~ Chair SAF-FUR · NFPA 101 -- F99 ROC Technical Committee on Board and Care Facilities (SAF-BCF) (Chapters 22 and 23) Philip C. Favro, Chair Favro Assoc., CA [SE]

Report of the Committee on

Safety to Life

Technical Correlating Committee (SAF-AAC)

J. Kenneth Richardson, CAair Ken Richardson Fire Technologies, Inc., Ontario, Canada [SE]

Ron Cot6, Nonvoting Secretary Nat'l Fire Protection Assn., MA

Alastair J. M. Aikman, Nat'l Research Council of Canada, Ontario, Canada [RT] hn L. Bryan, Frederick, MD [SE] chard W. Bukowski, U.S. Nat'l Inst. of Standards and

Technology, MD [RT] Rep. NFPA Nat'l Fire Alarm Code Committee

Lee J. Dosedlo, Underwriters Laboratories Inc., IL [RT] Gene B. Endthoff, Nat'l Fire Sprinkler Assn., IL [M] Wayne D. Holmes, HSB Professional, Loss Control Inc., CT [I] J. Edmund Katie, Jr., Prince George s County Gov't, MD [E] Alfred J. Longhitano, Gage-Babcock & Assoc., Inc., NY [U]

Rep. American Health Care Assn. Ronald IL Mengel, Pittway Systems Technology Group, IL [M]

Rep. Nat'l Electrical Mfrs. Assn. Kirby W. Perry, Kirby W. Perry Architects & Assoc. Inc., TX [SE]

Rep. American Inst. of Architects Lawrence G. Perry, Silver Spring, MD [U]

Rep. Building Owners & Managers Assn. Intl James R. Quiter, RolfJensen & Assoc., Inc., CA [SE] Walter Smittle, West Virginia State Fire Marshal, WV [E]

Rep. Int'l Fire Marshals Assn. Richard E. Thonnings, American Insurance Services Group, Inc.,

NY [ll Jay Woodward, Int'l Conference of Building Officials, MO [E]

Rep. Int'l Code Council, Inc.

Alternates

Frederick C. Bradley, Gage-Babcock & Assoc., Inc., GA [U] (Alt. to A.J. Longhitano)

Kenneth E. Bush, Maryland State Fire Marshals Office, MD [E] (Alt. to W. Smittle)

J. Thomas Carter, Chloride Systems, NC [M] (Alt. to 1L K. Mengel)

Russell P. Fleming, Nat'i Fire Sprinkler Assn., NY [M] (Alt. to G. B. Endthoff)

Howard Hopper, Underwriters Laboratories Inc., CA [RT] (Alt. to L.J. Dosedlo)

Daniel Madrzykowski, U.S. Nat'l Inst. of Standards & Technology, MD [RT] (Alt. to R. W. Bukowski)

Martin H. Reiss, The RJA Group, Inc., MA [SE] (Alt. to J. R. Quiter)

Michael D. Tomy, Heery Int'l Inc., GA [SE] (Alt. to K. W. Perry)

Nonvoting

Wayne G. (Chip) Carson, Carson Assoc., inc., VA, Chair SAF-HEA Philip C. Favro, Philip C. Fawo & Assoc., CA, Chair SAF-BCF Thomas W. Jaeger, Gage-Babcock & Assoc., Inc., VA, Chair

SAF-DET Joseph M. Jardin, New York City Fire Dept., NY, Chair SAF-RES William E. Koffei, Jr., Koffel Assoc., Inc., MD, Chair SAF-MEA Gerald E. Lingenfelter, American Ins Services Group Inc., NY,

Chair SAF-FUR

~ ohn W. McCormick, Code Consultants Inc., MO, Chair SAF-FIR onus L. Morehart, Punta Gorda, FL (Member Emeritus)

Harold E. Nelson, Hughes Assoc., Inc., MD (Member Emeritus)

Richard IL Osman, Schirmer Engr Corp., IL, Chair SAF-BSF Ed Schultz, Code Consultants Inc., MO, Chair SAF-MER John A. Sharry, Lawrence Livermore Nat'l Laboratory, CA, Chair

SAF-AXM

Catherine L. Stashak, Des Plalnes Fire Dept., IL, Chair SAF-END David W, Stroup, U.S. Nat'l Inst. of Standards and Technology,

MD, Chair SAF-AL,S Gregory W. Thomas, Liberty Mutual Group, CT, Chair SAF-IND John M. Watts, Jr., Fire Safety Inst., VT, Chair SAF-FUN

Committee Scope: This Committee shall have primary responsibility for documents on the protection of human life from fire and other circumstances capable of producing similar consequences and for the nonemergency and emergency movement of people.

Technical Committee on

Assembly Occupancies and Membrane Structures (SAF-AXM) (Chapters 8, 9 and NFPA 102)

John A. Sharry, Chair Lawrence Livermore Nat'l Laboratory, CA [C]


Stanton M. Alexander, North American Testing Co., FL [M] Weston E. Bacon, Jr., Bacon Hedland Mgmt., IL [U]

Pep. Int'l Assn. of Exposition Mgmt. Scott IL Bartlett, Simplex Time Recorder Co., MA[M]

Rep. Nat'l Electrical Mfrs. Assn. Dale T. Cich, Birdair, Inc., NY [IM] William Conner, Jerit/Boys Inc., IL [SE]

Rep.. American Sodety of Theater Consultants Bhola Dhume, City of New Orleans, LA [E]

Rep. Southern Bldg. Code Congress Int'l Inc. Robert D. Fiedler, Lincoln Bureau of Fire Prevention, NE [El William E. Fitch, Omega Point Laboratories Inn, TX [RT] William J. Fries, Liberty Mutual Insurance Co., MA [I]

Rep. The Alliance of American Insurers Ralph Gerdes, Ralph Gerdes Consultants, LLC, IN [SE] Brad Gessner, 22"dDistrict Agricultural Assn., CA [U]

Rep. Int'l Assn. Of Assembly Managers, Inc. Jeffrey A. Maddox, RolfJensen & Assoc., Inc., CA [SE] Vern L. Martlndale, Church of Jesus Christ of Latter-day Saints,

LIT [U] Daniel M. McGee, American Iron and Steel Inst., NJ[M] Joseph J. Messersmith, Jr., Portland Cement Assn., VA [M] Gregory IL Miller, Code Consultants Inc., MO [U]

Rep.Nat'l Assn. of Theatre Owners Jake Pauls, Jake Pauls Consulting Services in Bldg. Use and Safety,

MD [SE] Philip It. Sherman, P. IL Sherman Inc., MA [SE] David L. Sutter, Hussey Seating Co., ME [M]

Rep. Nat'l School Supply & Equipment Assn. Henry Teague, Rosser Int'l, GA [SE] Harold E. "Caip ~ Ulich, Herberger Theater Center, AZ [U]

Rep. U.S. Inst. for Theatre Technology Paul L. Wertheimer, Crowd Mgmt. Strategies, IL [SE]

Alternates

David Cook, Ralph Gerdes Consultants, IN [SE] (Alt. to R. Gerdes)

Victor L. Dubrowski, Code Consultants Inc., MO [SE] (Alt. to G. R. Miller)

Don Hancock, Int'l Assn. Of Assembly Managers, TX [U] (Alt. to B. Gessner)

Eugene A. LaValle, Sentrol, Inc., GA [M] (Alt. to S. IL Bartlett)

David J. May, Church of Jesus Christ of Latter-day Saints, UT [U] (Alt. to V. L. Martindale)

Daniel It. Victor, lnterkal, Inc., MI [M] (Alt. to D. L. Sutter)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other drcumstances capable of producing similar consequences, and on the nonemergency and emergency movement of people in assembly occupancies, tents, anct membrane structures.

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N F P A 101 - - F 9 9 R O C


Board and Care Facilities (SAF-BCF) (Chapters 22 and 23)

Philip C. Favro, Chair Favro Assoc., CA [SE]

James D. Lake, Nonvoting Secretary Nat'l Fire Protection Assn., MA

Greg Austin, Gentex Corp., MI [M] Rep. Nat'l Electrical Mfrs. Assn.

James R, Bell, Marriott Corp., DC [U] Rep. American Hotel & Motel Assn.

Warren D. Boniseh, Schirmer Engr Corp., TX [SE] Harry L. Bradley, Maryland State Fire Marshals Office, MD [E]

Rep. Int'l Fire Marshals Assn. " Mary Ellen Early, Florida Assn. of Homes for the Aging (FAHA),

FL [UI Rep. American Assn. of Homes for the Aging

Thomas W. Gardner, Gage-Babcock & Assoc., VA [U] Pep. American Health Care Assn.

Norman E. Groner, Santa Cruz, CA [SE] Laura A. Hoffman, Nashville Tennessee Fire Dept., TN [E] Kenneth E. Isman, Nat'l Fire Sprinkler Assn., NY [M] Philip 1L Jose, U.S. Dept. of Veterans Affairs, NY [U] David Ray Kiely, Community Resource Center of Sullivan County,

NY [U] Rep. American Network of Community Options & Resources

James K. Lathrop, Koffel Assoc., CT [SE] Bernard M. Levin, Rockville, MD [SE] Paul E. Patty, Underwriters Laboratories Inc., IL [RT] Francis G. Reuer, U.S. Dept. of Health & Human Services Health

Care Financing Admin., CO [El

Alternates

Kerry M. Bell, Underwriters Laboratories Inc., IL [RT] (Alt. to P. E. Patty)

Gene B. Endthoff, Nat'l Fire Sprinkler Assn., IL [M] (AlL to ~ E. Isman)

Jonl Fritz, American Network of Community Options & Resources, VA [U] (Alt. to D. 1L Kiely)

Harold E. Nelson, Hughes Assoc. Inc~, MD [SE] (Alt. to B. M. Levin)

Daniel J. Schoeps, U.S. Dept. of Veterans Affairs, DC [U] (Alt. to P. 1L Jose)

James F. Woodford, Simplex Time Recorder Co., MA [M] (Alt. to G. Austin)

Mayer D. Zimmerman, U.S. Dept. of Health & Human Services Health Care Financing Admin., MD [E] (Alt. to F. G. Reuer)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances producing similar consequences, and on the emergency movement of people, in residential board and care facilities.


Building Service and Fire Protection Equipment (SAF-BSF) (Chapter 7)

Richard IL Osman, Cha/r Schirmer Engr Corp., IL [SE]

James D. Lake, Nonvoting Secretary Nat'l Fire Protection Assn., MA

Harry L. Bradley, Maryland State Fire Marshals Office, MD [E] Rep. Int'l Fire Marshals Assn.

Pat D. Brock, Oklahoma State University, OK [SE] Lawrence Brown, Nat'l Assn. Of Home Builders (NAHB),

DC [IM] Edward A. Donoghue, Edward A. Donoghue Assoc., Inc., NY [M]

Rep. Nat'l Elevator Industry Inc. Kenneth E. Isman, Nat'l Fire Sprinkler Assn. [M] Joseph M. Jardin, New York City Fire Dept., NY [C]

Rep. NFPA Fire Service Section

Ronald H. Kirby, Simplex Time Recorder Co., MA [M] Rep. Nat'l Electrical Mfrs. Assn.

David P. Klein, U.S. Dept. of Veterans Affairs, MD [U] Richard L Klinker, Klinker & Assn., Inc., MD [SE] Roger L. McDaniel, Dept. of Corrections, FL [U] L. L. (Larry) Neibauer, Automatic Fire Alarm Assn., FL [M] Martin H. Relss, The RJA Group, Inc., MA [SE] John T. Wandell, Town of Palm Beach Fire/Rescue, FL [E]

Alternates

Rouald S. Berger, Low Voltage Systems Technology [M] (Alt. to L. L. Neibauer)

James D. Brown, Oklahoma State University, OK [SE] (AlL to P. D. Brock)

Tariq Bsharat, Nat'l Fire Sprinkler Assn., NY [M] (Alt. to K. E. Isman)

Greg Gottlieb, Hauppauge Fire District, NY [C] (Alt. to J. M. Jardin)

Claudia Hagood, Klinker and Assoc., Inc., MD [SE] (AIt. to 1L L Klinker)

Peter A. l.arrimer, U.S. Dept. of Veterans Affairs, PA [U] (Alt. to D. P. Klein)

Eugene A. Lagalle, Sentrol, Inc., GA [M] (Alt. to R. H. Kirby)

Randolph W. Tucker, RolfJensen & Assoc., Inc., TX [SE] (Alt. to M. H. Reiss)

Joseph Wiehagen, Nat'l Assn. of Home Builders, MD [IM] (Air. to L. Brown)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances capable of producing similar consequences and on the emergency movement of people.


