Page 134 of 195 Public Comment No. 3-NFPA 101-2013 [ Section No. 28.7.6.1 ] 28.7.6.1 New draperies, curtains, and other similar loosely hanging furnishings and decorations shall be flame resistant as demonstrated by testing in accordance with meet the flame propagation performance criteria contained in Test Method 1 or Test Method 2, as appropriate, of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. Statement of Problem and Substantiation for Public Comment Page 1 of 10
Page 135 of 195 This is a section where a public input was apparently omitted (probably my fault). The public comment makes this section consistent with the language in the majority if the sections of NFPA 101 where NFPA 701 is referenced. See, for example section 10.3.1. See also public input 118 and FR506. Two issues are being addressed here: (a) the replacement of "flame resistant" by "the flame propagation criteria of NFPA 701" and (b) the clarification of the test method to be used. The first item relates to the fact that NFPA 701 used to be described as a test for "flame resistant" fabrics or decorations but it is now (more appropriately) described as a test that assesses flame propagation criteria. This terminology is used throughout NFPA 101 and other codes and should be used in this section. The rationale for adding "in accordance with Test Method 1 or Test Method 2" follows and is intended to avoid misrepresentation by some suppliers (perhaps due to confusion): In 1989 the NFPA Technical Committee on Fire Tests eliminated the so-called small-scale test from NFPA 701 because the results had been shown not to represent a fire performance that corresponded to what happened in real scale. Instead of the small-scale test NFPA 701 now (and for over 20 years) contains two tests (Test 1 and Test 2), which apply to materials as indicated by the text of NFPA 701 (2010) that is shown at the bottom of this public input. However, a large number of manufacturers continue stating that the materials or products that they sell have been tested to NFPA 701, when they really mean the pre-1989 smallscale test in NFPA 701. That test no longer exists and materials or products meeting that test do not exhibit acceptable fire performance. Text of NFPA 701 (2010): 1.1.1.1 Test Method 1 shall apply to fabrics or other materials used in curtains, draperies, or other window treatments. Vinyl-coated fabric blackout linings shall be tested according to Test Method 2. 1.1.1.2 Test Method 1 shall apply to single-layer fabrics and to multilayer curtain and drapery assemblies in which the layers are fastened together by sewing or other means. Vinyl-coated fabric blackout linings shall be tested according to Test Method 2. 1.1.1.3 Test Method 1 shall apply to specimens having an areal density less than or equal to 700 g/m2 (21 oz/yd2), except where Test Method 2 is required to be used by 1.1.2. 1.1.2.1 Test Method 2 (flat specimen configuration) shall be used for fabrics, including multilayered fabrics, films, and plastic blinds, with or without reinforcement or backing, with areal densities greater than 700 g/m2 (21 oz/yd2). 1.1.2.2 Test Method 2 shall be used for testing vinyl-coated fabric blackout linings and lined draperies using a vinyl-coated fabric blackout lining. 1.1.2.3 Test Method 2 shall be used for testing plastic films, with or without reinforcement or backing, when used for decorative or other purposes inside a building or as temporary or permanent enclosures for buildings under construction. 1.1.2.4 Test Method 2 shall apply to fabrics used in the assembly of awnings, tents, tarps, and similar architectural fabric structures and banners. Note also the following from the text of NFPA 701 (2010): 1.2* Purpose. 1.2.1 The purpose of Test Methods 1 and 2 shall be to assess the propagation of flame beyond the area exposed to the ignition source. A.1.1 A small-scale test method appeared in NFPA 701 until the 1989 edition. It was eliminated from the test method because it has been shown that materials that pass the test do not necessarily exhibit a fire performance that is acceptable. The test was not reproducible for many types of fabrics and could not predict actual full-scale performance. It should not, therefore, be used. A.1.1.1 For the purposes of Test Method 1, the terms curtains, draperies, or other types of Page 2 of 10
Page 136 of 195 window treatments, where used, should include, but not be limited to, the following items: (1) Window curtains (2) Stage or theater curtains (3) Vertical folding shades (4) Roll-type window shades (5) Hospital privacy curtains (6) Window draperies (7) Fabric shades or blinds (8) Polyvinyl chloride blinds (9) Horizontal folding shades (10) Swags Examples of textile items other than window treatments to which Test Method 1 applies include: (1) Table skirts (2) Table linens (3) Display booth separators (4) Textile wall hangings (5) Decorative event tent linings not used in the assembly of a tent Submitter Information Verification Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Fri Mar 08 17:07:07 EST 2013 Copyright Assignment I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Page 3 of 10
