Public Comment No. 32-NFPA 90A-2016 [ Section No ] Statement of Problem and Substantiation for Public Comment

Transcription

1 of 53 11/9/2016 9:07 AM Public Comment No. 32-NFPA 90A-2016 [ Section No ] ASTM International Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM C411, Standard Test Method for Hot-Surface Performance of High-Temperature Thermal Insulation, 2011., ASTM D93, Standard Test Methods for Flashpoint by Pensky-Martens Closed Cup Tester, a., ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2013a 2015b., ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials, 2012a 2016., ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 C, , ASTM E2231, Standard Practice for Specimen Preparation and Mounting of Pipe and Duct Insulation Materials to Assess Surface Burning Characteristics, , ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-Shaped Airflow Stabilizer, at 750 C, date updates First Revision No. 1-NFPA 90A-2015 [Section No. 2.3] Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Wed May 04 17:22:22 EDT 2016 Rejected but see related SR SR-1-NFPA 90A-2016 Statement: date updates

2 of 53 11/9/2016 9:07 AM Public Comment No. 36-NFPA 90A-2016 [ Section No ] UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL ANSI/UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors, ANSI/UL 181A, Standard for Safety Closure Systems for Use with Rigid Air Ducts, ANSI/UL 181B, Standard for Safety Closure Systems for Use with Flexible Air Ducts and Air Connectors, ANSI/UL 263, Standard for Fire Tests of Building Construction and Materials, 2011, Revised ANSI/UL 555, Standard for Safety Fire Dampers, 2006, Revised2014. ANSI/UL 555C, Standard for Safety Ceiling Dampers,2014. ANSI/UL 555S, Standard for Safety Smoke Dampers, ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, 2008, Revised ANSI/UL 867, Standard for Safety Electrostatic Air Cleaners, 2011, Revised ANSI/UL 900, Standard for Safety Air Filter Units, ANSI/UL 1598,Luminaires, ANSI/UL 1820, Standard for Safety Fire Test of Pneumatic Tubing for Flame and Smoke Characteristics, 2004, Revised ANSI/UL 1887, Standard for Safety Fire Test of Plastic Sprinkler Pipe for Visible Flame and Smoke Characteristics, 2004, Revised ANSI/UL 1995, Standard for Safety Heating and Cooling Equipment, ANSI/UL 2024, Standard for Safety for Cable Routing Assemblies and Communications,2014, Revised ANSI/UL 2043, Standard for Safety Fire Test for Heat and Visible Smoke Release for Discrete Products and Their Accessories Installed in Air-Handling Spaces, UL 2518, Outline of Investigation for Air Dispersion System Materials, ANSI/UL 2846, Fire Test of Plastic Water Distribution Plumbing Pipe for Visible Flame and Smoke Characteristics, ANSI/UL 2846, Standard for Fire Test of Plastic Water Distribution Plumbing Pipe for Visible Flame and Smoke Characteristics, ANSI/UL , Standard for Safety of Household and Similar Electrical Appliances, Part 2-40: Particular Requirements for Electrical Heat Pumps, Air-Conditioners and Dehumidifiers A reference to ANSI/UL is being added as it is anticipated that ANSI/UL 1995 will be withdrawn by UL and replaced by ANSI/UL by the year 2020.

3 of 53 11/9/2016 9:07 AM First Revision No. 1-NFPA 90A-2015 [Section No. 2.3] Submitter Full Name: Ronald Farr Organization: UL LLC Submittal Date: Mon May 16 13:17:20 EDT 2016 Accepted SR-2-NFPA 90A-2016 Statement: A reference to ANSI/UL is being added as it is anticipated that ANSI/UL 1995 will be withdrawn by UL and replaced by ANSI/UL by the year 2020.

4 of 53 11/9/2016 9:07 AM Public Comment No. 2-NFPA 90A-2016 [ Section No ] 3.3.3* Air Connector. A conduit for transferring air between an air duct or plenum and an air terminal unit or an air inlet or air outlet. This is a limited use product. Air connectors are not UL listed air ducts. Additional Proposed Changes File Name Description Approved Connector_attached_at_floor.pdf Air connector attached to a register boot in a second floor wall cavity. No flame penetration test is required for air connectors and this allows for failure of smoke control and drafting into the second floor essentially bypassing the floor assembly. Justification: UL has a testing protocol for air connectors and air ducts. This consist of 16 test. Air connectors are only required to pass 13 of these 16 test. The three they do not have to pass are flame penetration, puncture, and impact test. Many times air connectors are used connected to a 1 inch collar penetrating a fire/smoke assembly. Allowing the use of air connectors next to these fire assemblies without passing the flame penetration test allows for smoke to immediately by pass the fire smoke assembly. Submittal Date: Fri Feb 26 14:50:07 EST 2016

