National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 Fax: 617-770-0700 www.nfpa.org MEMORANDUM TO: FROM: Technical Committee on Residential Occupancies Kelly Carey, Project Administrator DATE: October 18, 2016 SUBJECT: NFPA 101 Second Draft Ballot FINAL Ballot Results (A2017) According to the final ballot results, all ballot items received the necessary affirmative votes to pass ballot. 29_ Members Eligible to Vote _4_ Members Not Returned (Boyd, Damron, Meehan and ) 13_ Members Voted Affirmative on All Revisions _4_ Members Voted Affirmative with Comment on one or more Revisions (Coats, Klein, Nickson and Weaver) _ 8_ Members Voted Negative on one or more Revisions (Asp, Isman, Klein, Lampella, Longhitano, Mayl, Spangler and Weaver) 0_ Members Abstained on one or more Revisions The attached report shows the number of affirmative, negative, and abstaining votes as well as the explanation of the vote for each revision. To pass ballot, each revision requires: (1) a simple majority of those eligible to vote and (2) an affirmative vote of 2 /3 of ballots returned. See Sections 3.3.4.3.(c) and 4.4.10.1 of the Regulations Governing the Development of NFPA Standards.
NFPA 101 TC ON RESIDENTIAL OCCUPANCIES SECOND DRAFT BALLOT RESULTS SR-6003, Section No. 26.1.1.5, See SR-6003 Agree with the deletion. I am voting negative on the entire document because it is my opinion that the adoption of 24.2.8 GRAB BARS is so far afield from a standard on protection of human life from fire it calls into question the motives and credibility of the entire document. Are we now experts on fall prevention? What's next? Having the fire marshal enforce rules about what kind of slip-resistant shoes people need to wear in their homes? Is there anyone who really believes that people who invest $25,000 to $50,000 on renovating their bathrooms want the town fire marshal to tell them that the lack of grab bars on their tub or shower is a fire code violation?? SR-6005, Section No. 26.3.2.2, See SR-6005 Page 1 of 14
Agree with the deletion. SR-6006, Section No. 28.3.4.6.4, See SR-6006 Agree with proposal. Page 2 of 14
SR-6007, Section No. 28.3.5.3, See SR-6007 Agree with proposal. SR-6008, Section No. 30.3.4.6.4, See SR-6008 Affirmative with Comment 0 Negative 2 This change does not recognize when a gas-fired water heater or other appliance is in a room inside an apartment that is accessed from the outside. Page 3 of 14
SR-6013, Section No. 30.3.5.2, See SR-6013 Affirmative 21 Affirmative with Comment 3 Marshall A. Klein Staff copied the type of occupancies from SR-6007 into this SR 6013 new Section 30.3.5.2 without changing them from "...hotel and dormitory occupancies..." to "...apartment occupancies...". This is a staff error and needs to be corrected because Chapter 30 covers the requirements for new apartments (SR-6013) and Chapter 28 is for new hotels and dormitory occupancies. This was strictly a "copy and paste" error by Staff at the Second Draft Meeting since it was the Committee's intent to apply this requirement to the occupancies covered in Chapters 28 and 30. Ronald G. Nickson Agree with proposal. When SR-6007 was copied into SR 6013 the term "...hotel and dormitory occupancies..." was not changed to "...apartment occupancies..." which is necessary to make the approved change appropriate for apartments. Page 4 of 14
SR-6009, Section No. 24.2.4.8, See SR-6009 Affirmative 22 Negative 2 Kevin Spangler Agree with proposal. It should read 36 inches or the door width. There is no reason to have a 36 inch wide landing with a smaller door. SR-6014, New Section after 24.2.7.2, See SR-6014 Affirmative 20 Affirmative with Comment 0 Negative 5 I do not agree with the proposed change as the cost to install grab bars exceeds the cost benefit of installing them. Current federal law and building codes require the installation of blocking for the owner to install grab bars at their discretion. Page 5 of 14
Eric N. Mayl Kevin Spangler Gary Lampella While this provision may reduce injuries, it is overly intrusive. Grab bars in showers are for fall protection, not for means of egress. Grab bars in one and two family dwellings are for personal preference and should not be mandated by NFPA 101. The information/documentation provided at the last meeting did not have substantial technical information that indicated that the falls that were referenced were in one or two family dwellings. At a minimum, section 24.2.8.1.2 should be in when the floor does not exceed 6 inches in height. A six inch curb has not proven to be a fall hazard in any of the documentation provided. Of concern is the statement that all new bathtubs, bathtub-shower combinations and showers be provided with grab bars will include replacements. These will be regulated by the plumbing code with no reference back to these sections. We also have concerns with replacement (new) fixtures as there was committee discussion on retrofitting grab bars and the proponent mentioned a test for an epoxy/glue attachment in-lieu of the typical mechanical attachment to solid blocking/backing. We have reservations about promoting this type of attachment. An epoxy/glue attachment is only as strong as the surface it is attached to, not just new construction. We would suggest maybe adding an explanatory note to 24.2.8.4.3 indicating epoxy/glue