Page 137 of 195 Public Comment No. 4-NFPA 101-2013 [ Section No. 29.7.6.1 ] 29.7.6.1 New draperies, curtains, and other similar loosely hanging furnishings and decorations shall be flame resistant as demonstrated by testing in accordance with meet the flame propagation performance criteria contained in Test Method 1 or Test Method 2, as appropriate, of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. Statement of Problem and Substantiation for Public Comment Page 4 of 10
Page 138 of 195 This is a section where a public input was apparently omitted (probably my fault). The public comment makes this section consistent with the language in the majority if the sections of NFPA 101 where NFPA 701 is referenced. See, for example section 10.3.1. See also public input 118 and FR506. Two issues are being addressed here: (a) the replacement of "flame resistant" by "the flame propagation criteria of NFPA 701" and (b) the clarification of the test method to be used. The first item relates to the fact that NFPA 701 used to be described as a test for "flame resistant" fabrics or decorations but it is now (more appropriately) described as a test that assesses flame propagation criteria. This terminology is used throughout NFPA 101 and other codes and should be used in this section. The rationale for adding "in accordance with Test Method 1 or Test Method 2" follows and is intended to avoid misrepresentation by some suppliers (perhaps due to confusion): In 1989 the NFPA Technical Committee on Fire Tests eliminated the so-called small-scale test from NFPA 701 because the results had been shown not to represent a fire performance that corresponded to what happened in real scale. Instead of the small-scale test NFPA 701 now (and for over 20 years) contains two tests (Test 1 and Test 2), which apply to materials as indicated by the text of NFPA 701 (2010) that is shown at the bottom of this public input. However, a large number of manufacturers continue stating that the materials or products that they sell have been tested to NFPA 701, when they really mean the pre-1989 smallscale test in NFPA 701. That test no longer exists and materials or products meeting that test do not exhibit acceptable fire performance. Text of NFPA 701 (2010): 1.1.1.1 Test Method 1 shall apply to fabrics or other materials used in curtains, draperies, or other window treatments. Vinyl-coated fabric blackout linings shall be tested according to Test Method 2. 1.1.1.2 Test Method 1 shall apply to single-layer fabrics and to multilayer curtain and drapery assemblies in which the layers are fastened together by sewing or other means. Vinyl-coated fabric blackout linings shall be tested according to Test Method 2. 1.1.1.3 Test Method 1 shall apply to specimens having an areal density less than or equal to 700 g/m2 (21 oz/yd2), except where Test Method 2 is required to be used by 1.1.2. 1.1.2.1 Test Method 2 (flat specimen configuration) shall be used for fabrics, including multilayered fabrics, films, and plastic blinds, with or without reinforcement or backing, with areal densities greater than 700 g/m2 (21 oz/yd2). 1.1.2.2 Test Method 2 shall be used for testing vinyl-coated fabric blackout linings and lined draperies using a vinyl-coated fabric blackout lining. 1.1.2.3 Test Method 2 shall be used for testing plastic films, with or without reinforcement or backing, when used for decorative or other purposes inside a building or as temporary or permanent enclosures for buildings under construction. 1.1.2.4 Test Method 2 shall apply to fabrics used in the assembly of awnings, tents, tarps, and similar architectural fabric structures and banners. Note also the following from the text of NFPA 701 (2010): 1.2* Purpose. 1.2.1 The purpose of Test Methods 1 and 2 shall be to assess the propagation of flame beyond the area exposed to the ignition source. A.1.1 A small-scale test method appeared in NFPA 701 until the 1989 edition. It was eliminated from the test method because it has been shown that materials that pass the test do not necessarily exhibit a fire performance that is acceptable. The test was not reproducible for many types of fabrics and could not predict actual full-scale performance. It should not, therefore, be used. A.1.1.1 For the purposes of Test Method 1, the terms curtains, draperies, or other types of Page 5 of 10