5 of 53 11/9/2016 9:07 AM Public Comment No. 4-NFPA 90A-2016 [ Section No ] Air Distribution System. A continuous passageway for the transmission of air that, in addition to air ducts, can include air connectors, air duct fittings, dampers, plenums, fans, and accessory air-handling equipment but that does not include conditioned spaces. Additional Proposed Changes File Name Description Approved Air_Connector_connecting_furnace_return_and_path_to_first_floor.pdf This diagram shows how fire and smoke can jump floor to floor due to no flame penetration testing required for air connectors. Why does NFPA require draft stop material around openings when you allow a product that fails with fire immediately and allows smoke and fire to jump floor to floor or into a wall cavity. NFPA requires draft stopping on penetrations but about every 8 feet NFPA allows for air connectors attached to floor boots that do not pass a flame penetration test. These floor boots are about every 8 foot on the perimeter of the floor making a perfect situation to help fire and smoke spread quickly. It is like allowing balloon framing again. Seems so odd that the small cracks around a duct have to be draft stopped but consideration for the inside of the duct is not considered. Submittal Date: Tue Mar 01 15:09:24 EST 2016

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7 of 53 11/9/2016 9:07 AM Public Comment No. 3-NFPA 90A-2016 [ Section No ] Air Duct. A conduit or passageway for conveying air to or from heating, cooling, air-conditioning, or ventilating equipment, but not including the plenum. Flexable air ducts shall meet UL 181. Additional Proposed Changes boot_into_second_floor_air_connector.jpg File Name Description Approved Picture_of_UL_listed_Air_Duct_vs_air_connector_taking_a_flame.pdf This picture shows how the fire and smoke can use the duct system to allow smoke and fire to jump floor to floor. Air connectors do not pass a flame penetration test so air connectors can immediately fail and allow fire and smoke to jump floor to floor or in a wall cavity. This is the same HVAC duct connection showing one connection with an air duct and one connection with a UL listed air duct. The air connector does not pass the flame penetration test and will

8 of 53 11/9/2016 9:07 AM Air_Connector_connecting_furnace_return_and_path_to_first_floor.pdf allow smoke and fire to jump floors or into a wall cavity quickly. This diagram shows how fire and smoke have a huge void to allow for fire and smoke to jump to the first floor. For classification as an air duct UL has developed 16 test. To be classified as an air duct all 16 test must be passed. Currently there is a lot of confusion on what an air connector is and what an air duct is. This will help code officials determine what is an air duct. by allowing air connectors to be called air ducts leads to confusion on what is an air duct and what is and air connector. NFPA defines what an air duct is, then NFPA defines what and air connector is, and NFPA then turns around and says an air connector is an air duct. An air connector is not an air duct as per UL 181 so please don't use the term air duct to describe a air connector. Submittal Date: Tue Mar 01 14:46:32 EST 2016

9 of 53 11/9/2016 9:07 AM Public Comment No. 5-NFPA 90A-2016 [ New Section after ] Raised Floor Plenum. The space between the top of the finished floor and the underside of a raised floor not used to supply air to the occupied area or to return air to or exhaust air from the occupied area. There are 2 applications for raised floors. One is used as a supply duct and the other as an access for wiring etc. 2 separate applications should have 2 separate definitions. Submittal Date: Tue Mar 01 15:20:48 EST 2016

10 0 of 53 11/9/2016 9:07 AM Public Comment No. 37-NFPA 90A-2016 [ Section No ] The requirements of and shall not apply to equipment tested and listed in accordance with ANSI/UL 1995, Standard for Safety Heating and Cooling Equipment or ANSI/UL , Standard for Safety of Household and Similar Electrical Appliances, Part 2-40: Particular Requirements for Electrical Heat Pumps, Air-Conditioners and Dehumidifiers. The additional reference to ANSI/UL is being added as it is anticipated that ANSI/UL 1995 will be withdrawn by UL by the end of 2020 and replaced by ANSI/UL The reference to ANSI/UL has been added to 2.3.6, UL Publications. First Revision No. 1-NFPA 90A-2015 [Section No. 2.3] Submitter Full Name: Ronald Farr Organization: UL LLC Submittal Date: Mon May 16 13:39:36 EDT 2016 Accepted SR-3-NFPA 90A-2016 Statement: The additional reference to ANSI/UL is being added as it is anticipated that ANSI/UL 1995 will be withdrawn by UL by the end of 2020 and replaced by ANSI/UL The reference to ANSI/UL has been added to 2.3.6, UL Publications.

11 1 of 53 11/9/2016 9:07 AM Public Comment No. 7-NFPA 90A-2016 [ Section No ] Class 0 or Class 1 rigid or flexible air ducts tested in accordance with ANSI/UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors, and installed in conformance with the conditions of listing shall be permitted to be used for ducts where air temperature in the ducts does not exceed 121 C (250 F) or where used as vertical ducts serving not more than two adjacent stories in height. Additional Proposed Changes File Name Pictures_of_air_connector_used_on_the_other_side_of_a_1_hour_fire_rarted_ceiling.pdf Description Approved This photo shows how it is currently not against any code to use air connectors attached to a short fitting (2") right up tight to a fire rated ceiling. Why bother with a fire rated ceiling if it allowed to have penetrations with air connectors attached to the ceiling. It is not right to have multiple penetrations with no flame penetration test required on products that penetrate a fire wall or

12 2 of 53 11/9/2016 9:07 AM Drafting_required_around_air_connector.jpg Connector_going_through_several_assembelies.jpg Connector_going_throgh_floor_with_a_elbow.jpg Connector_being_used_to_penatrate_floor_with_short_register_boot.jpg ceiling. The photo is for the irony of it all. Requiring draft stop material around a product that does not pass a flame penetration test. One quick flame on the air connector and wide open hole is in that assembly. Allowing the use of air connectors can lead to several assemblies being breached with one HVAC duct run. This shows how using air connector can breach a floor assembly easily. This is a typical application of using air connectors. About every 8 feet around the perimeter of a building has a floor boot through the floor.