Detention and Correctional Occupancies (SAF-DET) (Chapters 14 and 15)

Thomas W. Jaeger, Chair Gage-Babcock & Assoc., Inc., VA [SE]

Ron Cott, Nonvoting Secretary Nat'l Fire Protection Assn., MA

?ames IL Ambrose, Code Consultants Inc., MO [SE] rancis C. Barbaro, Hampden County Sheriff's Dept., MA [U]

David L. Bondor, St. Paul Fire & Marine., TX [I] Rep. American Society of Safety Engr

Robbie D. Church, U.S. Bureau of Prisons, DC [U] Michael DiMascio, Solutions Engr Inc., MA [SE] Randy Gaw, Correctional Service of Canada, Ontario, Canada [E] David A. Gilda, Builders Hardware Mfrs. Assn., CT [M] Patrick G. Gordon, Philadelphia Prison System, PA [U] Larry Harrison, Illinois Office of State Fire Marshals, IL [E] Kenneth E. Isman, Nat'l Fire Sprinkler Assn. [M] W'flliam E. Koffel, Jr., Koffel Assoc., Inc., MD [SE] Roger L McDaniel, Dept. of Corrections, FL [U] E. Eugene Miller, Washington, DC [SE] A. N.Moser, Jr., Nat'l Sheriffs' Assn., VA [U] Jerry Nealy, Cumulus Fibres, Inc., NC [M]

Rep. Institutional Bedding Mfrs. Assn. Steven E. Rawson, Simplex Time Recorder Co., MA [M]

Rep. Nat'l Electrical Mfrs. Assn. Kenneth J. Schwartz, Schirmer Engr Corp., IL [SE] Wayne S. Smith, Texas Commission on Fire Protection Regions,

TX[E] Rep. Int'l Fire Marshals Assn.

Alternates

Peter J. Collins, U.S. Federal Bureau of Prisons, DC [U] (Alt. to R. D. Church)

A. Larry Iseminger, Jr., Maryland State Fire Marshals Office [E] (AlL to W. S. Smith)

Alfred J. Longhitano, Gage-Babcock & Assoc., Inc., NY [SE] (Alt. to T. W. Jaeger)

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N F P A 101 - - F99 R O C

Richard IL McDaniel, Office of the Illinois State Fire Marshal, IL [El (Alt. to L. Harrison)

Robert IL Perry, Robert Perry Assoc., Inc., IL [M] (Voting Alt. to DHI Rep.)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in detention and correctional occupancies.


Educational and Day-Care Occupancies (SAF-END) (Chapters 10, 11, 30 and $1)

Catherine L. Stashak, Chair Des Plaines Fire Dept., IL [E]

Ron Cott, Nonvoting Sea*tar 3 Nat'l Fire Protection Assn., MA

Scott R. BarrieR, Simplex Time Recorder Co., MA [M] Samuel S. Dannaway, S. S. Dannaway Assoc., Inc., HI [SE] Victor L. Dubrowski, Code Consultants Inc., MO [SE] Stephen E. Duff'm, Zurich Services Corp., IL [1] Gene B. Endthoff, Nat'l Fire Sprinkler Assn., IL [M] Lance J. Ewing, School District of Philadelphia, PA [U] Douglas R. Freels, Performance Design Technologies, LLC,

TN [SE] Vern L. Martlndale, Church of Jesus Christ of Latter<lay Saints, UT [U]

Michael L. Sinslgalli, Windsor Locks ~,re Dept., CT [E] Aleksy L. SL~chnowicz, Prince George s County Gov't Board of

Education, MD [E] Robert T. Trotter, Franklin Fire Dept., TN [U] Ralph J. Warburton, University of Miami, FL [SE] Carl F. Weaver, Brevard Community College, FL [SE] Kenneth Wood, Office of the Illinois State Fire Marshal, IL [E]

Alternate

R•tr B. Rudy, Performance Design Technologies, LLC, TN [SE] to D. R. Freels)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in educational occupancies and day-care occupancies.


Fire Protection Features (SAF-FIR) (Sections 6-1 through 6-4)

John W. McCormick, Chair Code Consultants Inc., MO [SE]

Walter P. Sterling, Nonvoting Secretary Nat'l Fire Protection Assn., MA

Carl F. Baldassarra, Schirmer Engr Corp., IL [SE] John F. Bender, Maryland Office of State Fire Marshal, MD [E]

Rep. Int'l Fire Marshals Assn. Robert M. Berhinig, Underwriters Laboratories Inc., IL [RT] Joseph A. Brooks, Air Movement and Control Assn. Int'l, Inc.,

IL [M] Edward IL Budnick, Hughes Assoc. Inc., MD [SE] Gregory J. Cahanin, St. Petersburg, FL [U]

Rep.Louisiana State Fireman's Assn. Raman B. Chauhan, Nat'l Research Council of Canada, Ontario,

Canada [RT] Eric Cote, RolfJensen & Assoc., Inc., MA [SE] Thomas G. Daly, Hilton Hotels Corp., CA [U]

Pep. NFPA Lodging Industry Section Brian L. Eklow, AON Risk Services, IL [I1 Gene B. Endthoff, Nat'l Fire Sprinkler Assn., IL [M] Sam W. Francis, American Forest & Paper Assn., PA[M] Ralph Gerdes, Ralph Gerdes Consultants, LLC, IN [SE]

Donald Murray Golf, Hillsborough County Fire Rescue, FL [E] Rep. Florida Fire Marshals Assn.

MilesJ. Haber, Monument Construction, Inc., MD [IM] Pep. Nat'l Assn. of Home Builders

Dale D. Hasty, Cerberus Pyrotronics, MO [M] Rep. Fire Suppression Systems Assn.

Wayne D. Holmes, HSB Professional Loss Control, Inc., CT [I] Jonathan Humble, American Iron and Steel Inst., CT [M] Tod L Jilg, Hoechst Celanese Corp., NC [M]

Rep. American Fiber Mfrs. Assn. Donald L. King, Steelcraft Mfg. Co., OH [M]

Rep. Steel Door Inst. Marshall A. Klein, Marshall A. Klein & Assoc., Inc., MD [SE] Richard F. Lattey, Liberty Mutual Insurance Group, MA [I]

Pep. The Alliance of American Insurers Joseph J. Messersmith, Jr., Portland Cement Assn., VA [M] Diane V. Stelger, CIGNA Loss Control Services, NJ [I]

Rep. American Insurance Services Group Sharon M. Stone, Koffel Assoc., Inc., MD [SE] Kenneth Wood, Orifice of Illinois State Fire Marshal, IL [E]

Alternates

Robert H. Barker, American Fiber Mfrs. Assn., DC [M] (AlL to T. L. Jilg)

Kenneth E. Bland, American Forest & Paper Assn., DC [M] (Alt. to S. W. Francis)

Delbert F. Boring, Jr., American Iron & Steel Inst., OH [M] (Alt. to J. Humble)

Lawrence Brown, Nat'l Assn. Of Home Builders (NAHB), DC JIM] (Alt. to M.J. Haber)


John F. Devlin, Schirmer Engr Corp., VA [SE] (Alt. to C. F. Baldassarra)

Jack Gump, HSB Professional Loss Control, TN [I] (Alt. to W. D. Holmes)

Daniel J. Harviugton, CGU Insurance, NY [I] (Alt. to D. V. Steiger)

Mark Kluver, Portland Cement Assn., CA [M] (Alt. to J.J. Messersmith)

William E. Koffel, Jr., Koffel Assoc., Inc., MD [SE] (Alt. to S. M. Stone)

David A. Lewis, Code Consultants Inc., MO [SE] (Alt. to J. W. McCormick)

JeffreyA. Maddox, RolfJensen & Assoc., Inc., CA [SE] (Air. to E. Cote)

Eric Rosenbaum, Hughes Assoc., Inc., MD [SE] (Alt. to E. K. Budnick)

Nonvoting

Michael Earl Dillon, Dillon Consulting Engr, Inc., CA Rep. TC on Air Conditioning

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances capable of producing similar consequences and on the emergency movement of people.


Fundamentals (SAF-FUN) (Chapters 1 through 4)

ohn M. Watts, Jr., Chair re Safety Inst., VT [SE]

Ron Cott, Nonvoting Seoretar~ Nat'l Fire Protection Assn., MA

Wayne G. (Chip) Carson, Carson Assoc., Inc., VA [SE] Gregory W. Gallagher, New York State Dept. of State, NY [E] Norman E. Groner, Santa Cruz, CA [SE] Howard Hopper, Underwriters Laboratories Inc., CA [RT] Morgan J. Hurley, Society of Fire Protection Engr, MD [U] David P. Klein, U.S. Dept. of Veterans Affairs, MD [U] James IL Lathrop, Koffel Assoc., CT [SE] Richard A. Morris, Nat'l Assn, of Home Builders, DC [IM]

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N F P A 101 - - F 9 9 R O C

Walter Smittle, III, West Virginia State Fire Marshals Office, WV [El Rep. Int'l Fire Marshals Assn.

David W. Stroup, U.S. Nat'l Inst. of Standards and Technology, MD [RT]

Joy Woodward, Int'l Conference of Bldg. Officials, MO [E]

Alternate

Lawrence Brown, Nat'l Assn. Of Home Builders (NAHB), DC [IM] (Alt. to 1L A. Morris)

Eugene A. Cable, U.S. Dept. of Veterans Affairs, NY [U] (AlL to D. P. Klein)

Brian J. Meaeham, Society of Fire Protection Engr, MA [U] (Alt. to M.J. Hurley)

Nonvothg

Carol Caldwell, Galdwell Consulting, Ltd, New Zealand

Committee Scope: This Committee shall have primary responsibifity for documents on the basic objectives, requirements, and definitions for protection of human life from fire and other circumstances capable of producing similar consequences and on the nonemergency and emergency movement of people.


Furnishings and Contents (SAF-FUR) (Sections 6-5 and 6-6)

Gerald E. Lingenfelter, Chair American Insurance Services Group Inc., NY Ill


Patty IL Adair, American Textile Mfrs. Inst., DC [M] Alastair J. M. Aikman, Nat'l Research Council of Canada, Ontario,

Canada [RT] Vytenis Babrauskas, Fire Science and Technology Inc_, MD [SE]

hn A. Blair, The DuPont Co., DE [M] chard W. Bukowski, U.S. Nat'! Inst. of Standards and

Technology, MD [RT] Eugene A. Cable, U.S. Dept. of Veterans Affairs, NY [U] Frederic B. Clarke, Benjamin/Clarke Assoc., Inc., MD [SE] Paul Dillon, Southern College of Technology, GA [M]

Rep. Sleep Products Safety Council W'dliam E. Fitch, Omega Point Laboratories Inc., TX [RT] Marcelo M. Hirschler, GBH Int'l, CA [SE] Alfred J. Hogan, Reedy Creek Improvement District, FL [E] E. Ken McIntosh, The Carpet andRug Inst., GA [M] T. Hugh Talley, Hugh Talley Co., TN [M]

Rep. American Furniture Mfrs. Assn. James J. Urban, Underwriters Laboratories Inc., IL [RT]

Alternates

Donald W. Belles, Koffel Assoc., Inc., TN [M] (Alt. to E. K. McIntosh)

Raman B. Chauhan, Nat'l Research Council, Ontario, Canada [M] (Alt. to A. J. M. Alkman)

Jolln W. Michener, Milliken Research Corp., SC [M] (Alt. to P. K. Adair)

Thomas J. Ohlemillec, Nat'l Inst. of Standards and Technology, MD [RT] (Alt. to R. W. Bukowski)

James V. Ryan, Potomac, MD [SE] (Alt. to 17. B. Clarke)

Nonvoting

ames F. Hoebel, U.S. Consumer Product Safety Commission, MD ammad Malik, U.S. Consumer Product Safety Commission, MD [C] (Alt. to J. F. Hoebel)

Committee Scope: This Committee shall have primary responsibility for documents on limitin~g the impact of furnishings and building contents effect on protecuon of human life from fire and other carcumstances capable of producing similar consequences and on the emergency movement of people.


