1 72-12 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 3.3.x Deficiency (New) (Log # 209 ) 72-13 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 3.3.x Deficiency (New) (Log # 234 ) 72-15 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 3.3.x Impairment, Emergency Impairment, Preplanned Impairment (New), 10.19, 14.2.1.2 and Chapter 15 Nnew) (Log # 238 ) Affirmative with Comment Moore, J. At the ROP stage the TMS committee stated that they were not averse to a new chapter dealing with proper handling of impairments related fire alarm and signaling systems. While the text of ROC 72-15 would require revision to fully address fire alarm and signaling systems, the Code is currently sorely lacking guidance for both building owners and AHJs to effectively deal with fire alarm system impairments. Since all chapters are affected by impaired protection, the TCC should appoint a task group to develop complete impairment handling guidelines that can be referenced by an AHJ or used by a facility owner to develop and implement their own impairment handling program. These guidelines can then be added as an annex to the Code. 72-17 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 3.3.x Impairment, Emergency Impairment, Preplanned Impairment (New) and 10.19 (Log # 235 ) Affirmative with Comment
2 Koval, C. To be consistent with other actions taken and the committee statement, the "such as" examples listed in proposed new 3.3.y.1 Emergency Impairment belongs in the annex, not in the body of the standard. 72-33a Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 3.3.xx Critical deficiency, non-critical deficiency (Log # CC904 ) 72-41 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Chapter 7 (Log # 338d ) 72-45 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Chapter 7 (Log # 374d ) Affirmative with Comment Koval, C. The committee statement does not address the submitter's request to delete 7.10.2, FA & EVAC IT Form. 72-47 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Chapter 7 (Log # 102b ) Affirmative with Comment
3 Koval, C. See my Comment on Affirmative on Comment 72-45 (Log #374d). 72-51 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Chapter 7 (Chapter 8) (Log # 103b ) Affirmative with Comment Koval, C. See my Comment on Affirmative on Comment 72-45 (Log #374d). 72-64 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 10.4.3 (Log # 89 ) 72-65 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 10.4.3 (Log # 275 ) 72-66 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 10.4.3 (Log # 348 )
4 72-67 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 10.4.3.1.x (New) (Log # 276 ) 72-67a Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 10.4.3.2 (Log # CC903 ) 72-68 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 10.4.3.4 (Log # 105 ) 72-149a Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 10.19.5 [new 14.2.1.3] (Log # 190a ) 72-162 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 14.2.1.2.4 (Log # 189 )
5 72-163 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 14.2.1.2.4 (New) (Log # 191 ) 72-164 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.3.1 (Log # 25 ) 72-165 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.3.1 (Log # 212 ) Affirmative with Comment Koval, C. Though the committee action removed Interface Equipment as requested by the proponent, in revising the text to read Fire Alarm Control interface and Emergency Control Function Interface, the change created a coordination problem between this table and the Table 14.4.2.2 (now 14.4.3.2), Testing. The Testing table still includes separate testing requirements for 15. Interface Equipment (now 16) and 19 Emergency Control Functions (now 20), yet there are no testing requirement for Fire Alarm Control Interfaces. And with the action taken on this comment, there now are no visual inspection requirements for Interface Equipment. In addition, the new language requires a visual inspection of the interface when in actuality, the inspection is of the interface device which is part of the fire alarm system. Hence, it would have been better to have the text read emergency control function interface device so the visual inspection does not include the emergency control function (e.g., elevator recall, damper closure, etc.) which are outside the scope of NFPA 72 (see new Figure 3.3.127.3). Similar language should also have been included in Table 14.4.2.2. In addition, Interface Equipment should have been deleted from Table 14.4.2.2 to be consistent. 72-165b Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.3.1 (Log # CC901 )
6 72-166 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.3.1, Table 14.4.2.2, and Table 14.4.5 (Log # 66 ) 72-167 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.3.1, Item 4 (Log # 363 ) 72-168 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.3.1, Item 4 (Log # 364 ) 72-169b Eligible To Vote:28 Affirmative: 23 : 1 Abstain: 0 : 4 14.4.1.2.1 (Log # 21 )