13 3 of 53 11/9/2016 9:07 AM Air_Connector_connecting_furnace_return_and_path_to_first_floor.pdf Allowing several penetrations for flame and smoke spread. This illustration shows how a huge hole is in the floor and how air connector can allow fire and smoke spread to go from one area to the other. On a side note for humor "at least the gap around the outside of the duct is draft stopped" :-) Stop the spread of smoke and fire. UL has a testing protocol for air connectors and air ducts. This consist of 16 test. Air connectors are only required to pass 13 of these 16 test. The three they do not have to pass are flame penetration, puncture, and impact test. Many times air connectors are used connected to a 1 inch collar penetrating a fire/smoke assembly. Allowing the use of air connectors next to these fire assemblies without passing the flame penetration test allows for smoke to immediately by pass the fire smoke assembly. Air connectors do not pass the UL flame penetration test and should not be used in HVAC duct systems. The IAPMO sub comittee on duct construction is recommending to remove air connectors as a product to be used in HVAC duct systems.

14 4 of 53 11/9/2016 9:07 AM Submittal Date: Tue Mar 01 16:46:48 EST 2016

15 5 of 53 11/9/2016 9:07 AM Public Comment No. 28-NFPA 90A-2016 [ Section No ] Gypsum Board Air Ducts Gypsum board having a flame spread index not exceeding 25 without evidence of continued progressive combustion and a smoke developed index not exceeding 50 when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, shall be permitted to be used for negative pressure exhaust and return ducts where the temperature of the conveyed air does not exceed 52 C (125 F) in normal service The air temperature limits of shall not apply where gypsum board material is used for emergency smoke exhaust air ducts. Additional Proposed Changes File Name _from_manufacture_saying_no_testing_has_been_done_on_sheet_rock_as_metal_ducts.pdf Eliminate the fire and smoke hazard created by allowing people to build HVAC ducts how they feel like doing it verses building the ducts to a recognized standard. Description There is no standard to build gypsum wall board ducts. No manufactures have done testing on this. What if any standard does one have to follow when constructing HVAC ducts our of gypsum wall board?

16 6 of 53 11/9/2016 9:07 AM Submittal Date: Thu Mar 03 15:33:14 EST 2016

17 7 of 53 11/9/2016 9:07 AM Public Comment No. 6-NFPA 90A-2016 [ Section No ] Gypsum board having a flame spread index not exceeding 25 without evidence of continued progressive combustion and a smoke developed index not exceeding 50 when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, shall be permitted to be used for negative pressure exhaust and return ducts where the temperature of the conveyed air does not exceed 52 C (125 F) in normal service. Additional Proposed Changes File Name Description Ap National_Gypsum_Association_stand_on_not_using_gypsum_board_as_HVAC_ductwork.pdf All HVAC duct work is built to a national standard except gypsum ductwork. SMACNA leads the way in these standards. Flex duct goes through UL testing to get approved. Phenolic is and has gone through an extensive process to have industry standards. Why can people just use gypsum board anyway they want to for HVAC ducts? There is no standard for building gypsum ducts, that I am aware of or anyone on ASHRAE TC 5.2 Duct construction technical committee know of. What standard are gypsum ducts sealed to? What type of tape is used on these ducts? NFPA requires UL 181 testing for tapes on duct work, but if a person uses gypsum they can use an untested paper tape to seal it up? IF there are standards for gypsum ducts they should be allowed if there are not standards gypsum should not be used until there are standards developed for making HVAC duct work out of gypsum boards. Can people use 1/4 gypsum for ducts? Does it have to be 3/8" thick? Does it have to fire rated? If so why? If not why? These are communications from the Gypsum Association and USG on not using gypsum as HVAC ductwork.

18 8 of 53 11/9/2016 9:07 AM Submittal Date: Tue Mar 01 16:30:40 EST 2016

19 9 of 53 11/9/2016 9:07 AM Public Comment No. 8-NFPA 90A-2016 [ Section No ] The air temperature limits of shall not apply where gypsum board material is used for emergency smoke exhaust air ducts. Additional Proposed Changes File Name Description Ap National_Gypsum_Association_stand_on_not_using_gypsum_board_as_HVAC_ductwork.pdf Eliminate this exemption. The gypsum association technical director says not to use this material and have documented gypsum is not a viable material for HVAC ducts at temperatures above 125 degrees F. Along with gypsum board being a porous surface that absorbs material from the air stream. Toxins from smoke can be absorbed by the gypsum board and stay in the building. These smoke evac shafts are typically in non-accessible areas and to remove them after a smoke evac event is nearly impossible and very expensive. Gypsum wall board cannot be cleaned with any duct cleaning machines on the market today. These smoke evac ducts are used many times during a buildings life. They are not only used once in a catastrophe. Even the toxins from smoke candles can impregnated into the gypsum. Many of these smoke evac ducts have a very high static pressure. This can be a positive pressure if the fan is located in the building. When the fan is located in the building this static pressure will put even more pressure and along with the heat from the fire/smoke on the gypsum board causing it to fail and the smoke at that point will not be pushed outside of the building. At what point do these ducts fail? At what point can these ducts fail? All code approved duct work is built to a standard. SMACNA leads the way in these standards. There are no standards that these gypsum board ducts systems are built to. To date I have only found one gypsum board company that makes any construction standard when using their wall board as an air shaft and it must be constructed to a 2 hour fire rating with specified bracing and supports. If this is allowed NFPA at a minimum should require the designed system must be built to that company s standard. I can provide that standard upon request. Communication on the use of gypsum used as HVAC duct work. 3 conditions which must be met, and information there is no national standard on how to build duct work using gypsum.