Health Care Occupancies (SAF-HEA) (Chapters 12 and 13)

Wayne G. (Chip) Carson, Chair Carson Assoc., Inc., VA[SE]


Kenneth E. Bush, Maryland State Fire Marshals Office, MD [E] Rep. Int'l Fire Marshals Assn.

Michael Crowley, Rolf Jensen & Assoc., Inc., TX [SE] Douglas S. Erickson, American Society for Healthcare Engr, IL [U] Kenneth S. Fauistich, U.S. Dept. of Veterans Affairs, DC [U] John E. Fishbeck, Joint Commission on Accreditation of

Healthcare Orgs., IL [E] Curt Fogel, Phico Insurance Co., ND [I] Thomas W. Jaeger, Gage-Babcock & Assoc. Inc., VA [U]

Rep. American Health Care Assn. Ronald IL Mengel, Pittway Systems Technology Group, IL [M]

Rep. Nat'l Electrical Mfrs. Assn. Daniel.[. O'Connor, Schirmer Engr Corp., IL [SE] Kirby W. Perry, Kirby W. Perry Architects & Assn. Inc., TX [SE]

Rep. American Inst. of Architects Peter P. Petresky, Pennsylvania Dept. of Health, PA [E]

Rep. Assn. of Health Facility Survey Agencies Brian Prediger, U.S. Army, MD [U] Thomas A. Salamone, Kemper Nat'l Insurance Cos., NY [I] David M. Sine, David M. Sine & Assoc., TX [U]

Rep. Nat'l Assn. of Psychiatric Health Systems Richard D. Strub, Life Care Centers of America, TN [U]

Rep. NFPA Health Care Section Mayer D. Zimmerman, U.S. Dept. of Health & Human Services

Health Care Financing Admin., MD [El

Alternates

James IL Ambrose, Code Consultants Inc., MO [SE] (Voting Air. to CCI Rep.)

James H. Antell, RolfJensen & Assoc., Inc., IL [SE] (Alt. to M. Crowley)

John F. Deubler, Schirmer Engr Corp., IL [SE] (Air. to D.J. O'Connor)

J. Richard Fruth, Hayes Large Architects, PA [SE] (Alt. to IL W. Perry)

William E. Koffel, Jr., Koffel Assoc., Inc., [U] (Alt. to D. S. Erickson)

Steven J. Nolin, Simplex Time Recorder Co., MA[M] (Alt. to R. K. Mengel)

Edward M. Shedlock, U.S. Dept. of Veterans Affairs, FL [U] (Alt. to IL S. Fanlstich)

John S. Taylor, St. Vincent's Hospital, AL [U] (Alt. to R. D. Strub)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people, in health care occupancies.

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N F P A 101 - - F9 9 R O C


Industrial, Storage and Miscellaneous Occupancies (SAF-IND) (Chapters 28, 29 and $2)

Gregory W. Thomas, Chair Liberty Mutual Group, CT [I]

Rep. The Alliance of American Insurers


Donald C. Birchler, FP&C Consultants Inc., MO [SE] Howard M. Buccl, U.S. DOE-Fluor Daniel Hartford, WA [U]

J ohn E. Echternacht, Firesafety Consultants, TX [SE] ohn F. Farney, Jr., Sargent & Lundy Engr, IL [SE]

Lany N. Garrett, General Motors Corp., 1N [U] Pep. NFPA Industrial Fire Protection Section

Bruce W. Hisley, Nat'l Fire Academy FEMA, U.S. Fire Administration, MD [E] Rep. Int'l Fire Marshals Assn.

Wayne D. Holmes, HSB Professional Loss Control Inc., CT [I] Neal W. Krantz, Simplex, MI [M]

Rep. Nat'l Electrical Mfrs. Assn. Robert L Smith, Jr., Westinghouse Savannah River Co., SC [U] Michael J. Stelzer, ABB Lummus Crest, Inc., TX [SE]

Rep. American Society of Safety Engr Robert Bruce Wallace, Royal Insurance Co., CA [I]

Rep. American Insurance Services Group, Inc.

Alternate

Jack Gump, HSB Professional Loss Control, TN [I] (Alt. to W. D. Holmes)

Nonvoting

Glen E. Gardner, U.S. Occupational Safety & Health Administration, DC

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people, in industrial and storage occupancies, special structures, windowless and underground buildings, and high-rise buildings.


Means of Egress (SAF-MEA) (Chapter 5)

William E. Koffel, Jr., Chair Koffel Assoc., Inc., MD [SE]


Alastalr J. M. Aikman, Nat'l Research Council of Canada, Ontario, Canada [RT]

John L Barrios, Tampa Dept. Business & Community Services, FL [E] Rep. Southern Bldg. Code Congress Int'l Inc.

Lawrence Brown, Nat'l Assn of Home Builders (NAHB), DC JIM] { ohn L Bryan, Frederick, MD [SE]

enneth E. Bush, Maryland State Fire Marshals Office, MD [E] Rep. Int'l Fire Marshals Assn.

Davie J. Camp, Dover Elevator Systems, Inc., TN [M] Rep. Nat'l Elevator Industry, Inc.

David A. de Vries, American Soceity of Safety Engr, IL [U] Steven DiPilla, CIGNA Loss Control Services, NJ [I] Joshua W. Elvove, Veterans Administration Medical Center, co [u]

Gene B. Endthoff, Nat'l Fire Sprinkler Assn., IL [M] Philip C. Favro, Philip C. Favro & Assoc., CA [SE] Edward L. Fixen, Schirmer Engr, Corp., CA [SE] David W. Frable, U.S. General Services Administraton, IL [U] David A, Gilda, Builders Hardware Mfrs. Assn., CT [M] Billy G. HeRon, Lithonia Emergency Systems, GA [M]

Rep. Nat'l Electrical Mfrs. Assn. Daniel Madrzykowski, U.S. Nat'! Inst. of Standards & Technology,

MD [RT]

Lawrence J. McGimy, U.S. Central Intelligence Agency, DC [U] Wayne Menuz, Underwriters Laboratories Inc., CA [RT] Gene V. Paoluccl, Yasuda Fire & Marine Insurance Co. of

America, NY [I] Rep. American Insurance Services Group, Inc.

Jake Pauls, Jake Pauls Consulting Services in Bldg. Use and Safety, MD [SE]

Eric Resenbaum, Hughes Assoc., Inc., MD [SE] Leslie Strull, RolfJensen & Assoc., Inc., IL [SEI Michael D. Tomy, Heery Int'l. Inc., GA [SE]

Pep. American Inst. of Architects Joseph H. Versteeg, Torrington, CT [E]

Rep. Fairfield, Connecticut Fire Marshals Office David L. Wismer, Philadelphia Dept. of Licenses & Inspections,

PA [E] Rep. Bldg. Officials & Code Administrators Int'l, Inc.

Jay Woodward, Int'l Conference of Bldg. Officals, CA [E]

Alternates

John IL Battles, Southern Bldg. Code Congress Int'l, AL [E] (Air. to J. L Barrios)

Charles H. Kerry, Baltimore VA Medical Center, MD [U] (Alt. to J. W. Elvove)

Warren D. Bonisch, Schirmer Engr Corp., "IX [SE] (Alt. to E. L. F'txen)

Raman B. Chauhan, Nat'i Research Council, Ontario, Canada [RT] (Alt. to A. J. M. Aikman)

Paul Christensen, Prescolite, CA [M] (Alt. to B. G. Helton)

Edward A. Donoghue, Edward A. Donoghur Assoc., Inc., NY [M] (Alt. to D.J. Camp)

MilesJ. Habec, Monument Construction Inc., MD [M] (Air. to L. Brown)

J ames K. Lathro ap,, Koffel Assoc., GT [SE] (A]t. to W. E. I~offel)

James A. Milke, University of Maryland, MD [SEI (Alt. to J. L. Bryan)

Harold F~ Nelson, Hughes Assoc., Inc., MD [SE] (Alt to E. Rosenbaum) James R. Quiter, RolfJensen & Assoc., Inc., CA [SE]

(Alt. to L. Strull) Roy W. Schwarzenberg, U.S. Central Intelligence Agency, DC [U]

(Alt. to L.J. McGinty) Michael Shulman, Underwriters Laboratories Inc., CA [RT]

(Alt. to W. Menuz)

Committee Scope: This Committee shall have primary responsibility for documents on the general requirements for safe e.gress for protection of human life from fire and other ctrcumstances capable of producing similar consequences and on the nonemergency and emergency movement of people.


Mercantile and Business Occupancies (SAF-MER) (Chapters 24 through 27)

Ed Schultz, Chair Code Consultants Inc., MO [SE]


David M. Banwarth, Prince George's County Gov't, MD [E] E, Joseph Bocci, U.S. Dept. of the Treasury, DC [U] Kenneth E. Bush, Maryland State Fire Marshals Office, MD [E]

Rep. Int'l Fire Marshals Assn. Lawrence G. Danielkiewicz, The Taubman Co., MI [U] Douglas S. Erickson, American Society of Healthcare Engr, IL [U] SamW. Francis, American Forest & Paper Assn., PA[M] D~g~a~E1 ~ Freels, Performance Design Technologies, LLC,

Daniel J. Gauvin, Simplex Time Recorder 4~o., MA [M] Rep. Nat'l Electrical Mfrs. Assn.

Darrell W, Harguth, Fire Equipment Mfrs. Assn., Inc., CA [M] Wayne D. Holmes, HSB Industrial Risk Insurers, CT [I] {~j. nathan Humble, #ffnerican Iron and Steel Inst., CT [M]

chard F, Lattey, Liberty Mutual Insurance Group, MA [I] Pep. The Alliance of American Insurers

68

N F P A 1 0 1 - - F 9 9 R O C

Daniel Madrzykowski, U.S. Nat'l Inst. of Standards & Technology, MD [RT]

Brian L Marburger, Kemper Nat'l Insurance Cos., IL If] Rep. American Insurance Services Group, Inc.

Richard V. Moon, Insurance Services Office, NY If] Richard It. Osman, Schirmer Engr Corp., IL [SE] Lawrence G. Perry, Bldg. Owners & Managers Assn. Int'l, MD [U] William J. Tomes, TVA Fire and Life Safety, GA [U]

Rep. Home Depot

Alternates

James P. Begley, Performance Design Technologies, LLC, TN [SE] (Ait. to D. R. Freels)

Delbert F. Boring, Jr . , American Iron & Steel Inst., OH [M] (Alt. to J. Humble)

Jack Gump, HSB Professional Loss Control, TN [I] (AlL to W. D. Holmes)

Eugene A. LaValle, Sentrol, Inc., GA [M] (Alt. to D.J. Gavin)

CoryMakoff, Kemper Insurance Cos., GA [I] (Alt. to B. L. Barburger)

Geot~ge Mills, American Society for Healthcare Engr (AHSE), IL [U] (Alt. to D. S. Erickson)

Sheldon S. Rucinski, Schirmer Engr Corp., IL [SE] (Alt. to R. R. Osman)

David W. Stroup, U.S. Nat'l Inst. of Standards & Technology, MD [RT] (Alt. to D. Madrzykowski)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances capable of producing similar consequences, and for the emergency movement of people, in mercantile and business occupanoes.


Residential Occupancies (SAF-RES) (Chapters 16through 21)

Joseph M. Jardin, Chair New York City Fire Dept., NY [C]

Rep. NFPA Fire Service Section

James D. Lake, Nonvoting Segtetar 3 Nat'l Fire Protection Assn., MA

Carl F. Baldassarra, Schirmer Engr Corp., IL [SE] H. Wayne Boyd, U.S. Safety & Engr Corp., CA [M] Harry L Bradley, Maryland State Fire Marshals Office, MD [E]

Rep. Int'l Fire Marshals Assn. Ronald M. Brave, Snow Country Development LLC, CO [IM]

Rep. Nat'l Assn, of Home Builders Richard W. Bukowsld, U.S. Nat'l Inst. of Standards & Technology,

MD [RT] Peter G. Christie, TAA Ltd., MD [SE] Thomas G. Daly, Hilton Hotels Corp., CA [U]

Rep. NFPA Lodging Industry Section William IL DesPres, Royal Insurance, NC [I]

Rep. American Insurance Services Group, Inc. Sam W. Francis, American Forest & Paper Assn., PA[M] Ralph Gerdes, Ralph Gerdes Consultants, IN [SE] Kenneth E. Isman, Nat'l Fire Sprinkler Assn., NY [M] Robert Kelly, Washington County, OR [E] Marshall A. Klein, Marshall A. Klein & Assoc., Inc., MD [SE] ames IL Lathrop, Koffel Assoc., CT [SE] ugene A. LaValle, Sentrol, Inc., NE [M] Pep. Nat'l Electrical Mfrs Assn.

