Publications ASTM Publications. American Society for Testing and Materials. 100 Barr Harbor Drive, West Conshohocken, PA ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials, ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 C, EPA Publication. Environmental Protection (EPA), Crystal Station, 2800 Crystal Drive, Arlington, VA EPA Test Methods202, Determination of Condensable Particulate Emissions for Stationary Sources UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL UL 197, Standard for Safety Commercial Electric Cooking Appliances, UL 300, Standard for Fire Testing of Fire Extinguishing Systems for Protection of Restaurant Cooking Areas, UL 723, Standard for Test For Surface Burning Characteristics of Building Materials, UL 1046, Standard for Grease Filters for Exhaust Ducts, SUBSTANTIATION: Revisions provide the correct titles of UL Standards and current edition dates of those standards. (Log #CC3) (12-1.2): Hold COMMENT ON PROPOSAL NO: RECOMMENDATION: Add to the following references: Kitchen Exhaust Cleaning & Certification Manual Inspection Manual for Commercial Kitchen Exhaust Systems SUBSTANTIATION: The information in these manuals provide additional education regarding inspection and cleaning of kitchen exhaust systems. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: New material. 16

10 (Log #23) (A-4-5.1): Reject SUBMITTER: Glen Edgar, Selkirk Inc. COMMENT ON PROPOSAL NO: RECOMMENDATION: Change wording to "Examples of acceptable materials for ducts include: 1. Carbon Steel, 2. Calvanized steel, 3 Stainless steel." SUBSTANTIATION: This issue is already covered in Paragraph However, it appears the committee may desire to add/clarify that galvanized steel is an option. We do not believe galvanized steel is an acceptable option for fabrication of welded ducts and should not be referenced. The galvanized coating on galvanized steel is burned off in any welding operation and the remaining weld has poor corrosion protection. In addition, respiration of the fumes from the overheating of galvanized steel is a fairly well known/documented health hazard. Overheating can occur both during welding operations as well as if/when a fire occurs in the duct. COMMITTEE STATEMENT: Galvanized steel is an acceptable material. AFFIRMATIVE: 28 NEGATIVE: 1 EXPLANATION OF NEGATIVE: HOPSON: I felt that the general consensus of the committee was that Galvanized Steel is an acceptable material to be used for ducts, however it is difficult to field weld. For that reason, I feel it should be eliminated as an example since it would promote its use, which could lead to leaks from inadequate field welds. (Log #21) (A-8-2.2): Accept RECOMMENDATION: Add the following informational text to the Appendix: "The date of manufacture marked on fusible metal alloy sensing elements does not limit when they can be used. These devices have unlimited shelf life. The intent of is to require replacement of fusible metal alloy sensing elements that have been installed for up to 1 year in environments subjecting them to contaminant-loading, such as grease in restaurant hoods and ducts that could adversely affect their proper operation." SUBSTANTIATION: Provide information to the user as to the intent of the requirement. This text reflects the exact language as that found in A of NFPA 17A. (Log #10) (A-7-2.5(d) (New) ): Accept COMMENT ON PROPOSAL NO: RECOMMENDATION: Add an annex to the original proposal: A-7-2.5(d) An approved weekly recorded inspection could consist of a mere log of entries that would display the date and time of the inspection and the initials of the persons conducting the visual inspection. By attaching the log onto a clipboard and mounting it near the valve in question serves as a convenient reminder of the need to conduct the inspection. SUBSTANTIATION: Provide guidance to the user of a means of complying with the requirement in an acceptable and time proven manner. Editorially delete the word "mere". 17