20 0 of 53 11/9/2016 9:07 AM The gypsum association also recommends that the dew point is never reached inside a gypsum duct. During a event how is this prevented? If any type of water is used or sprayed onto a fire the relative humidity is not controllable and could easily hit dew point inside the gypsum duct. This exemption goes against all 3 minimum requirements set by the gypsum association 1 Negative pressure ducts only 2 Control humidity below dew point 3 Temperature shall never go above 125 degrees Remaining questions about the use of gypsum material used as emergency smoke exhaust air ducts: 1 Does NFPA have any studies on why this is allowed? 2 Where is the science behind this exception? 3 What is the NFPA standard these gypsum ducts need to be built to? Submittal Date: Tue Mar 01 17:22:54 EST 2016

21 1 of 53 11/9/2016 9:07 AM Public Comment No. 9-NFPA 90A-2016 [ Section No ] All air duct materials shall be suitable for continuous exposure to the temperature and humidity conditions of the environmental air in the air duct. Exception gypsum wall board used as smoke evacuation duct. If is not eliminated this exemption should be mentioned here since it says that you can use gypsum for smoke evacuation duct even though it is not supposed to be used for temps above 125 F. No gypsum wall board company allows their product for this application. Submittal Date: Wed Mar 02 13:24:00 EST 2016

22 2 of 53 11/9/2016 9:07 AM Public Comment No. 10-NFPA 90A-2016 [ Section No [Excluding any Sub-Sections] ] The materials, thickness, construction, and installation of ducts shall provide structural strength and durability in conformance with recognized good practice. Delete this section good practice is not code or standard language. Where can one find the definition of good practice? The following section address what standards duct shall be built to. Submittal Date: Wed Mar 02 13:32:00 EST 2016

23 3 of 53 11/9/2016 9:07 AM Public Comment No. 11-NFPA 90A-2016 [ Section No ] Air ducts shall be considered to be in compliance with where constructed and installed in accordance with the ASHRAE Handbook HVAC Systems and Equipment and with one of the following as applicable: (1) NAIMA Fibrous Glass Duct Construction Standards (2) SMACNA Fibrous Glass Duct Construction Standards (3) SMACNA HVAC Duct Construction Standards Metal and Flexible (4) ANSI/SMACNA HVAC Air Duct Leakage Test Manual (5) SMACNA Phonolic Duct Construction Standards With Phenolic duct being used it should be built to a standard. SMACNA is the leader in duct construction standards and should be inserted here. Submittal Date: Wed Mar 02 13:38:28 EST 2016 Rejected The document is not mentioned/used in the body of the standard.

24 4 of 53 11/9/2016 9:07 AM Public Comment No. 29-NFPA 90A-2016 [ New Section after ] TITLE OF NEW CONTENT Duct made of other materials other than metal. Additional Proposed Changes File Name Description Approved ASHRAE_62.1_for_mold_and_duct_erosion_NFPA_90B.docx ASHRAE language for ducts made out of other materials If NFPA is going to allow HVAC ducts to made up of gypsum board and any other materials those materials should at least meet ASHRAE standard 62.1 Public Input No. 1-NFPA 90A-2015 [Global Input] Submittal Date: Wed Mar 09 14:49:33 EST 2016

25 5 of 53 11/9/2016 9:07 AM Public Comment No. 12-NFPA 90A-2016 [ Section No ] Where no standard exists for the construction of air ducts, the ducts shall be constructed to withstand both the maximum positive and the maximum negative pressures of the system at fan shutoff. All HVAC ducts should be built to a duct construction standard. Having this section allows for anyone to use anything and construct duct anyhow they want to and still claim to meet NFPA 90. NFPA list several duct construction standards about this section which mandate HVAC duct work is built to a recognized standard. UL has standards to built to as well. Submittal Date: Wed Mar 02 13:41:08 EST 2016

26 6 of 53 11/9/2016 9:07 AM Public Comment No. 14-NFPA 90A-2016 [ Section No ] Where no standard exists for the construction of air ducts, the ducts shall be constructed to withstand both the maximum positive and the maximum negative pressures of the system at fan shutoff. All duct should be built to a duct construction standard. Having this section allows for anyone to anything and construct duct anyhow they want to and still claim to meet NFPA 90. NFPA list several duct construction standards about this section which mandate HVAC duct work is built to a recognized standard. UL has standards to build ducts to as well. Submittal Date: Wed Mar 02 14:46:26 EST 2016