7 Edwards, S. NEMA Comment Comment 72-185 Log #151 SIG-TMS Section: (Table 14.4.2.2, Item 15) Panel Action: Reject Our Comment: The NEMA comment rejected acceptance of lowering system test requirements and eliminating testing of db appliances. Recommendation: Vote with the following statement: There is more than adequate reason to reject this proposal as it is entirely plausible that ADS changes may have occurred since prior testing which WILL affect audibility. Relying upon a technicians ear is not an acceptable method of verifying audibility nor can it be assumed that the technician will recall changes that have been made to the ADS from the prior testing. 72-169c Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2 (Log # CC902 ) Affirmative with Comment Koval, C. See comment on ROC 72-165 (Log #212) pertaining to Interface Equipment and Emergency Control Functions and the coordination problem with Table 14.3.1, Visual Inspections. Van Overmeiren, F. Editorial Change: Table 14.4.3.2 Item 18(c) should have 2 sections like Items 18(a) and 18(b). Replace Annually with N/A for first section and replace N/A with Annually for second section covering periodic testing. 72-170 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2 (Log # 365 ) 72-171 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2 and Table 14.4.5 (Log # 88 )
8 72-172 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 8 (Log # 368 ) 72-173 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Items 8(a) and (d) (Log # 367 ) 72-174 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 12(d)3 (Log # 366 ) 72-175 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 14(g)(2) (Log # 259 ) Affirmative with Comment Van Overmeiren, F. Add to committee statement: Only the testing of carbon monoxide alarms/carbon monoxide detectors for the purpose of fire detection is within the scope of NFPA 72 (Table 14.4.2.2 Item 14(h) - 2010 Edition)
9 72-176 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2 Item 14(g)(5) (Log # 36 ) 72-177 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2 Item 14(g)(6) (Log # 37 ) 72-178 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 14(h) (Log # 260 ) 72-179 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 14(j) (Log # 130 ) 72-180 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 14(j) (Log # 213 )
10 72-181 Eligible To Vote:28 Affirmative: 23 : 1 Abstain: 0 : 4 Table 14.4.2.2, Item 14(j) (Log # 220 ) Van Overmeiren, F. Committee statement and proposal are incorrect. Section 5.3.3.3 of NFPA 25-2008 only requires testing by operating the inspector s test connection. The statement indicating the flow of water equal to that from a single sprinkler of the smallest orifice size is not a requirement of NFPA 25. The test methods of an electrically connected water flow switch is within the scope of NFPA 72. 72-182 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 14(j) (Log # 258 ) 72-183 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2 Item 15 (Log # 40 ) 72-184 Eligible To Vote:28 Affirmative: 23 : 1 Abstain: 0 : 4 Table 14.4.2.2, Item 15 (Log # 131 )
11 Shackley, D. The most important function of a fire alarm system is to alert the occupants of a fire emergency, so they have more time to react. By eliminating the requirement for meter db testing, there is no way to assure the fire alarm signals is being heard at the proper level when needed. 72-185 Eligible To Vote:28 Affirmative: 22 : 2 Abstain: 0 : 4 Table 14.4.2.2, Item 15 (Log # 151 ) Edwards, S. There is more than adequate reason to reject this proposal as it is entirely plausible that ADS changes may have occurred since prior testing which WILL affect audibility. Each device should be functionally tested to ensure proper operation. Relying upon a technicians ear is not an acceptable method of verification. Shackley, D. See my Explanation of on Comment 72-184 (Log #131). 72-186 Eligible To Vote:28 Affirmative: 22 : 2 Abstain: 0 : 4 Table 14.4.2.2, Item 15 (Log # 253 )
12 Scibetta, J. Comment 72-186 (Log #253) was not a rejection of Proposal 72-203 but rather a revision, acknowledging the submitter's concern with technicians using sound meter readings to conclude that design changes have taken place. However, the revision presented in this comment retains the use of a sound meter for periodic testing so that the technician doesn't have to guess or make a subjective call based on their own hearing (often with hearing protection in place) that alarm levels do not adequately exceed ambient levels. Between periodic tests, changes can take place in a building, other than those related to building re-design, that result in sound levels that fail to meet the required minimum per Code. Consider the following examples: 1) A tenant places clear tape over a horn/strobe to muffle the sound during fire drills. The clear tape isn't easily visible during a sound test. However, a meter would indicate that the audible alarm signal isn't meeting the minimum dba level and prompt the technician to get a closer look at the appliance. With hearing protection in place and without a meter, the lowered sound level resulting from the tampered device could likely go unnoticed. Additionally, there is no guarantee that the building owner would ever find this out. 2) Additional equipment is moved into an industrial occupancy since the last test and now the ambient level in that area is above 105 dba, thus requiring the installation of a strobe. How does the technician know this if he doesn't have a meter? 