Page 139 of 195 window treatments, where used, should include, but not be limited to, the following items: (1) Window curtains (2) Stage or theater curtains (3) Vertical folding shades (4) Roll-type window shades (5) Hospital privacy curtains (6) Window draperies (7) Fabric shades or blinds (8) Polyvinyl chloride blinds (9) Horizontal folding shades (10) Swags Examples of textile items other than window treatments to which Test Method 1 applies include: (1) Table skirts (2) Table linens (3) Display booth separators (4) Textile wall hangings (5) Decorative event tent linings not used in the assembly of a tent Related Public Comments for This Document Related Comment Public Comment No. 3-NFPA 101-2013 [Section No. 28.7.6.1] Relationship same issue for new hotels in 28.7.6.1 and for existing hotels in 29.7.6.1 Submitter Information Verification Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Fri Mar 08 17:30:30 EST 2013 Copyright Assignment I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Page 6 of 10
Page 140 of 195 Public Comment No. 41-NFPA 101-2013 [ Sections 30.3.4.6.1, 30.3.4.6.2 ] Sections 30.3.4.6.1, 30.3.4.6.2 30.3.4.6.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with Section 9.8 and 30.3.4.6 shall be provided in new apartment buildings where either of the following conditions exists: (1) Dwelling units with communicating attached garages, unless otherwise exempted by 30.3.4.6.3 (2) Dwelling units containing a permanently installed fuel-burning appliance or fuel-burning fireplace (3) Common areas of buildings that are served by fuel fired appliances 30.3.4.6.2 Where required by 30.3.4.6.1, carbon monoxide alarms or carbon monoxide detectors shall be installed in the following locations: (1) Outside of each separate dwelling unit sleeping area in the immediate vicinity of the sleeping rooms (2) On every occupiable level of a dwelling unit (3) Throughout all common corridors and areas not exempted by 30.3.4.6.3. Statement of Problem and Substantiation for Public Comment With over 2000 deaths a year from carbon monoxide poisoning the codes have acknowledged a need to incorporate CO detection in the model codes. When doing so, the codes neglected or overlooked the spaces of the buildings that are often most effected by the largest number of residents and responding personnel, the corridors and common areas. More and more often new residential building are being served by fuel fired furnaces and appliances like fire places and community rooms with stoves and associated fuel fired water heaters etc. The need for CO coverage needs to extend beyond the individual units into common spaces as well to best protect and prevent unknowing persons from entering a hazardous atmosphere. Submitter Information Verification Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Apr 02 21:41:02 EDT 2013 Copyright Assignment Page 7 of 10
Page 141 of 195 I, Doug Hohbein, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Doug Hohbein, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Page 8 of 10
Page 142 of 195 Public Comment No. 42-NFPA 101-2013 [ New Section after 31.3.4.5.4 ] 31.3.4.6 Carbon Monoxide Detection 31.3.4.6.1 single station carbon monoxide detection shall be installed throughout the common areas of all existing residential buildings that are served by fuel fire appliances in accordance with the following: 1. Where permanent power is readily available all devices shall be attached to the permanent wiring system in accordance with NFPA 70 2. Where permanent power is not readily available, or where approved by the AHJ battery powered carbon monoxide detection shall be permitted 31.3.4.6.2 Carbon monoxide alarms and carbon monoxide detectors as specified in 31.3.4.6.1 shall not be required in open parking garages and enclosed parking garages with functioning mechanical ventilation systems 31.3.4.6.4 Carbon monoxide alarms or carbon monoxide detectors shall be provided in areas other than dwelling units in accordance with Section 9.8, as modified by 30.3.4.7.5. 31.3.4.6.5 Carbon monoxide alarms or carbon monoxide detectors shall be installed in accordance with the manufacturer s published instructions and in accordance with their listing. Statement of Problem and Substantiation for Public Comment With over 2000 deaths a year from carbon monoxide poisoning the codes have acknowledged a need to incorporate CO detection in the model codes. When doing so, the codes neglected or overlooked the spaces of the buildings that are often most effected by the largest number of residents and responding personnel, the corridors and common areas. More and more often new residential building are being served by fuel fired furnaces and appliances like fire places and community rooms with stoves and associated fuel fired water heaters etc. The need for CO coverage needs to extend beyond the individual units into common spaces as well to best protect and prevent unknowing persons from entering a hazardous atmosphere. Submitter Information Verification Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Apr 02 21:44:25 EDT 2013 Page 9 of 10
Page 143 of 195 Copyright Assignment I, Doug Hohbein, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Doug Hohbein, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Page 10 of 10