27 7 of 53 11/9/2016 9:07 AM Public Comment No. 15-NFPA 90A-2016 [ Section No ] A duct enclosure used for the multiple distribution or gathering of ducts or connectors shall be constructed of materials and methods specified in Electrical wires and cables and optical fiber cables within a duct enclosure shall comply with Allowing the use of air connectors that do not pass UL 181 testing can lead to flame and smoke spread. Allowing them in this section is allowing them in a cluster area compounding the threat not passing UL 181 flame penetration testing in the cluster area. Submittal Date: Thu Mar 03 11:45:18 EST 2016

28 8 of 53 11/9/2016 9:07 AM Public Comment No. 16-NFPA 90A-2016 [ Section No ] Air Dispersion Systems. Air dispersion systems shall meet the following criteria: (1) They shall only be installed in entirely exposed locations. (2) They shall always operate under positive pressure. (3) They shall not penetrate fire resistance rated construction. (4) They shall not pass through fire resistance rated construction. (5) They shall be listed and labeled in accordance with UL 2518, Outline of Investigation for Air Dispersion System Materials. (6) They shall not connector to a duct penetrating a fire wall or fire assembly. Allowing air dispersion ducts to attach to a 6 inch metal collar to pass through a fire assembly should only be allowed if a fire damper is installed in the fire wall. Submittal Date: Thu Mar 03 11:50:13 EST 2016

29 9 of 53 11/9/2016 9:07 AM Public Comment No. 17-NFPA 90A-2016 [ Section No [Excluding any Sub-Sections] ] Air connectors shall be permitted to be used as limited-use, flexible air ducts that shall not be required to conform to the provisions for air ducts where they meet the requirements of through Additional Proposed Changes File Name Description Approved Air_connector_photo_with_round_and_rectangular_labels.jpg This photo shows how confusing the manufactures can make identifying a air connector in the field, There are no standards on how air connectors are labeled. A round UL label indicates the product is a air connector, a UL rectangular label indicates that the product is a UL listed air duct. Sometimes manufactures put a very small round label on the air connector, and also put a larger rectangular performance label next to the smaller round label. When an inspector looks for a

30 0 of 53 11/9/2016 9:07 AM Air_Connector_connecting_furnace_return_and_path_to_first_floor.pdf flexible air duct they look for that rectangular label. Well the air connector has that larger rectangular label next to the UL symbol and it is overlooked as an air connector and is passed off as a UL listed air duct. What air connectors are to engineer, sheet metal installers and contractors. Not a round duct for conveying air. HVAC-DUCT-_Connector-Ad-LOWRES-JULY_20_air_connector.pdf What air connectors are to engineer, sheet metal installers and contractors. Not a round duct for conveying air. HVAC-3202_Silicone_HI-T_TDS_ _air_connector.pdf What air connectors are to engineers, sheet metal installers and contractors. Not a round duct for conveying air. HVAC-3202_Neoprene_TDS-LOW-RES_air_connector.pdf What air connectors are to engineers,

31 1 of 53 11/9/2016 9:07 AM sheet metal installers and contractors. Not a round duct for conveying air. HVAC-3202_VinylFlex_TDS-LOWRES_air_connector.pdf What air connectors are to engineers, sheet metal installers and contractors. Not a round duct for conveying air. HVAC-3202_Residential_Quality_2-3-2_28G_TDS- US_Version_ _air_connector.pdf What air connectors are to engineers, sheet metal installers and contractors. Not a round duct for conveying air. Carlisle_connector_plus.png What air connectors are to engineers, sheet metal installers and contractors. Not a round duct for conveying air. Delete the use of air connectors. They are not considered air ducts by UL test 181 and have spawned as a new HVAC product. Air connectors do not pass the UL 181 test for flame penetration and should not be used in a HVAC duct system. Air connectors are currently found being used in the wrong application as a UL 181 listed air duct. UL 181 Listed air ducts pass 16 of 16 UL test to be listed as an air duct. Air connectors pass 13 of 16 UL test for being a listed air ducts, failing 3 of the required test for being a listed air duct. The three test that are not required are, puncture, flame penetration, and impact test. Allowing the use of air connectors connected next to a fire wall kind of defeats the purpose of the fire wall since there is no

32 2 of 53 11/9/2016 9:07 AM flame penetration test you have an open hole to the other side of the fire wall. Allowing smoke to pass through the opening at the first flame that touches the air connector. Even when installed under the current requirements air connectors are the weak link leading to instant penetration of a HVAC duct system, breaching fire assembles and the HVAC system itself. When the HVAC duct system is breached the HVAC fan will spread smoke and heat to other parts of the building. IAPMO (UMC) did not allow the use of air connectors until a couple years ago. When they allowed the use of them it was a mistake as they thought an air connector was the small piece of flex to eliminate HVAC vibration. Attached are photos of what is viewed as air connectors by engineers, sheet metal workers, and installing contractors. Submittal Date: Thu Mar 03 11:54:50 EST 2016