{~ seph J. Messersmith, Jr., Portland Cement Assn., VA [M] onald G. Nickson, Nat'l Multi Homing Council, DC [U]

Michael A. O'Hara, The MountainStar Group, MN [SE] Erin A. M. Oueisom, U.S. Air Force, Civil Eng. Support Agency,

FL [U] Peter Puhlick, University of Connecticut, CT [U] Jim v. Ray, Marriott Int'l, Inc., DC [U]

Rep. American Hotel & Motel Assn. Vincent E. Sbarra, Gage-Babcock & Assoc., Inc., NY [SE] T. Hugh Talley, Hugh Talley Co., TN [M]

Rep. American Furniture Mfrs. Assn.

Alternates

James R. Bell, Marriott Corp. DC [U] (Alt. to J. v. Ray)

Kenneth E. Bland, American Forest & Paper Assn., DC [M] (AIt. to S. W. Francis)

Warren D. Bonlsch, Schirmer Engr Corp. TX [SE] (Alt. to C. F. Baldassarra)

Lawrence Brown, Nat'i Assn. Of Home Builders (NAHB), DC {im} (Alt. to R. M. Brave)


Russell P. Fleming, Nat'l Fire Sprinkler Assn., NY [M] (Air. to K. E. Isman)

Greg Gottlieb, Hauppauge Fire District, NY [C] (AlL to J. M. Jardin)

Robert Howe, Vermont Dept. of Labor & Industry, VT [E] (Air. to H. L. Bradley)

Robert J. James, MountainStar Enterprises, Ltd., MN [SE] (Alt. to M. A. O'Hara)

Roaald H. Kirby, Simplex Time Recorder Co., MAt [M] (Alt. to E. A. LaValle)

Mark louver, Portland Cement Assn., CA [M] (AIt. to J. J. Messersmith)

Alfred J. Longhltano, Gage-Babcock & Assoc. Inc., NY [SE] (Alt. to V. E. Sharra)

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances producing similar consequences, and on the emergency movement of people, in hotels, dormitories, apartments, lodging and rooming houses, and one- and two-family dwellings.

These lists represent the me~ership at the time each Coramittee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book.

This portion of the Report of the Committee on Safety to Life is presented for adoption in 2 parts.

This Report was prepared by the: * Technical Correlating Committee on Safety to Life (SAF-

AAC), • Technical Committee on Assembly Occupancies and

Membrane Structures (SAF-AXM), • Technical Committee on Board and Care Facilities (SAF-

BCF), • Technical Committee on Building Service and Fire Protection

Equipment (SAF-BSF), • Technical Committee on Detention and Correctional

Occupancies (SAF-DET), • Technical Committee on Educational and Day-Care

Occupancies (SAF-END), • Technical Committee on Fire Protection Features (SAF-FIR), • Technical Committee on Fundamentals (SAF-FUN), • Technical Committee on Furnishings and Contents (SAF-

FUR), • Technical Committee on Health Care Occupancies (SAF-

HEAL • Technical Committee on Industrial, Storage and

Miscellaneous Occupancies (SAF-IND), • Technical Committee on Means of Egress (SAF-MEA), • Technical Committee on Mercantile and Business

Occupancies (SAF-MER), and • Technical Committee on Residential Occupancies (SAF-RES).

Part I of this Report on Comments was prepared by the Technical Committee on Safety to Life, and documents its action on the comments received on its Report on Proposals on NFPA I01 e, Life Safety Code, 1997 edition, as published in the Report on Proposals for the 1999 November Meeting.

Part I of this Report on Comments has been submitted to letter ballot of the apphcable Life Safety Technical Committees. The results of the balloting, after circulation of any negative votes, can be found in the report.

Part I of this Report on Comments has also been submitted to letter ballot of the Technical Correlating Committee on Safety to Life, which consists of 16 voting members; of whom 14 voted

69

N F P A 101 - - F 9 9 R O C

affirmatively and 2 ballots were not returned (Thonnings and Woordward).

Part II of this Report on Comments was prepared by the Technical Committee on Assembly Occupancies and Membrane Structures, and documents its action on the comments received on its Report on Proposals on NFPA 102, Standard for Grandstands, Folding and Telescopic Seating, Tents, and Membrane Structures, 1995 edition, as published in the Report on Proposals for the 1999 November Meeting.

Part II of this Report on Comments has been submitted to letter ballot of the Technical Committee on Assembly Occupancies and Membrane Structures, which consists of 23 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report.

Part II of this Report on Comments has also been submitted to letter ballot of the Technical Correlating Committee on Safety to Life, which consists of 16 voting members; of whom 14 voted affirmatively and 2 ballots were not returned (Thonnings and Woordward).

PART I

(Log #1) Committee: SAF-FUN

101- 1 - (Entire Document): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed to show that Chapters 20 and 21 will not be reserved, but rather will address New Ambulatory Health Care Occul~ancies and Existing Ambulatory Health Care Occupancies, respectively. This is for correlation with the action on Comment 101-343 (Log #336). SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUN reconsider its action so as to accommodate the request from SAF-FUR via Proposal 101-274 that Sections 6-5 and 6-6 become a new chapter. The suggestion offered is that Chapter 8 becomes Interior Finish, Contents and Furnishings; and Chapter 9 becomes Special Structures and High-Rise Buildings.

Further, SAF-AAC suggests that additional chapter numbers be reserved prior to the occupancy chapters (e.g., reserve a minimum of 2 chapters, and number new assembly occupancies as Chapter 14). NFPA is developing a new manual of style that might dictate that only a fixed list of topics is permitted to be addressed in Chapter 1 - Administration. Other general topics might need to be split away and moved to a new Chapter 2 - General. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Principle.

Reorganize the Life Safety Code chapters as follows: Chapter 1 Administration (includes Tide, Scope, Purpose,

Application, Equivalency, Units) Chapter 2 Mandatory References Chapter $ Definitions Chapter 4 General (includes Goals, Objectives, Assumptions, Life

Safety Design Options, Fundamental Requirements, General Requirements, Fire Drills)

Chapter 5 Performance-Based Design Chapter 6 Classification of Occupancy and Hazard of Contents Chapter 7 Means of Egress Chapter 8 Features of Fire Protection Chapter 9 Building Service and Fire Protection Equipment Chapter 10 Interior Finish, Contents, and Furnishings Chapter 11 Special Structures and High-Rise Buildings (formerly

Chapter 32) Chapter 12 New Assembly Occupancies Chapter 13 Existing Assembly Occupandes Chapter 14 New Educational Occupancies Chapter 15 Existing Educational Occupancies Chapter 16 New Day-Care Occupancies Chapter 17 Existing Day-Care Occupancies Chapter 18 New Health Care Occupancies Chapter 19 Existing Health Care Occupancies Chapter 20 (Reserved-potential for splitting New Ambulatory

Health Care Occupancies away from Chapter 18) Chapter 21 (Reserved-potential for splitting Existing Ambulatory

Health Care Occupancies away from Chapter 19) Chapter 22 New Detention and Correcuonal Occupancies Chapter 23 Existing Detention and Correctional Occupancies Chapter 24 One- and Two-Family Dwellings Chapter 25 (Reserved-potential for addressing existing dwellings) Chapter 26 Lodging or Rooming Houses Chapter 27 (Reserved-potential for addressing existing

lodging/rooming houses) Chapter 28 New Hotels and Dormitories Chapter 29 Existing Hotels and Dormitories Chapter 30 New Apartment Buildings Chapter 31 Existing Apartment Buildings Chapter 32 New Residential Board and Care Occupancies Chapter 33 Existing Residential Board and Care Occupancies Chapter 34 (Reserved-for future use; maybe another residential-

type occupancysuch as new assisted living) Chapter 35 (Reserved-for future use; maybe another residential-

type occupancy such as existing assisted living) Chapter 36 New Mercantile Occupancies Chapter 37 Existing Mercantile Occupancies Chapter 38 New Business Occupancies Chapter 39 Existing Business Occupancies Chapter 40 Industrial Occupancies Chapter 41 (Reserved-potential for addressing existing industrial) Chapter 42 Storage Occupancies Annex A Explanatory Material Annex B Non-mandatory References

7O

N F P A 101 - - F9 9 R O C

COMMITTEE STATEMENT: The action addresses each of the concerns expressed by the TCC on Safety to Life. The subject matter assigned to Chapters 1 through 4, and the use of "Annexes" in place of "Appendices", meets the guidelines of the new NFPA style manual. NUMBER OF COMMrFFEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 11 NEGATIVE: 1

EXPLANATION OF NEGATIVE: GALLAGHER: It is still difficult to locate subject areas within

this large chapter organization. My proposal, which is the supplemental material on file with 101-4 (Log #400) that was not printed (not the printed text of either 101-$ (Log #$98) nor 101-4 (Log #400) is to break this large chapter organizational structure into four parts. Parts A--Code Principles, Chapters 1-5; Part B-- Basic Life Safety Requirements, Chapters 6-11; Part C--Occupancy Chapters, Chapters 12-41; Part D---Supplemental, Chapters 42and Appendix A and B. This new chapter organization is much easier to locate the subject chapters and gain a knowledge of how the chapters tie together. My reorganization within my Part C is (on file and not the text printed in 101-3 (Log #398) is also easier to follow with one consistent organization of all the occupancies that is similar in organization with the building code's organization of the same occupancies.


101- 2 - (Entire Document): Hold SUBMITTER: Peter W. Szerlag, Arlington, MA COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: I do not know where these two items might fit into NFPA 101. [Note: This comment has been assigned to SAF-FUN, SAF-FIR, SAF-BSF and SAF-IND.]

1. Every door shall have knockout panels at the bottom to allow a fire hose to be run through the door while retaining the fire control and smoke control attributes/capabilities of the door.

2. Every high rise building shall have smoke exhaust equipment on every floor (above the seventh floor) which can be remotely activated by the fire deparunent via radio remote control. SUBSTANTIATION: Item 1 - self evident

Item 2 - This item mirrors the recent FAA allowance of fire detection and fire suppression systems on planes which are interconnected via spread spectrum radio links. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The recommendation introduces material that has not had public review. AS such, it must be held

~l~ cessing during the next revision cycle. ER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 12

(Log #$98) Committee: SAF-FU N

101- $ - (Entire Document): Reject SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: Reorder Part B Occupancy Chapters as follows:

Residential Health Care Educational Business Mercantile Industrial Storage

Chapter 6 One and Two Family Chapter 7 Reserved Chapter 8 New Apt Chapter 9 Exist Apt Chapter 10 and 11 Hotels

SUBSTANTIATION: This will align life safety in an order more closely to the model codes for their use in their adoption. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: NFPA 101 is a stand alone document that will not be adopted, in total, by the model codes. NFPA 101B, Egress Code, is offered by NFPA as a substitute for Chapter 10 of the model codes. The submitter should note, however, that per the action on Comment 101-1 (Log #1) the residential occupancy chapters are being resequenced so as to begin with dwellings and build in size. NUMBER OF COMMrlq'EE MEMBERS ELIGIBLE TO VOTE: 12

VOTE ON COMMITrEE ACTION: AFFIRMATIVE: 11 NEGATIVE: 1

EXPLANATION OF NEGATIVE: GALLAGHER: See my Explanation of Negative on Comment to

101-1 (Log #1). It is the supplemental material on file that is of importance, not this printed text.