3) In that same scenario, the ambient levels have changed and now result in a combined ambient/alarm level greater than 110 dba, which exceeds the maximum dba level allowed in the Code. Again, how does the technician know this without a sound meter? And, in such a situation, he should have hearing protection, which makes the technician even more reliant on a sound meter to determine if sound levels are too high, in that instance, or too low. In none of these scenarios is the technician measuring against the sound levels arrived at in the original design of the system. Rather, sound measurements on a periodic test ensure that nothing since the last test has compromised minimum/maximum sound level requirements as specified in the Code. Where compromises have occurred, notating such instances would not be comparable to making a call on the issue of design compliance but would be based on what the Code does and does not allow with regard to minimum and maximum ambient and alarm sound levels. As to why dba readings don't meet required levels, that's up to the building owner to determine. The committee states that according to Proposal 72-203, the building owner is responsible to verify that facility changes do not adversely affect the fire alarm system. Building owners who actually do this are to be commended. However, will all building owners conduct a sound test whenever design changes are, in fact, made in order to carry out such verification? The committee statement addresses missing devices but does not address changing sound levels due to the addition or removal of furniture or carpet, the addition of machinery, etc., that do not necessarily constitute the types of design changes inherent with a renovation or reconstruction project. This issue has life safety implications. As the representatives of AFAA and NEMA stated in their comments on Proposal 72-203, eliminating the use of sound meters on periodic tests undermines the technician's ability to ensure that, long after the acceptance test has taken place, audible alarm signals can still be heard by building occupants, giving them the advance warning they need to evacuate. Shackley, D. See my Explanation of on Comment 72-184 (Log #131). 72-187 Eligible To Vote:28 Affirmative: 23 : 1 Abstain: 0 : 4 Table 14.4.2.2, Item 15 (Log # 350 ) Shackley, D. See my Explanation of on Comment 72-184 (Log #131). 72-188 Eligible To Vote:28 Affirmative: 23 : 1 Abstain: 0 : 4 Table 14.4.2.2, Item 15 (Log # 354 ) Shackley, D. See my Explanation of on Comment 72-184 (Log #131).
13 72-189 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 23 (Log # 152 ) 72-190 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Table 14.4.2.2, Item 23 (Log # 153 ) 72-191 Eligible To Vote:28 Affirmative: 22 : 2 Abstain: 0 : 4 14.4.5.3 (Log # 180 ) Koval, C. As currently written, sensitivity testing of smoke alarms is required unless the smoke alarm happens to be located in one and two family dwellings (i.e., it's only required for smoke alarms installed in commercial settings). The smoke alarm doesn't know where it has been installed. Either require sensitivity testing for all smoke alarms or delete the requirement entirely. Don't use the inability to enforce this requirement as the deciding factor. If the committee is not going to require sensitivity testing in one and two family dwellings, then it would seem appropriate to delete this requirement for all smoke alarms. The TCC needs to weigh on this one way or the other and remove this double standard so NFPA 72 can adequately protect the public, especially given the acceptance of 72-195 which will require all single and multiple station smoke alarms to be replaced when the fail to respond to operability tests.
14 Larrimer, P. The requirements for the testing of a device should be independent of the location or occupancy in which it is installed. The committee statement "No technical substantiation has been provided that if this requirement is dropped there will not be a negative impact on life safety." shows how hard it is to remove a code requirement when the code requirement is added without technical justification. The committee wants the proponent to justify the removal of the requirement for sensitivity testing that was never technically justified to be in the code in the first place. The committee also states "Without the requirements of sensitivity testing, the reliability of a smoke alarm device is reduced. " If the committee honestly believes that the reliability of smoke alarms will be reduced if sensitivity testing is not done, then exempting this requirement for one- and two-family dwellings seems to be irresponsible since it is well known and has been discussed in the committee meetings that the fire loss record in one- and two-family dwellings is much more of a problem than in the occupancies where the sensitivity testing smoke alarms is required. Why would the committee reduce the reliability of the device in one- and two-family dwellings where the fire record is known to be a bigger problem? If smoke alarms with a push button sensitivity test button are available at a reasonable cost, why are they not mandated to be installed in the first place? If these smoke alarms are so much better than those that don't have the push button sensitivity feature, then they should be mandated without expecting them to be installed via a back door testing requirement. 72-192 Eligible To Vote:28 Affirmative: 22 : 2 Abstain: 0 : 4 14.4.5.3 and Table 14.4.2.2 (Log # 262 ) Koval, C. See my Explanation of on Comment 72-191 (Log #180). Larrimer, P. See my Explanation of on Comment 72-191 (Log #180). 72-193 Eligible To Vote:28 Affirmative: 21 : 3 Abstain: 0 : 4 14.4.5.3 and Table 14.4.2.2 (Log # 298 ) Koval, C. See my Explanation of on Comment 72-191 (Log #180). Larrimer, P. See my Explanation of on Comment 72-191 (Log #180).