33 3 of 53 11/9/2016 9:07 AM Public Comment No. 18-NFPA 90A-2016 [ Section No [Excluding any Sub-Sections] ] Air connectors shall be permitted to be used as limited-use, flexible air ducts that shall not be required to conform to the provisions for air ducts where they meet the requirements of through Additional Proposed Changes File Name Description Approved Air_connector_photo_with_round_and_rectangular_labels.jpg Shows how air connectors that can only use a round UL label also has a rectangular label on the air connector which give and appearance of the product being a air duct not an air connector. There are no standards on how air connectors are labeled. Only how often they must be marked with a rectangular or a round UL listing label. A round UL label indicates the product is a air connector, a UL rectangular label indicates that the product is a UL listed air duct. Sometimes manufactures put a very small round label on the air connector, and also put a larger rectangular performance label next to the smaller round label. When an inspector looks for a flexible air duct they look for that rectangular label. Well the air connector has that larger rectangular label next to the UL symbol and it is overlooked as an air connector and is passed off as a UL listed air duct. Submittal Date: Thu Mar 03 13:20:41 EST 2016

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35 5 of 53 11/9/2016 9:07 AM Public Comment No. 19-NFPA 90A-2016 [ Section No ] Air connectors shall conform to the requirements for Class 0 or Class 1 air connectors when tested in accordance with ANSI/UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors. A ir connectors are only required to pass 13 of the 16 UL 181 test for air ducts. To aid ASHRAE, IAPMO, and the ICC this language can help AHJ's see the difference between air ducts and air connectors. Submittal Date: Thu Mar 03 13:32:56 EST 2016

36 6 of 53 11/9/2016 9:07 AM Public Comment No. 20-NFPA 90A-2016 [ Section No ] Air connector runs shall not exceed m (14 ft 7 inches ) in length. Additional Proposed Changes Carlisle_connector_plus.png HVAC-DUCT-_Connector-Ad-LOWRES- JULY_20_air_connector.pdf File Name Description Approved FlexConnCatalog2013_LR_air_connector.pdf What the industry views air connectors as Air connector by manufacture Duro Dyne air connector is not flex duct but a flexible air piece that connects to pieces of HVAC air duct. Air connectors are for vibration elimination and do not need to be longer than 7.8. Using them for longer lengths and allows for breaching of the HVAC duct systems in more spots. ASHRAE TC 5.2 cannot find any information on where this 14 foot limitation came from or any data on why it is allowed to be used for 14 feet. The IMC and UMC allow 14 feet of air connectors because NFPA says they can be 14 feet. NFPA is essentially providing the design of duct systems with this limitation and mention of air connectors. ASHRAE has made formal request for this justification of 14 feet from NFPA with no response back to the ASHRAE 5.2 subcommittee on duct construction. Air connectors were first developed to stop HVAC fan vibration in a building. They would be installed by the furnace, equipment or fan with the sole purpose of eliminating the fan vibrations from transferring though out the duct system. The ASHRAE 5.2 TC has been researching where this 14 foot limitation comes from with no real concrete findings. The UMC and IMC codes refer back to this NFPA limitation of 14 feet and do not know why or how 14 feet was determined. How did NFPA determine this 14 foot limitation? Please let ASHRAE know (5.2)

37 7 of 53 11/9/2016 9:07 AM Submittal Date: Thu Mar 03 13:39:47 EST 2016

38 8 of 53 11/9/2016 9:07 AM Public Comment No. 21-NFPA 90A-2016 [ Section No ] Air connectors shall not pass through be within 15 feet of passing through any wall, partition, or enclosure of a vertical shaft that is required to have a fire resistance rating of 1 hour or more. Additional Proposed Changes File Name Connector_being_used_to_penatrate_floor_with_short_register_boot.jpg Pictures_of_air_connector_used_on_the_other_side_of_a_1_hour_fire_rated_ceiling.pdf Air_Connector_connecting_furnace_return_and_path_to_first_floor.pdf Description Approved Shows how a air connector can be attached close to a outlet going through a floor or into a wall cavity. 1 hour fire assembly with air connector right next to the diffuser opening. Doesn't make sense to have a fire assembly if using a air connector next to the opening is allowed. This show how currently a large opening from floor to floor is created by allowing the use of

39 9 of 53 11/9/2016 9:07 AM air connectors Air connectors do not pass the UL flame penetration test. Allowing them to be attached to a short (no limit on length requirement) piece of metal next to or going through the fire assemble allows for a flame to breach right into the fire rated assembly. 15 feet may give enough length of duct with UL listed Duct flame penetration test duct or metal duct to stop the spread of smoke and flame through the floor. When looking from the top view of a floor plan having opening 8 feet apart on the entire floor looks a lot like balloon framing to me except in the occupied space not in wall cavities. Submittal Date: Thu Mar 03 13:45:19 EST 2016

40 0 of 53 11/9/2016 9:07 AM Public Comment No. 22-NFPA 90A-2016 [ Section No ] Air connectors shall not pass be within 15 feet of passing through floors. Additional Proposed Changes File Name Description Approved Connector_attached_at_floor.pdf Fitting which is attached to a opening in the floor. When air connector are attached to floor boot registers there is only about 2 inches of metal below the floor. With air connectors not passing the UL 181 flame penetration test this allows for smoke and fire to jump through a floor or into a wall cavity with relative ease. Easier than the smoke drafting material around the outside of the duct. Submittal Date: Thu Mar 03 13:52:02 EST 2016