101- 4 - (Entire Document): Reject SUBMN~I'ER: Gregory W. Gailagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: Reorder chapters as follows into 8 categories:

Part A - Code Part B - Occupancy Part C - System (building requirements) (How to fulfill requirements)

1 General 2 Fundamental $ Performance Option (see separate comment) 4 Reserved 5 Classification of Occupancy and Hazard of Contents

Means of Egress Features of Fire protection

Building Service and FP Equil?ment Special Structure and High Rise

SUBSTANTIATION: This will align the life safety code more closely to traditional building organization. Also your thinking will be consistent from macroscolpic to microscopic contents in the ordering of the chapters. This will assist Life Safety Code as more easily adopted into the model code process.

Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See the Committee Statement for the rejection of Comment 101-$ (Log #$98). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: See my Explanation of Negative on Comment to

101-1 (Log #1). It is the supplemental material on file that is of importance, not this printed text.


101- 5 - (1-2.3): Accept in Principle SUBMITI'ER: Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise text to read:

1-~.$ Other Considerations. In addition to means of e~ress, the Code L f _ ~ ~k-esse* protective features and systems, building services, ooecating features, maintenance activities and other snecial vrqvisions zc~='~cr=.'2~.=-~ ..k: t -- . . . . . . . . . . . . . . .~--:~ .^ . . . . . ~:¢̂ ~ Mc~. - ~ . I m recognition that achieving an acceptabl~ de~ree of life safety depends upon additional safetmards to provide adeouate e~ress time or nrotection for Deovleexnosed to fire "~ :..~.:: ~=.n ~.. m:.t~r

TIATION: As currently worded, the section is commentary more appropriate to the appendix. The revisions address what the other considerations are and what contribution they are intended to make to life safety. The items listed reflect the contents of the occupancy chapters and other provisions of the code. COMMITTEE ACTION: Accept in Principle.

Retain existing language and add the submitter's information so that 1-2.$ reads:

1-2.$ Other Considerations. The code addresses other considerations that are essential to life safety in recognition that life safety is more than a matter of egress. The code also addresses [~rotective features and systems, building services, operating teatures, maintenance activities and other provisions in recognition

I that . . . . . achievinmg an acceptable degree of life safety depends upon addinonal safeguards to prowde adequate egress ume or protecuon

if or people exposed to fire.

71

N F P A 101 - - F 9 9 R O C

COMMITTEE STATEMENT: The existing language is necessary and thus is being retained. The concept addressed by the submitter is being added. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 6 - (1-2.4(a)): Accept in Part SUBMITTER: Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-5 RECOMMENDATION: Add new appendix A-1-2.4(a) as follows:

A-1-2.4(a~ This code is intended to be adonted and used as oart of a comnrehensive vrogram that includes building, mechanical. plumbing, electrical, fuel ~,as. fire prevention and land use ret, ulations enforced to mitigate the freauencv or conseuuences of

v

~i~g¢l~. deaths, iniuries, illnesses and economic and social disruotions resulting from natural, technological and h,lman- c~Wu sed hazards. SUBSTANTIATION: Too many users fail to recognize the complimentary role the code is intended to fulfill when adopted and enforced in conjunction with other regulations. _T)oe proposed text underscores recognition that life safety is only of ~fiany goals fulfilled through apphcafion of the police power, and emphasizes the need to adopt and enforce companion codes. COMMITTEE ACTION: Accept in Part.

Add a new appendix A-1-2.4(a) to read: A-1-2.4(a) This code is intended to be adopted and used as part

of a comprehensive program of building regulations that include building, mechanical, plumbing, electrical, fuel gas, fire prevenuon, and land use regulations. COMMITTEE STATEMENT: The Committee Action adopts most of the material offered by the submitter. The wording that was not accepted is no t appropriate. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 7 - (1-5 (New)): Accept in Principle SUBMITIT, R: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-5 RECOMMENDATION: Add a new Appendix A-1-5 as follows:

A-1-5 The goals in this section reflect the scope of this Code (see Section 1-2). Other goals that are outside the scope of this Code may also need to be considered; however, compliance with this Code may assist in meeting goals outside of this Code's scope. SUBSTANTIATION: It is also important to highlight that there may be goals outside of the scope of NFPA 101 that may need to be addressed by the design team. I f so, the design team may need to turn to building codes or develop supplemental goals to those stated in this section. COMMITTEE ACTION: Accept in Principle.

Add a new Appendix A-l-5 as follows: A-l-5 The goals in this section reflect the scope of this Code (see

Section 1-2). Other fire safety goals that are outside the scope of this Code may also need to be considered such as property protection and continuity of operations. Compliance with this Code may assist in meeting goals outside of this Code's scope. COMMrFrEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #301) Committee: SAF-FU N

101- 8- (1-5.1): Reject SUBMITI'ER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Delete ~and injury" so text will read:

"The goal of this Code is to provide an environment reasonably safe from death a=d "aju.%. in fire and similar emergency by ..."

SUBSTANTIATION: Since when did the UFE Safety Code take the leap to protect occupants from injury? This is an important change which will complicate everything unnecessarily. All the 1997 .Code purpose and objective language statements do not menuon m3ury. COMMITTEE ACTION: Reject. COMM1TI'EE STATEMENT: See current 1997 edition paragraph 1-2.1 which addresses "life safety from fire". It is the committee s belief that life safety from fire is more than just protection from death. Also see current 2-1 which addresses "a reasonable degree of safet3?' and 2-2 which addresses "lives and safety of occupants." NUMBER OF COMMrlTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12 COMMENT ON AFFIRMATIVE:

LATHROP: The Committee Statement should refer commenter to Comment 101-10 (Log #CC1) (1-5.1) since this partially addresses the problem.


101- 9- (1-5.1): Reject SUBMITTER: Gregor,/W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Delete "and injury". SUBSTANTIATION: Injury could be considered smoke inhalation, exhaustion, logical, etc. with all the personal injury lawyers. This would be near impossible in some situations. No where else does the code mention "injury ~. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comments 101-8 (Log #301) and 101-10 (Log #CC1). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #CC1) Committee: SAF-FUN

101- 10 - (1-5.1): Accept SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-$ RECOMMENDATION: Revise 1-5.1 to read:

"1-5.1" Fire and Similar Emergency. The goal of this code is to provide an environment for the occupants tha t is reasonably safe from fire and similar emergencies by. .f[continue with subparts (a) and (b)]. SUBSTANTIATION: The revised wording better explains intent. COMMrI ' rEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 11 - (1-5.1(a)): Reject SOBMrITERa Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise text of appendix A-1-5.1 (a) to read:

A-1-5.1(a) The phrase "intimate with the initial fire development" refers to the person(s) at the ignition source and not all persons within the same room or area. Individuals intimat~ with a fire often cause the imaidon or contribute fuel to the develooing fire through ienltJon-of themselves, their clothln~ or bedding or furnishings in which thev are situated. SUBSTAI~ITIATION: Clarifies the relationship between individuals intimate with a fire and the ignition sources or fuels involved. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The appendix note already clarifies that not all persons in the room are intimate with the initial fire development. Also see Comment 101-12 (Log#224). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

72

N F P A 101 ~ F 9 9 R O C


101- 12- (1-5.1(a)): Accept SUBMITrER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-3

I RECOMMENDATION: Revise appendix A-1-5.1(a) as follows: "The phrase "intimate with the initial fire development" refers to

the person(s) at the ignition source or first materials burning and not to all persons within the same room or area." SUBSTANTIATION: This change presumably reflects the true intent of the committee. The hazed of concern is persons in contact with the first materials burning, not necessarily the ignition source itself. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 13 - (1-5.1(b)): Accept SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-3

I RECOMMENDATION: Delete proposed appendix A-1-5.1 (b). SUBSTANTIATION: The statement is incorrect. Consideration of the person intimate with ignition was specifically taken into account during the development of the prescriptive requirements currently in the Code.

If we remove the person intimate with ignition from consideration, we risk unacceptable building design. For buildings with many small rooms designed for single occupants (such as SRO home/hotels) the argument could be made that no fire protection (detection or suppression) is necessary in the rooms because the room is so small that the person is likely to be intimate with ignition and the Code allows us to ignore that person when deciding on appropriate measures of protection.

As written, A-l-5.1 (b) lends credence to that argument. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: WOODWARD: The appendix note should remain. While the

note may not address every condition, it is an appendix note which is provided for guidance. When this note and A-1-5.1(a) are viewed together, it gives a clearer picture of the codes goals. Eliminating the appendix note may have the effect of creating an unrealistic viewpoint of what the code can and should do. Without a little explanation of what "improving the survivability of occupants intimate with the initial fire development" is about, some people may see this as a means to protect to unrealistic levels. In essence, protecting all of the people all of the time, regardless of their location or situation. COMMENT ON AFFIRMATIVE:

GALLAGHER: There is considerable disagreement on the committee with major elements of this performance option, including the basic goals and objectives of the code as stated in 101-13 (Log #235) and 101-15 (Log #300). This is another indication that the performance option is just no ready for adoption at this time. Rather it should be further developed for adoption at the next revision cycle, not the current one. This will give more time to think through the major unresolved issues. With these two discussions about the fundamental intention of a design, it would seem to me that the authority having jurisdiction and designer would not get through their first meeting with an agreement of understanding on how the performance design intends to meet the goals and objectives of the code. These subtleties in the "word-smithing" could have tremendous implications in the design and its approval.


101- 14 - (1-5.2): Accept in Principle SUBMITTER: Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise text to read:

1-5.2 Crowd Movement. A goal is to provide for reasonably safe emergency a=~ :~ncmcrgc :~ / crowd movement where applicable.

SUBSTANTIATION: Like property conservation, safe nonemer[gency crowd movement seems to be a side-effect rather than outright goal of the code. The technical committees of the Safety to Life Project have previously rejected proposals to include provisions in the Life Safety Code® when the benefit of these requirements was primarily perceived prevent injuries during nonemergency use of means of egress and pedestrian features of buildings. Unless these committees erred or the philosophy of the code has changed, this goal should not appear in the code. ff the philosophy of the code has in fact changed, please identify provisions of the code primarily intended to facilitate safe movement of people in nonemergency situations. COMMITTEE ACTION: Accept in Principle.

Revise 1-5.2 to read: 1-5.2 Crowd Movement. A goal is to provide for reasonably safe

emergency crowd movement and, where required, reasonably safe non-emergency crowd movement. COMMITTEE STATEMENT: The rewording further clarifies intent. It should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #$00) Committee: SAF-FUN

I01- 15 - (1-6.1): Reject SUBMITTER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise 1-6.1 as follows:

1-6.1 Occupant Protection. A structure shall be designed, constructed, and maintained to protect the occupants not intimate with initial fire development ~ for ::t'.c ~ m z : . z z~z~ t~.

SUBSTANTIATION: The Code objective must be quantifiable - especially when one would choose the performance option. The word "protect" standing alone is too subjective. Any of many options are available to protect from loss of life so listing a few is inappropriate. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Loss of life is not the only objective. See Committee Statement associated with the rejection of

- Comment 101-8 (Log #301). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


GALLAGHER: There is considerable disagreement on the committee with major elements of this performance option, including the basic goals and objectives of the code as stated in 101-13 (Log #235) and 101-15 (Log #300). This is another indication that the performance option is just no ready for

"- adoption at this time. Rather it should be further developed for adoption at the next revision cycle, not the current one. This will give more time to think through the major unresolved issues. With these two discussions about the fundamental intention of a design, it would seem to me that the authority having jurisdiction and designer would not get through their first meeting with an agreement of understanding on how the performance design intends to meet the goals and objectives of the code. These subtleties in the "word-smithing" could have tremendous implications in the design and its approval.


101- 16 - (1-6.1): Reject SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Add "from loss of life". SUBSTANTIATION: All objectives, must be measurable and define to what degree. Protect the occupants is from loss of life, not from any injury that could occur. This later point is near impossible, in fire or emergency conditions. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 101-15 (Log#300). NUMBER OF COMMYIq'EE MEMBERS ELIGIBLE TOVOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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101- 17 - (1-6.1 and 1-6.2): Reject SUBMITITJ~ MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-$ RECOMMENDATION: Revise text:

1-6.10ccupantProtect ion. A= Structures shall be designed, constructed and maintained to protect the occupants not intimate with the initial fire development for the time oredJcted to be needed to evacuate, relocate, or defend in place.