attachments may not meet the structural loading requirements and mechanical attachment to solid blocking/backing is the preferred method. There is also the issue of the proposed vertical grab bars, especially those from the floor to the ceiling, which will be inviting for children to climb. This will more than likely lead to the unintended consequence of serious injuries due to the misuse of the grab bars in dwelling units. It is obvious that the ramifications of this major change to the nation s living spaces has not been fully vetted. We are not convinced that these devices should be regulated by the person enforcing this code, which would be the fire code official. We are also concerned about putting these requirements in the means of egress chapters while other activities in and around a bathroom are not specifically regulated. Such as, transferring from a chair to a wheelchair, getting on and off a bed and other daily functions that pose a safety risk to many persons. We think the issue of new tub/showers, retrofits and inserting the language in the means of egress chapters should be addressed prior to insertion into the code. Page 6 of 14
SR-6001, Section No. 24.3.2, See SR-6001 Agree with the deletion. SR-6002, Section No. 24.3.5.2, See SR-6002 Agree with the proposal. Page 7 of 14
SR-6004, New Section after 26.1.1.4, See SR-6004 Agree with the proposal. SR-6015, New Section after 26.2.3.6, See SR-6015 Affirmative 20 Affirmative with Comment 0 Negative 5 I do not agree with the proposed change as the cost to install grab bars exceeds the cost benefit of installing them. Current federal law and building codes require the installation of blocking for the owner to install grab bars at their discretion. Page 8 of 14
Eric N. Mayl Kevin Spangler Gary Lampella While this provision may reduce injuries, it is overly intrusive. Grab bars in showers are for fall protection, not for means of egress. Information provided as documentation for the falls did not provide substantial information that grab bars would prevent the falls. At a minimum, section 26.2.4.1.2 should be in when the floor does not exceed 6 inches in height. A six inch curb has not proven to be a fall hazard in any of the documentation provided. Of concern is the statement that all new bathtubs, bathtub-shower combinations and showers be provided with grab bars will include replacements. These will be regulated by the plumbing code with no reference back to these sections. We also have concerns with replacement (new) fixtures as there was committee discussion on retrofitting grab bars and the proponent mentioned a test for an epoxy/glue attachment in-lieu of the typical mechanical attachment to solid blocking/backing. We have reservations about promoting this type of attachment. An epoxy/glue attachment is only as strong as the surface it is attached to, not just new construction. We would suggest maybe adding an explanatory note to 26.2.4.4.3 indicating epoxy/glue attachments may not meet the structural loading requirements and mechanical attachment to solid blocking/backing is the preferred method. There is also the issue of the proposed vertical grab bars, especially those from the floor to the ceiling, which will be inviting for children to climb. This will more than likely lead to the unintended consequence of serious injuries due to the misuse of the grab bars in dwelling units. It is obvious that the ramifications of this major change to the nation s living spaces has not been fully vetted. We are not convinced that these devices should be regulated by the person enforcing this code, which would be the fire code official. We are also concerned about putting these requirements in the means of egress chapters while other activities in and around a bathroom are not specifically regulated. Such as, transferring from a chair to a wheelchair, getting on and off a bed and other daily functions that pose a safety risk to many persons. We think the issue of new tub/showers, retrofits and inserting the language in the means of egress chapters should be addressed prior to insertion into the code. Page 9 of 14
SR-6010, New Section after 28.3.4.3.6, See SR-6010 Affirmative 21 Affirmative with Comment 2 Paul D. Coats Agree with the proposal. I've looked in NFPA 72 for when the mass notification system would be required, and it's not indicated unless I missed it. I'm a little uncomfortable requiring an analysis so broadly when the decision as to when it's required is subjective. I can see the potential benefits, but I wonder if it may not be better to have a more conservative and firm indicator for triggering the analysis. I voted affirmative because I'm uncertain how much burden doing the analysis is in cases where mass notification is not likely to be needed. Negative 2 Kevin Spangler Mass notification is an owners preference. Mass notification is not required for any particular occupancies. A mass notification analysis may be requested by the owner, but it should not be a mandated document. This is an unnecessary cost to the owner who has ultimate say in whether or not a mass notification system should be installed. As a consulting engineer that would be hired to do these assessments, I would estimate a minimum of $6,000, and more likely around $10,000 would be charged to the client for a report/assessment that is being required in this new section. Page 10 of 14