15 Moore, J. Until the 2002 Edition of the Code, the inspection, testing and maintenance requirements for single and multiple station smoke alarms were contained in the self-contained chapter that addressed Single- and Multiple-Station Alarms and Household Fire Alarm Systems. The 2002 edition of NFPA 72 moved all inspection, testing, and maintenance requirements for single- and multiple-station smoke alarms to Chapter 10, Inspection, Testing and Maintenance. The sensitivity testing requirements that were originally applicable only to system detectors, was made applicable to single- and multiple-station smoke alarms in other than one- and two-family dwellings by a change to 10.4.3.2. The Committee Statement for the 2002 ROP action on 72-441a states, In previous action (1999) it was the intent of the Committee to require sensitivity testing for single station smoke alarms installed in other than one and two family dwelling units. However, NFPA 72-1999, 7-3.2.1 (Sensitivity Testing), Exception 2 states, This requirement shall not apply to single station detectors referenced in 7-3.3 and Table 7-2.2. The committee statement for NFPA 72-2002, ROP 73-441a also references commentary text in the 1999 Edition of the NFPA 72 Handbook as justification for why the requirement applies to single station detectors. The handbook commentary is just that, commentary. It can t be used as after the fact justification for a previous committee action. The committee action must be justified on its own merit. The current committee action on NFPA 72-2013, ROC 72-193 continues to require that sensitivity testing for single- and multiple-station smoke alarms in other than one- and two-family dwellings without technical substantiation that (1) it s possible or practical to enforce in many situations, and (2) that it improves the safety of the building occupants. The commenter s substantiation the explains that the committee explanation that the same right of entry issues used as the basis to exempt one- and two-family dwellings from the sensitivity testing requirements exist in apartments and condominiums. 72-194 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 14.4.7.1 (Log # 26 ) 72-195 Eligible To Vote:28 Affirmative: 22 : 2 Abstain: 0 : 4 14.4.8.1 (Log # 221 ) Kerr, J. I believe the committee acted outside of our scope. This requirement came to us from Household and belongs to them. Van Overmeiren, F. Smoke alarms should not remain in service longer than 10 years based upon environment issues, battery life and technology. If testing and listing of devices can prove a life cycle longer than 10 years, sections 14.4.8.1 and 14.4.8.2 should be changed to reflect such. 72-196 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 14.4.13, 14.4.13.1, 14.4.13.2, 14.4.13.3 (Log # 84 )
72-197 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 14.5.1 (New) (Log # 284 ) 72-198 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 14.5.1 and 14.5.2 (New) (Log # 328 ) 72-199 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 14.6.2.4 (Log # 19 ) 72-200 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Figure 14.6.2.4 through Figure 14.6.2.4(e) (Log # 90 ) 72-200b Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Figure 14.6.2.4 (Log # CC900 ) 16
17 72-201 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Figure 14.6.2.4(a) through (f) (Log # 254 ) 72-249 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 21.2.12 and A.21.2.12 (Log # 60 ) 72-250 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 21.2.13, 21.2.14, and A.21.2.14 (New) (Log # 38 ) 72-426 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 A.14.2.1.2 and Annex H (Log # 236 )
18 72-428 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 A.14.4.12.1.3, A.14.4.12.1.4, and A.14.4.12.1.5 (Log # 20 ) 72-429 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Figure A.14.6.2.4 (Log # 53 ) 72-456 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 D.5.2.3.5 (Log # 211 ) 72-458 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 Annex G (Log # 56 ) 72-459 Eligible To Vote:28 Affirmative: 24 : 0 Abstain: 0 : 4 G.1 (Log # 362 )
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