1-6.2 Structural Integrity. Structural integrity shall be maintained for the time oeriod reasonably oredicted to be needed to evacuate, relocate, or defend in place the occupants not intimate with the initial fire development. SUBSTANTIATION: One will not know the actual time required for evacuation or relocation until after a fire event. The best one can do is reasonablypredict the time required. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The objective is correctly stated. How one determines what the "needed time" is doesn't need to be stated here. The submitter's wording "reasonably predicted" is not quantifiable. It would confuse the prescriptive-based use of this objective. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: WOODWARD: While the phrase "period reasonably predicted to

be" may not be quantifiable, it does provide a vagueness which can keep the objectives realisti~ Without th~ vagueness, it will be easy to measure how you met the objectives. If a person remote to the initial development is affected, you have failed. Unfortunately, that could even be if the failure was 5 hours after the initial development. The problems at the World Trade Center and the time lines to evacuate and remove people might be viewed as having failed to meet these objectives as they are currently written. However, perhaps any failure was due to circumstances beyond what is "reasonably predicted."


101- 19 - (1-6.$): Accept in Principle SUBMrrrERa Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Add "reliable" to read:

"Systems utilized to achieve the goals shall be effective, maintained and operational.r SUBSTANTIATION: Effective pertains only to after this system is activated. Reliable means the system will be activated when it is called upon. COMMITTEE ACTION: Accept in Principle.

See Comment 101-18 (Log #175). COMMITTEE STATEMENT: The action on the referenced comment should meet ' the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMI3q'EE ACTION:

AFFIRMATIVE: 12

(Log #2) Committee: SAF-AX M

101- 20 - (1-7): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize (where appropriate) on the use of the term "emergency egress and relocation drills." SUBSTANTIATION: See the above recommendation. COMM1TrEE ACTION: Accept in Principle.

No further change needed. COMbflTFEE STATEMENT: The subject is addressed in Chapters 8 and 9 in 8-7.7 and 9-7.7. The current use of the word "drills" does not conflict. As such, no further changes are needed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 21 NOT RETURNED: 2 Cich, Conner


101- 18 - (1-6.$): Accept in Principle SUBM1TrER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise text:

"Systems Effectiveness. Systems utilized to achieve the goals of Section 1-5 shall be effective in mitigating the hazard 9r ~gnditi0t3 for which they are bein~ used. shall have a high de~ree of reliability, shall be main-tained to the level ~;which-they were desigmed to operate, and shall remain operational throughout the life of the buildin~ or structure." SUBSTANTIATION: The new text is necessary to better define "effective," to introduce reliability, and to ensure maintenance at the level of intended operation. The new text is consistent with 1-11.13 of Proposal 101-$. COMMITTEE ACTION: Accept in Principle.

Revise 1-6.3 to read: 1-6.$ Systems Effectiveness. Systems utilized to achieve the goals

of Section 1-5, shall be effective in mitigating the hazard or condition for which they are being used, shall be reliable, shall be maintained to the level at which they were designed to operate, and shall remain operational. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. The wording "throughout the life of the building or structure" was not added because it could confuse the issue when conditions change witlfin a building. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #2a) Committee: SAF-BCF

101- 21 - (1-7): Accept in Principle SUBMYIq'ER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize .(where appropriate) on the use of the term "emergency egress and relocation drills." SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise both 22-7.3 and 23-7.3 as follows: "Emergency Egress and Relocation Drills. ~ .

Emergency egress and relocation drills F'rc zx't d~-!!~ shall be conducted at least six times per year on a bimonthly basis with a minimum of two drills conducted during the night when residents are sleeping. The drills shall be p.ermitte d to be announced in advance to the residents. The drills shall involve the actual evacuation of all residents to an assembly point as specified in the emergency plan and shall provide residents with experience in egressing through -all exits and means of escape required by the Code. Exits and means of escape not used in any fire drill shall not be credited in meeting the requirements of this Code for board and care facilities."

Exceptions 1 and 2 remain the same. COMMITTEE STATEMENT: Addresses the correlation issues in these chapters. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16

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(Log #2b) Committee: SAF-DET

101- 22 - (1-7): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize (where appropriate) on the use Of the term "emergency egress and relocation drills." SUBSTANTIATION: See the above recommendation. COMMITFEE ACTION: Accept in Principle.

I In the title of 14-7.1 and 15-7.1 delete the word "Exit" from the term "Fire Exit Drills" so that it reads:

14-7.1 Attendants, Evacuation Plan, Fire Drills. 15-7.1 Attendants, Evacuation Plan, Fire Drills.

COMMITTEE STATEMENT: Chapter 1 is being revised to use the term "fire drills" in the title of Secuon 1-7; and use the term "emergency egress and relocation drills" within the text of paragraphs. The above change is consistent with this. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 20 VOTE ON COMMI'IqTEE ACTION:

AFFIRMATIVE: 19 NOT RETURNED: 1 Barbaro

(Log #2e) Committee: SAF-IND

101- 25 - (1-7): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize (where appropriate) on the use of the term "emergency egress and relocation drills3 SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

Revise 28-2.2.11 by adding "emergency egress" before drills so that it reads:

28-2.2.11 Slide Escapes. Approved slide escapes complying with 5-2.10 shall be permitted as components in 100 percent of the required means of egress for both new and existing high hazard industrial occupancies. Slide escapes shall be counted as means of egress only where regularly used in emergency egress drills so that occupants are familiar with their use through practice. COMMITTEE STATEMFaNT: This revision is made to reflect the recent revisions done to section 1-12 (old 1-7). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 11 NOT RETURNED: 1 Holmes

(Log #2c) Committee: SAF-END

101- 23 - (1-7): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize (where appropriate) on the use of the term "emergency egress and relocation drills." SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

In the ROP, see Proposals 101-396, 101-867, and 10-872. COMMITTEE STATEMENT: The correlated action requested has already been accomplished. No further changes are needed. This should meet the submitter's in tent NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14 NOT RETURNED: 1 Ewing

(Log #2d) Committee: SAF-HEA

101- 24 - (1-7): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize (where appropriate) on the use of the term "emergency egress and relocation drills." SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ In 12-7.1.2, 15-7.1.2, A-12-7.1.2the first sentence, and A-15-7.1.2 [ the fn'st sentence, change the words "fire exit drills" to "fire drills".

COMMITTEE STATEMENT: The Committee Action on Proposal 101-457 in the ROP does most of what was requested by the Technical Correlatin6 Committee. The above action completes the changes needed. Thin should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 17 NOT RETURNED: 1 Crowley

(Log Committee: SAF-MER

101- 26 - (1-7): Accept in Principle [ TCC NOTE: The Technical Correlating Committee on Safety to [ Life (SAF-AAC) directs that the action on this comment be revised ] so that in 24-4.5.6 and 25-4.5.6 the words ~emergency egress or [ relocation ~ be changed to ~emergency egress and relocation. ~ [ This is done for correlation purposes as explained in the J explanation of negative vote received from Mr. Francis.

SUBMITI'ER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize (where appropriate) on the use of the term "emergency egress and relocation drills." SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise the following paragraphs so that they read: 24-7.1 Drills. In every Class A or Class B mercantile occupancy,

t e l l1 A employees shall be periodically trained in ~:re ex'. _rL. ~rece2ure: "n c==-£~,m==cc accordance with Section 1-12.

25-7.1 Drills. In every Class A or Class B mercantile occupancy, employees shall be periodically trained in .q=z cx't d-2! ~r=zcd=rz- ! : c~:ff~.rmm=cc accordance with Section 1-12.

24-4.5.6 Emergency Plan and Employee Training. There shall be in effect an approved written plan for the ¢:"~c'.:a~n emergency e~ress or relocation of occupants. All employees shall be instructed and periodically drilled with respect to their duties under theplan.

25-4.5.6 Emergency Plan and Employee Training. There shall be in effect an approved written plan for the :vaz::a~.n emergencv egres~ or relocation of occupants. All employees shall be instructed and periodically drilled with respect to their duties under the plan.

26-7.1 Drills. In any business occupancy building occupied by more than 500 persons or more than 100 persons above or below the street level, employees and supervisory personnel shall be periodically instructed . . . . . . . . . . . . . . . r . . . . . . . . . m accordance with Section 1-12 and shall hold drills periodically where practicable.

27-7.1 Drills. In any business occupancy building occupied by more than 500 persons or more than 100 persons above or below the street level, employees and supervisory personnel shall be periodically instructed . . . . . . . . . . . . r . . . . . . . . . In accordance with Section 1-12 and shall hold drills periodically where practicable. COMMITrEE STATEMENT: The revisions to these sections are in response to the activity of Proposal 101-9 where the terms "emergency egress and relocation drills ~ have been added to the proposed revision to Section 1-12 (current 1-7). The revisions to

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24-7.1, 25-7.1, 26-2.1 and 27-2.1 is to provide a direct to Section 1-12. The revision to 24-4.5.6 and 25-4.5.6 was done to incorporate the current language as noted in Section 1-12. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COI~IMrI'I~E ACTION:

AFFIRMATIVE: 16 NEGATIVE: 1 NOT RETURNED: 2 Holmes, Moon

EXPLANATION OF NEGATIVE: FRANCIS: The section as structured in the comment does NOT

accomplish the TCC's desire to correlate the issue in the occupancy chapters. The use of the word or in the committee's action renders the section different from its original form arm different from the TCC's guidance.

"Relocation" is an element of a subset of the set "Egress". In other words, exiting the building is relocating from a given point in the building to the public way outside the building. Relocation, as a subset implies leaving a given point upon notification of a hazard or awareness to it and moving to a point acceptable for that situation. Although it is primarily a feature of the defend inplace approach to fires, it is not mutually exclusive with "egress". The use of the word "and" in no way invalidates the concept. Nor does it compel the user to consider ONLY a relocation exercise. I believe that correlation mandates the wording as [~roposed originally. Thus, the expression will be used consistently throughout the document and will be understood by users to mean the set of possible solutions ranging from relocation where it is permitted within an occupancy chapter such as health care, to traditional exiting where "defend in place" is not an option. Users are smart enough to figure out when an occupancy chapter permits a subset. But they will always see the notion in a single expression and will not try to read anything into the subde differences introduced by saying "egress OR relocation ~ in one chapter compared to "egress and relocation" in all other chapters.

(Log #2g) Committee: SAF-RES

101- 27 - (1-7): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM, SAF-BCF, SAF- DET, SAF-END, SAF-HEA, SAF-IND, SAF-MER and SAF-RES review their chapters' terminology and make revisions so as to standardize (where appropriate) on the use of the term "emergency egress and relocation drills." SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

I Revise 16-7.3.1 and 17-7.3.1 as follows: I Drills. Emergency egress and relocation ~ drills shall be ] regularly conducted in accordance with Section 1-7.

COMMITTEE STATEMENT: Consistency of terms with Chapter 1. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 22 NOT RETURNED: 2 Kelly, Oneisom


101- 29 - (1-7.1): Reject SLIBMITTER: Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise text to read:

SECTION 1-7 .A¢.S~SU.~PTION CONDITIONS 1-7.1" Single Fire Source. The protection methods prescribed by

Chanter 4 through 41 are conditioned uoon the assumntion that the fire is from a single fire source that does not obstruct more than one hath of travel.

1-7.2 Other Situations. Performance-based desitrns develoned in accordance with Chanter 3 are conditioned unon the snecifi-c fire scenarios nresented in Section 3-5.