41 1 of 53 11/9/2016 9:07 AM Public Comment No. 23-NFPA 90A-2016 [ Section No ] An air connector shall not be interrupted by a short collar less than 15 feet or any other fitting on one side and then connected to another air connector on the other side where penetrating a floor or a wall, partition, or enclosure of a vertical shaft that is required to have a fire-resistance rating of 1 hour. Additional Proposed Changes File Name Connector_being_used_to_penatrate_floor_with_short_register_boot.jpg Connector_attached_at_floor.pdf Description Approved Shows a floor boot going from basement to first floor Picture of fitting going through floor. When using the term short what does that mean? If the air connector is used only on one side of the floor or wall can it be used on one side of the fire assembly? With this language it could be. Weather the penetration is connected on the other side of the fitting to another duct or is open it should not matter. Allowing this to penetrate a floor or wall into the occupants space would allow smoke to enter the space quicker. This language will allow for unlimited numbers or air connectors used on a duct run if connected with long collars. How long is a long collar? 1 foot? Submittal Date: Thu Mar 03 13:54:42 EST 2016

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43 3 of 53 11/9/2016 9:07 AM Public Comment No. 24-NFPA 90A-2016 [ Section No ] Multiple air connector runs shall not be spliced together, or be longer that 14 in total, to exceed the length limitation in Stopping the installation of 14 feet in the basement, 14 feet in the first floor, 14 feet in the second floor, 14 feet in the attic. I have not found any information on why NFPA has this 14 foot limitation, but I am assuming NFPA does not want 14 feet of connector on each level of a home or building. This would help define NFPA's position. Submittal Date: Thu Mar 03 14:31:06 EST 2016

44 4 of 53 11/9/2016 9:07 AM Public Comment No. 25-NFPA 90A-2016 [ Section No ] Vibration isolation Air connectors in duct systems shall be made of materials having a maximum flame spread index of 25 and a maximum smoke developed index of 50. Additional Proposed Changes Carlisle_connector_plus.png File Name Description Approved HVAC-3202_Residential_Quality_2-3-2_28G_TDS- US_Version_ _air_connector.pdf HVAC-3202_VinylFlex_TDS-LOWRES_air_connector.pdf HVAC-3202_Neoprene_TDS- LOW-RES_air_connector.pdf HVAC-3202_Silicone_HI- T_TDS_ _air_connector.pdf HVAC-DUCT-_Connector-Ad-LOWRES- JULY_20_air_connector.pdf FlexConnCatalog2013_LR_air_connector.pdf Manufactures description of a air connector. NFPA defines this product as a Vibration isolator. Manufactures description of a air connector. NFPA defines this product as a Vibration isolator. Manufactures description of a air connector. NFPA defines this product as a Vibration isolator. Manufactures description of a air connector. NFPA defines this product as a Vibration isolator. Manufactures description of a air connector. NFPA defines this product as a Vibration isolator. Manufactures description of a air connector. NFPA defines this product as a Vibration isolator. Manufactures description of a air connector. NFPA defines this product as a Vibration isolator. The HVAC industry calls these products air connectors. NFPA calls them Vibration eliminators. Either NFPA should change their definition, or try to have the HVAC industry change their definition. Either way this a disparity that should be address and brought together.

45 5 of 53 11/9/2016 9:07 AM Submittal Date: Thu Mar 03 14:35:05 EST 2016

46 6 of 53 11/9/2016 9:07 AM Public Comment No. 26-NFPA 90A-2016 [ Section No [Excluding any Sub-Sections] ] Pipe and duct insulation and coverings, duct linings, vapor retarder facings, adhesives, fasteners, tapes, and supplementary materials added to air ducts, plenums, panels, and duct silencers used in duct systems, unless otherwise provided for in or , shall have, in the form in which they are used, a maximum flame spread index of 25 without evidence of continued progressive combustion and a maximum smoke developed index of 50 when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, or with ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials. Pipe and duct insulation and coverings, duct linings and their adhesives, and tapes, except gypsum wall board paper tape, shall use the specimen preparation and mounting procedures of AASTM E2231, Standard Practice for Specimen Preparation and Mounting of Pipe and Duct Insulation Materials to Assess Surface Burning Characteristics. Since NFPA allows the use of gypsum wall board as ducts and its tape the paper sheet rock tape should be noted as an exemption. Submittal Date: Thu Mar 03 14:42:22 EST 2016

47 7 of 53 11/9/2016 9:07 AM Public Comment No. 31-NFPA 90A-2016 [ Section No [Excluding any Sub-Sections] ] Pipe and duct insulation and coverings, duct linings, vapor retarder facings, adhesives, fasteners, tapes, and supplementary materials added to air ducts, plenums, panels, and duct silencers used in duct systems, unless otherwise provided for in or , shall have, in the form in which they are used, a maximum flame spread index of 25 without evidence of continued progressive combustion and a maximum smoke developed index of 50 when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, or with ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials. Pipe and duct insulation and coverings, duct linings and their adhesives, and tapes shall use the specimen preparation and mounting procedures of AASTM E2231, Standard Practice for Specimen Preparation and Mounting of Pipe and Duct Insulation Materials to Assess Surface Burning Characteristics. Shall meet ASHRAE standard 62.1 for HVAC duct surfaces. Additional Proposed Changes File Name Description Approved ASHRAE_62.1_for_mold_and_duct_erosion_NFPA_90.docx Make the duct last at least a specific length of time as per ASHRAE ASHRAE standard on HVAC duct surfaces Submittal Date: Thu Mar 10 15:27:32 EST 2016