SR-6016, New Section after 28.7.7, See SR-6016 Affirmative 19 Negative 5 Marshall A. Klein Roland A. Asp Agree with the proposal. I agree with the negative ballots of Ken Isman and Roland ASP on this Second Revision proposal. The negative ballot is cast for several reasons. The result of the proposed text is far reaching and will have multiple outcomes when it is enforced by local authorities having jurisdiction. Integrated system is not defined in NFPA 101 and the definition in NFPA 4 is very unclear as to the extent of the testing, especially as explained by the annex text (A.3.3.12.1.3) in NFPA 4. Furthermore, the life safety system and fire protection system is also not defined in NFPA 101 or NFPA 5000. These definitions are important to go forward with this language to provide uniform enforcement. It is very important to note that if this proposal goes forward, it will conflict with the other model building and fire codes (IBC/IFC, proposal F145-16) that are developing their 2018 editions. The IFC/IBC is limiting NFPA 4 to high rise buildings (as is the First Draft Report, NFPA 101, Section 11.8.9) and where smoke control systems are integrated. It is common in several states that the IBC and NFPA 101 is used across multiple jurisdictions. Having conflicting requirements between the documents is not new, but the extent of testing integrated systems should be consistent for building owners, contractors, and authorities having jurisdiction. Page 11 of 14
Kenneth E. Isman Kevin Spangler A wet pipe or dry pipe sprinkler system with the waterflow switch set up as an initiating device for the alarm system meets the definition of an integrated system, but should not have to be tested as an integrated system. The integrated system testing is more expensive than the individual testing of the sprinkler and alarm systems and is not justified. If the link between the sprinkler system and the alarm system fails for some reason, the sprinkler system can still do its job. The alarm system is not preventing the sprinkler system from functioning, so there is no reason to require them to be tested together. I can see how a preaction sprinkler system would need to be tested with the alarm system in an integrated fashion. If the alarm system does not work, then the sprinkler system won t operate properly. But for a regular wet pipe or dry pipe sprinkler system, that does not rely on the alarm system for operational purposes, causing the sprinkler system to be tested as an integrated system just because it is tied to the alarm system is too much. See Kenneth Isman comments. SR-6017, New Section after 30.7.3, See SR-6017 Affirmative 19 Negative 5 Marshall A. Klein Agree with the proposal. I agree with the negative ballots of Ken Isman and Roland ASP on this Second Revision proposal. Page 12 of 14
Roland A. Asp The negative ballot is cast for several reasons. The result of the proposed text is far reaching and will have multiple outcomes when it is enforced by local authorities having jurisdiction. Integrated system is not defined in NFPA 101 and the definition in NFPA 4 is very unclear as to the extent of the testing, especially as explained by the annex text (A.3.3.12.1.3) in NFPA 4. Furthermore, the life safety system and fire protection system is also not defined in NFPA 101 or NFPA 5000. These definitions are important to go forward with this language to provide uniform enforcement. It is very important to note that if this proposal goes forward, it will conflict with the other model building and fire codes (IBC/IFC, proposal F145-16) that are developing their 2018 editions. The IFC/IBC is limiting NFPA 4 to high rise buildings (as is the First Draft Report, NFPA 101, Section 11.8.9) and where smoke control systems are integrated. It is common in several states that the IBC and NFPA 101 is used across multiple jurisdictions. Having conflicting requirements between the documents is not new, but the extent of testing integrated systems should be consistent for building owners, contractors, and authorities having jurisdiction. Kenneth E. Isman A wet pipe or dry pipe sprinkler system with the waterflow switch set up as an initiating device for the alarm system meets the definition of an integrated system, but should not have to be tested as an integrated system. The integrated system testing is more expensive than the individual testing of the sprinkler and alarm systems and is not justified. If the link between the sprinkler system and the alarm system fails for some reason, the sprinkler system can still do its job. The alarm system is not preventing the sprinkler system from functioning, so there is no reason to require them to be tested together. I can see how a preaction sprinkler system would need to be tested with the alarm system in an integrated fashion. If the alarm system does not work, then the sprinkler system won t operate properly. But for a regular wet pipe or dry pipe sprinkler system, that does not rely on the alarm system for operational purposes, causing the sprinkler system to be tested as an integrated system just because it is tied to the alarm system is too much, even in a high rise building. Page 13 of 14
Kevin Spangler See Kenneth Isman comments. Page 14 of 14