~JBS'T'A~T~I()~N".'~"~I%e I~'ffe~afetys~Tategiesptres'cr'i~d by the code's provisions not only assume that the fire is limited to a single source; their success depends upon this condition. Brannigan has noted the important distinction between the different types of assumptions used in fire regulation and modeling. For clarity of intent, and to underscore the important limitations of this assumption, the title should be revised to reflect that this assumption is a condition not an estimate. Multiple fires can and do occur, as do very large fires that block more than one path of travel. Although the "single source" assumption applies to both the prescriptive and performance-based design options, it should be acknowledged in the administrative provisions that the Code requires consideration of multiple single source scenarios in performance-based design. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The word "assumptions" better explains intent and agrees with the NFPA primer on the subject. The chapters don't need to be spelled out, so subdivision is not needed. A reference to performance based designs should not be mentioned here; it would appear too early in the code and confuse the user. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 30 - (1-7.1): Accept SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Add "of this code" to read:

"The protection methods of this code assume a single fire source." SUBSTANTIATION: This is so as to confused this section from applyin 6 to the assumptions behind the engineering method, calculataons, equations, models, etc. used in the analyses. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12


101- 28 - (1-7): Accept in Principle SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise tide to read:

"Code Assumptions" SUBSTANTIATION: This is not to confuse this section from applyin~ to the assumptions behind the engineering methods, calcula~ons or equations, used in the analyses. (See related changes to same 1tern). COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-30 (Log #404). COMMITTEE STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 31 - (1-7.4): Accept in Principle SUBMITTER: Margaret D. Carson, Carson Assoc. Inc. COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: Add a new appendix A-1-7.4 as follows:

A-1-7.4 Prior to evaluation of performance an opportunity for instruction and practice should be provided all occupants. This educational opportunity should be presented in a non-threatening manner with consideration to prior knowledge, age and ability of audience. SUBSTANTIATION: The only opportunity for learning how to correctly evacuate a buildinl{ should not be presented as a timed test. People need opportunity to ask questions, have explanation given, and project "What W' scenarios. The instructor needs the assurance that messages are understood and the actions can be performed correctly. COMMITTEE ACTION: Accept in Principle.

Add the following appendix text at the end of the first paragraph of A-l-12:

"Prior to an evaluation of performance of an emergency egress and relocation drill, an opportunity for instruction and practice

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I should be provided. This educational opportunity should be presented in a non-threatening manner with consideration to prior knowledge, age, and ability of audience." COMMI'Iq'EE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12


101- 32 - (1-8): Accept SUBMITIXR: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise the tide of Section 1-8 to read:

Section 1-8 Life Safety Compliance Options. SUBSTANTIATION: The change further darities intent and should make the code more usable. COMMITIT, E ACTION: Accept. NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- $3 - (1-8.1, 1-8.2 (New)): Reject SUBMITI'ER: Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revised text to read:

SECTION 1-8 LIFE SAFETY ~ - D E g t G N OPTIONS 1-8.1 Options. Life safety meeting the goals and objectives of

Sections 1-5 and 1-6, shall be provided in accordance with either: (a) the prescription Frc:c-p~2vc based provisions per t-4G2-

/-8.1./. or (b) the performance-based provision per ~ - 1 - 8 . 1 . 2 . 1-8.1.1 ~ l?rescriptionPrczc-p'dve based Option. A

prescription prczc-p'.!ve based life safety design shall be in accordance with Chapters 1, 2, 4-7, the applicable occupancy chapters 8-31, 32 and 33 of this Code.

1-8.1.2 4-4G~ Performance-based Option. A performance-based life safety design shall he in accordance with Chapter 1, 2, S and 33 of this Code.

1-8.2 Operating Reouirements. Notwithstanding the ontion used. all life safety desirous shall be maintained in accordance with the conditions of the intended design annroach to demonstrate full compliance with the goals and objectives of Sections 1-5 and 1-6. Comnliance with theone ra t ion and maintenance nrovisions of this Code. including but not limited to the items listed below, shall be

v

rcq¢ired for bgth prescription-based and perforr0ance-based

(a) po~ting and enforcement of smoking regulations. (bl control of contents and furnishingsfire-hazards. (c) use of eouiDment. (dl emer~encv nlannin~ and nrenaredness. (el inspection of facilities. (t3 oualifications, sunervision and traininw of staff, and (g/ conduct of emergency egress and relocation drills.

SUBSTANTIATION: The Code is a compliance and enforcement tool, not a design manual. The tide of the section should be revised to emphasize that the Code recognizes two equally acceptable methods of demonstrating compliance with its intent. Which method is suitable for a given design is highly dependent upon the circumstances of a particular project. Since one or the other method may be entirely unsuitable to a given situation, the code should not suggest these are entirely equivalent design approaches.

Just as importantly, the design method and compliance should be separated to ensure continued adherence to the conditions and limitations of the design approach employed. Maintenance provisions must be added to verify that both prescription-based and performance-based approaches continue to satisfy the goals and objectives of the code.

Finally, performance-based design should not be considered a substitute for operating requirements intended to manage human factors that could undermine the level of safety provided by either

approach. Compliance with the operating features requirements of the Code should apply to all designs. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Operating requirements are not go Eriate to this section.

R OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: Although it may not be appropriate to this

section, a section shou ldbe developed which would include this material. The operating conditions of the building are inadequately addressed in the present Chapter $ proposal. My proposal in 101-63 (Log #393), which is contained in the material on file and not printed in the ROC, illustrates my concern that this Performance Option in Chapter S is not fully developed with adequate statements of its limitations specified in the document to be an usable and enforceable document.


101- 34- (1-9.2): Accept in Principle SUBMITTER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-$ RECOMMENDATION: Add the following at the end of A-1-9.2:

The prescriptive provisions of this code provide specific requirements for broad classifications of buildings and structures. These requirements are stated in terms of fixed values, such as maximum travel distance, minimum fire resistance ratings, and minimum features of required systems (e.g., detection, alarm, suppression, and ventilation), and not in terms of overall building or system performance.

However, the equivalency clause in 1-9.2 permits the use of alternative systems, methods, or devices to meet the intent of the

escribed code provisions where approved as being equivalent. is provides an opportunity for a performance-based design

approach. Through the rigor of a performance-based design, it can be demonstrated whether or not a building design is satisfactory and complies with the implicit or explicit intent of the applicable code requirement.

When employing the equivalency clause, it is important to clearly identify the prescriptive-based code provision being addressed (scope), to provide an interpretation of the intent of the provision (goals and objectives), to provide an alternative approach (trial design), and to provide appropriate engineering support for the suggested alternative (evaluate trial designs). The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design provides a framework for addressing these issues in a logical and consistent manner.

Trial designs can be compared to the performance of the design features required by this code with the performance resulting from the trial desi~n. Using prescribed features as a baseline for comparison, ~t can then be demonstrated in the evaluation whether or not a trial design offers the intended level of performance. A comparison of safety provided can provide the basis for establishing equivalency of performance-based designs. SUBSTANTIATION: Equivalences will continue to be sought to the prescriptive requirements of the code, without utilizing the performance-based code option in chapter S. The proposed text would expand the "equivalency" guidance, and would provide a reference to the SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design, which gives additional guidance on developing and evaluating equivalent designs. COMMI~i'EE ACTION: Accept in Principle.

Add the following at the end of A-1-9.2 (current 1997 edition A-1-6.2) :

The prescriptive provisions of this code provide specific requirements for broad classifications of buildings and structures. These requirements are stated in terms of fixed values, such as maximum travel distance, minimum fire resistance ratings, and minimum features of required systems (e.g., detection, alarm, suppression, and ventilation), and not in terms of overall building or system performance.

However, the equivalency clause in 1-9.2 permits the use of alternative systems, methods, or devices to meet the intent of the

escribed code provisions where approved as being equivalent. is provides an opportunity for a performance-based design

approach. Through the rigor of a performance-based design, it can be demonstrated whether or not a building design is

77

N F P A 101 - - F 9 9 R O C

satisfactory and complies with the implicit or explicit intent of the applicable code requirement.

When employing the equivalency clause, it is important to clearly identify the prescriptive-based code provision being addressed (scope), to provide an interpretation of the intent of the provision (goals and objectives), to provide an alternative approach (proposed design), and to provide appropriate support for the suggested alternative (evaluate proposed designs). See references cited in A-3.

Proposed designs can be compared to the performance of the design features required by this code with the performance resulting from the proposed design. Using prescribed features as a baseline for comparison, it can then be demonstrated in the evaluation whether or not a proposed design offers the intended level of performance. A comparison of safety provided can provide the basis for establishing equivalency. COMMYITEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITIT.E MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 35 - (1-10.2): Reject SUBMITrER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-10 and 101-3 RECOMMENDATION: Delete entire text of 1-10.2 S~9¢ropriateness of Safeguards".

STANTIATION: This paragraph adds no meaningful discussion or information not otherwise covered in 1-10 a n d / o r rest of the Code. This Section 1-10 should precisely outline fundamental requirements as a form of redundancy - especially redundant requirements which will be needed and might be necessary for the performance-based option. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The text that the submitter proposes be deleted does add a meaningful general requirement that the authority having jurisdiction can enforce to get an.appropriate group of safeguards. It is important to retain this. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #230) . Committee: SAF-FUN

101- 36- (1-10.4): Accept SUBMITTER= Philip R.Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: In the appendix A-l-10.4 remove EXIT from the term Fire Exit Drills. SUBSTANTIATION: Editorial; to be consistent with the new change in terminology. COMMITTEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVF: 12


101- 37- (1-10.4): Reject SUBMITI'ER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-10 RECOMMENDATION: Delete proposed 1-10.4 and A-1-10.4. SUBSTANTIATION: This section and appendix note were not part of my original submission because it is not needed as a fundamental requirement. Section 1-10.6 does address the fundamental requirement that any system installed must be installed correctly. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The general provisions of Section 1-10 need to address alarms/occul3ant notification. Otherwise, the section would be silent on the subject of size or arrangement of buildings dictating a need for alarms. The submitter has not provided adequate substantiation to delete the material.

NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 38- (1-10.4): Accept in Principle SUBMITrER= GregoryW. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-$ RECOMMENDATION: Add to appendix A-l-10.4 the following: "and emergency response services to assist occupants. Fire alarms

alert occupants to imtiate emergency procedures, facilitates the orderly conduct of fire exit drills and initiate emergency services to respond to assist the needs of occupants." SUBSTANTIATION: Fire alarms initiate emergency services to respond also. This is just as important as alerting the occupants. COMMYIq'F~ ACTION: Accept in Principle.

Add to appendix A-1-10.4 the following:. "l~re alarms alert occupants to initiate emergency procedures,

facilitate the orderly conduct of fire drills, andin i t ia te response by emergency services." COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- $9 - (1-10.4): Reject SUBMITTER: GregoryW. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Delete the introductory danse:

Fire alarm facilities shall be provided where necessary to warn occupants of the existence of fire." SUBSTANTIATION: This clause weakens the statement. The remaining sentence includes the possibility of not having to put in an alarm system. COMMITI'EE ACTION: Reject. COMMITTEE STATEMENT: The wording proposed to be deleted b VuMthe submitter helps to explain the concept.

BER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 40 - (1-10.4): Accept SUBMITIT_~ Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-10

I RECOMMENDATION: Change the title of proposed 1-10.4 from "Alarm Systems ~ to "Occupant Notification ~. SUBSTANTIATION: The change in title better explains the

rovisions of the paragraph. OMMITrEE ACTION: Accept.


AFFIRMATIVE: 12


101- 41 - (1-11): Reject SUBMITrER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: Move 7-7.6 Sprinklers and 7-6.1.8 Fire Alarms to 1-11 General. SUBSTANTIATION: Currently performance design can not reach any of the prescriptiveprovisinns. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The subject introduced by the submitter is one of reliability. As such, it is better addressed under the reliability secdon. If, at a later date, it is determined that

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N F P A q 0 1 - - F 9 9 R O C

similar wording is needed, it should be placed within the retained prescriptive provisions of 3-$.1. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHEP~ Reliability needs to be addressed adequately now

in the code, not at a later date, for this Chapter $ Performance Option to be an usable and enforceable document. Reliability is one means of specifying the limitations of a design under this new performance system. COMMENT ON AFFIRMATIVE:

WOODWARD: Although rejected, this proposal raises an issue which should be further reviewed. The concept behind this proposal should be looked at and brought into Chapter $. This would provide a method for operational issues to be covered within the performance section.


101- 42 - (1-11.1.1): Accept SUBMITrER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-3

I RECOMMENDATION: Replace existing 1-11.1.1 with the following:

1-11.1.1 The authority having jurisdiction mall determine whether the provisions of this Code are met. SUBSTANTIATION: Proposed 1-11.1.1 in the ROP incorrectly mentions performance objectives which have application only to performance-based designs. Also, the revision corrects current language that seems to single out the means of egress rather than the overall provisions of the Code. As such, the revision is an improvement. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:


GALLAGHER: I would like to add to the substantiation and stress that this provision does not allow the design team to just satisfy only one level of the code from amongst the goals, objectives, criteria, or scenarios. The design team must satisfy at a minimum every applicable provision, which includes all the goals, objectives, criteria, and scenarios of this Code as determined by the authority having jurisdiction. The design can always specify more than the code, see 1-$.1, 1-10.1, 1-11.9. Since these sections to specify more than the code are all from Chapter 1, they apply to both the existing prescriptive provisions and the new performance provisions.