48 8 of 53 11/9/2016 9:07 AM Public Comment No. 27-NFPA 90A-2016 [ Section No ] Closure systems for use with rigid and flexible air ducts tested in accordance with ANSI/UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors, shall have been tested, listed, and used in accordance with the conditions of their listings, in accordance with one of the following: (1) ANSI/UL 181A, Standard for Safety Closure Systems for Use with Rigid Air Ducts (2) ANSI/UL 181B, Standard for Safety Closure Systems for Use with Flexible Air Ducts and Air Connectors (3) Except gypsum board ducts If NFPA is going to allow gypsum board ducts to be used there is no closure standard for them. The sheet rock paper used as tape has not been tested to either standard in this section. Submittal Date: Thu Mar 03 14:45:05 EST 2016

49 9 of 53 11/9/2016 9:07 AM Public Comment No. 30-NFPA 90A-2016 [ Section No ] Air ducts complying with and air connectors complying with shall be permitted. Deleting this would make fire rated assemblies safer and meet their design intent. Air connectors do not pass the UL 181 test for flame penetration and should not be used in a HVAC duct system. Air connectors are currently found being used in the wrong application as a UL 181 listed air duct. UL 181 Listed air ducts pass 16 of 16 UL test to be listed as an air duct. Air connectors pass 13 of 16 UL test for being a listed air ducts, failing 3 of the required test for being a listed air duct. The three test that are not required are, puncture, flame penetration, and impact test. Allowing the use of air connectors connected next to a fire wall kind of defeats the purpose of the fire wall since there is no flame penetration test you have an open hole to the other side of the fire wall. Allowing smoke to pass through the opening at the first flame that touches the air connector. Even when installed under the current requirements air connectors are the weak link leading to instant penetration of a HVAC duct system, breeching fire assembles and the HVAC system itself. When the HVAC duct system is breached the HVAC fan will spread smoke and heat to other parts of the building. IAPMO (UMC) did not allow the use of air connectors until a couple years ago. When they allowed the use of them it was a mistake as they thought an air connector was the small piece of flex to eliminate HVAC vibration. Attached are photos of what is viewed as air connectors by engineers, sheet metal workers, and installing contractors. There are no standards on how air connectors are labeled. Only how often they must be marked with a rectangular or a round UL listing label. A round UL label indicates the product is a air connector, a UL rectangular label indicates that the product is a UL listed air duct. Sometimes manufactures put a very small round label on the air connector, and also put a larger rectangular performance label next to the smaller round label. When an inspector looks for a flexible air duct they look for that rectangular label. Well the air connector has that larger rectangular label next to the UL symbol and it is overlooked as an air connector and is passed off as a UL listed air duct.

50 0 of 53 11/9/2016 9:07 AM Submittal Date: Thu Mar 10 15:05:36 EST 2016

51 1 of 53 11/9/2016 9:07 AM Public Comment No. 34-NFPA 90A-2016 [ Section No ] Smoke detectors provided as required by shall automatically stop shunt their respective fan(s) on detecting the presence of smoke. The desire is for fans to immediately begin to spin down upon detection of smoke to prevent the spread of smoke by the air handler. An example is a 135,000 cfm system that ran for three and a half minutes after the detection indicated smoke. This circulated 472,000 cf of smoke. The intent of this comment is to have the power to the fans immediately shunted, so that the spin down of the air handler begins immediately. This avoids the time it may take to relay through the system to begin shutdown. As noted by the committee s reason for not utilizing PI 32, it would be nearly impossible to immediately stop the airflow, which was not the intent of PI 32. Having a shunt will immediately begin the process of stopping the air handler, much like the shunting of an elevator upon heat detection. Public Input No. 32-NFPA 90A-2015 [Section No ] Submitter Full Name: Jim Muir Organization: Building Safety Division, Clark County, Washington Affilliation: NFPA's Building Code Development (BCDC) Submittal Date: Tue May 10 13:22:52 EDT 2016

52 2 of 53 11/9/2016 9:07 AM Public Comment No. 38-NFPA 90A-2016 [ Section No. A ] A Air Inlet. For further discussion of various types of air inlet devices, see ASHRAE Handbook Fundamentals 2013, Chapter 32 20, Space Air Diffusion. Correction to latest version of referenced publication ASHREA Fundamentals. Chapter changed from 32 to 20. Public Input No. 1-NFPA 90A-2015 [Global Input] Submitter Full Name: John Kennedy Organization: NAIT Affilliation: Instructor HVAC Submittal Date: Mon May 16 13:59:36 EDT 2016 Accepted SR-5-NFPA 90A-2016 Statement: Correction to latest version of referenced publication ASHREA Fundamentals. Chapter changed from 32 to 20.

53 3 of 53 11/9/2016 9:07 AM Public Comment No. 33-NFPA 90A-2016 [ Section No. C ] C ASTM International Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2015a 2015b. ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 C, AASTM ASTM E2231, Standard Practice for Specimen Preparation and Mounting of Pipe and Duct Insulation Materials to Assess Surface Burning Characteristics, ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-Shaped Airflow Stabilizer, at 750 C, date updates Public Input No. 11-NFPA 90A-2015 [Section No. C.1.2.3] Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Wed May 04 17:27:14 EDT 2016 Rejected but see related SR SR-6-NFPA 90A-2016 Statement: date updates