101- 43 - (1-11.1.2): Accept in Principle SUBMITTER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-$ RECOMMENDATION: Add a sentence to 1-11.1.2, this sentence comes from my proposed rewrite to old Chapter 2.

"Also. no orovisions of the Code shall be construed as reouirin~ or nermitting any condition that might be hazardous under norma~ occuDancv conditions." SUBSTANTIATION: This sentence is taken from the old Chapter 2, Section 2-10 and is intended to allow the authority having jurisdiction specifically to not apply an item of the Code where that application would be detrimental to life safety. For example: installing an exit sign where head room is not adequate. COMMITTEE ACTION: Accept in Principle.

Insert a new 1-11.1.$ to read: 1-11.1.$ Any requirement shall be permitted to be modified if its

application would be hazardous under normal occupancy condition in the judgment of the authority having jurisdiction where it is evident that a reasonable degree of safety is provided. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 44- (1-11.3): Reject SUBMFFTER: Mark Chubb, Incendiis Consultants C O ~ T ON PROPOSAL NO: 101-$ RECOMMENDATION: Revise text to read:

1-11.3 Historic Buildings. The provisions of this Code shall be permitted to be modified by the authority having jurisdiction for buildings or structures identified a.-:~ : la~:~c~ as historic buildings er :'.:'~':~'.:'re: where approved fire prevention, fire p r ~ c t i o n and fire emergency nlans confornaing with NFPA 909 demonstrate comnliance-with the ~oals and obiectives of Sections 1-5 and 1-6 it is c--~z:.t ~ : . : : r~:c.~:.5!z ~-~'c~. ef -~z.%" -

SUBSTANTIATION: The Technical Committee on Protection of Cultural Resources has gone to great lengths to prepare a document on protection of historic buildings which provides a mechanism for determining what constitutes an apprdpriate level of safety for these properties. The Life Safety Code@ should reference this standard, NFPA 909-1997, Standard on Protection of Cultural Resources Including Museums, Libraries, Places of Worship, and Historic Properties, for this purpose.

NFPA 909:1-3 reflects the intent that historic properties conform with the existing building provisions of the Life Safety Code to the greatest extent practical. Where alternative arrangements are necessary to preserve the architectural, cultural or historic fabric of a building or its contents, NFPA 909 requires that an equal or greater degree of protection be demonstrated. This stands in contrast to the rather vague and open-ended language presently proposed. The protection of cultural resources demands that nay exceptions not be ambiguous or subject to liberal interpretations formed without an intentional, thorough and deliberate analysis of the circumstances that affect fire safety in a given historic property. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The word "dassified" has special meaning and needs to be retained. The more general ROP language offers the authority havin~jurisdicdon greater latitude in judging the acceptability of a situanon. The submitter's language would force a costly analysis and lead to quasi-mandatory use of performance based design. The current language is adequate. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12


101- 45 - (1-11.3): Accept in Principle SUBMITFER= GregoryW. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101"-2 RECOMMENDATION: Move to 1-11.2 Historical

and 1-11.2 becomes 1-11.$ Existing 1-11.$ becomes 1-11.4 1-11.4 becomes 1-11.5 1-11.5 becomes 1-11.6 1-11.6 becomes 1-11.7 1-11.7 becomes 1-11.8 1-11.8 becomes 1-11.9 1-11.9 becomes 1-11.10.

SUBSTANTIATION: This keeps all the existing provisions together. Historical is existing, therefore appears before it. If 1-11.4. COMMITTEE ACTION: Accept in Principle.

[ Swap the position of current 1-11.2 and 1-11.$ so that the I paragraph applicable to historic buildings appears before the [ paragraph applicable to modification of reqmrements for existing ] buildings.

COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITIT_.E MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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N F P A 101 - - F 9 9 R O C


101- 46 - (1-11.$): Accept SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Insert the words "or structures" as a

s e c o n d appearance within the paragraph so as to read: I "...classified as historic buildings or structures where it is evident...". SUBSTANTIATION: The addition of the words ~or structures" is for consistency with a similar earlier use within the sentence. COMMrlq'EE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #411 ) Committee: SAF-FUN

101- 50 - (1-11.9): Reject SUBMITTER; Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Move to 1-11.3 after authority having jurisdiction, ahead of the existing section. SUBSTANTIATION: This will keep all existing paragraphs together. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The current placement is adequate. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 47- (1-11.8): Accept in Principle SUBMITTERa Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Reword according to my proposals in Chapter "Organization" and put ahead of Section 1-8.1 and reorder 1-8.2 as Options and reword section Code Organization Options. SUBSTANTIATION: Both are telling you the same thing, how to use this code organization. COMMITTEE ACTION: Accept in Principle.

Move 1-11.8 into 1-8.2 so that 1-8.2 reads: 1-8.2 Prescriptive-based Option. 1-8.2.1 A prescriptive-based life safety design shall be in

accordance with Chapters 1, 2, 4-7, the applicable occupancy Chapters 8-31, 32, and $$ of this Code.

1-8.2.2 Where specific requirements contained in Chapters 8-32 differ from general requirements contained in Chapters 1-7, the requirements of Chapters 8-32 shall govern.

Delete current 1-11.8, Priority of Chapter Requirements. COMMITTEE STATEMENT: The reorganization of material should meet the submitter's intent. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 48- (1-11.9): Reject SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Move to Applications 1-4.$ new section. SUBSTANTIATION: Too important to be buried in Genera/. It is much broader applied in Applications for the whole Code. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The material suggested for relocation does not fit the applications section. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12


101- 49- (1-11.9): Reject SUBMITrER: GregoryW. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Move to 1-11.1 ahead of authority having jurisdiction as 1-11.2. SUBSTANTIATION: Too important to be buried within the Code. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The current placement is adequate. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 51 - (1-11.10.2): Accept in Principle in Part SUBMITTER: Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-$ RECOMMENDATION: Revise text to read:

1-11.10.2" Where comoliance with this code is affected bv means of a oerformance-based design, the owner shall annually certify comnliance with the conditions and limitations of the desitna by submittinu a warrant of fitness orenared by a aualified individual acceptable to the authority havin~r iurisdiction. The warrant of

- v

fitness shall attest that the buildin~ features, systems and use have been insDected and confirmed to remain consistent with desit, n snedfications oudined in the documentation reauired bv Section 3-9 and that they continue to satisfy the ~oals ancl obiectives

v

sDedfied in Sections 1-5 and 1-6. ~?..m.ere a pe:ff.e:va.ance ba~ed

Chapter $.) A-1-11.10.2 A warrant of fitness consists of an en~ineerin~ renort.

technical analysis or other written documentation Drenared by an individual or team of individuals uualified in the evaluation of nerformance-based designs. SUBSTANTIATION: Owners will not typically possess the qualifications necessary to independently assess conformance with the conditions of a performance-based design. Public confidence in the safety and rehability of performance alternatives to prescriptive regulation will demand a significant degree of indep.endence and accountability for the continuous assessment of conditions required to maintain performance. The warrant of fitness approach is widely recognized by countries presently employing performance-based regulations, including England and Wales and New Zealand. COMMITTEE ACTION: Accept in Principle in Part.

Do not add a new appendix but revise 1-11.10.2 to read: 1-11.10.2 Where compliance with this code is effected by means

of a performance-based design, the owner shall annually certify compliance with the conditions and limitations of the design by submitting a warrant of fitness acceptable to the authority having jurisdiction. The warrant of fitness shall attest that the building features, systems and use have been inspected and confirmed to remain consistent with design specifications outlined in the documentation required by Section 3-9 and that they continue to satisfy the goals and objectives specified in Sections 1-5 and 1-6. (See Chapter 3.) COMMYrTEE STATEMENT: The Committee Action should

f~Bthe submitter's intent. FaR OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12

VOTE ON COMMIq[q'EE ACTION: AFFIRMATIVE: 12


101- 52 - (1-11.10.2): Reject SUBM1TrER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Relocate to Chapter 3 Administrative Procedures. (New section). SUBSTANTIATION: (None provided) COMMITTEE ACTION: Reject.

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N F P A 101 - - F 9 9 R O C

COMMITTEE STATEMENT: The material must be retained in Chapter 1 for application to existing buildings. The code user would typically go to the performance based chapter 3 only for the original design. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 53 - (1-11.10.2): Reject SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Add "the owner t,9 t~¢ authority having Jurisdiction shall annually certify". - Add sentence: "The authority having jurisdiction has the responsibility to conduct an annual inspection verifying the owners statements that the buildings features, systems and uses remain in accordance with performance design." SUBSTANTIATION: (None provided) COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Comment 101-51 (Log #128). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 54- (1-11.12): Reject SUBMITTER: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Recommend that the proposal to strike the following wording from proposed 1-11.12 be reconsidered, "or from one occupancy subclassification to another subclassificadon of the same occupancy". SUBSTANTIATION: The substantiation for striking the wording is stated as follows, "Occupancy to be silent on changes in subclassification so as to force those few occupancies that use subdassification to note the requirement in their respective occupancy chapters." The wording dealing with subclassificadon is important to authorities having{ jurisdiction and should not be stricken from the general reqmrements of the Code. Consideration should be given to retaining the wording in 1-11.12, and having specific situations covered in the occupancy chapters. Frankly, I have not had the time to check all proposals that might be related, therefore, .I do not know if any of the proposals would indicate compliance with the desires of the committee to deal with subclassifications in occupancy chapters. It seems more realistic for the occupancy chapters to be mandated to make such changes before the wording inquest ion is removed from proposed 1-11.12. COMMITTEE ACTION: Reject. COMMITTEE STATi~ENT: All of the occupancy chapters have addressed the subject adequately. For example, in the ROP, see Proposals 101-416 and 101-417 for health care, 101-627 and 101-696 for board and care facilities, 101-734 for mercantile, 101-803 for industrial, and 101-835 for day care. Additionally, for the 1997 of the code the assembly occupancies chapters did away with subclassifications A, B, and C. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 55 - (1-11.12): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: In 1-11.12, Change of Occupancy, keep the struck wording. SUBSTANTIATION: At the present time, all technical committees have not addressed this issue. It is premature to delete the text until all technical committees have addressed the issue. We also feel that in this case redundancy is needed to ensure compliance with the Code. COMMITTEE ACTION: Reject.

COMMITTEE STATEMENT: See the Committee Statement for the rejection of Comment 101-54 (Log #164). NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 56 - (1-11.13.2): Reject SUBMITI'ER: Mark Chubb, Incendiis Consultants COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise text to read:

• • • ^ ' l - . . , . I " . . . . # ~ +1~ . . . . 1 .~1 :~ : 4 f " 1-11.1B.2 Emsung life safety features . . . . . . . . . . . . v . . . . . . . . not required by the Code shall be maintained or removed. SUBSTANTIATION: As clearly indicated by the Appendix A commentary accompanying this section, the presence of fire protection features creates reliance upon them. Whether the presence of a feature is obvious to an untrained observer is unimportant. If the occupant, the public or emergency services have formed expectations associated with the existence of a life safety feature or features regardless how they came to this understanding, such protection should be maintained or the expectation changed or eliminated. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The words "obvious to the ~ublic" need to be retained or the paragraph becomes too strict. ~or example, a sprinklered hospital would be required to maintain smoke barrier duct dampers - which are not obvious or visible to the public - although such dampers are not required based on the

~ rUMesence of the automatic sprinklers. BER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12

VOTE ON COMMI'ITEE ACTION: AFFIRMATIVE: 12


101- 57 - (1-11.13.2): Accept SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-3 RECOMMENDATION: Revise appendix A-1-11.13.2 as follows:

"A-1-11.13.2 Examples of such features include automatic sprinklers, fire alarm systems, standpipes, and portable fire extinguishers ~.-z~.nt.:! c::'~. The...". SUBSTANTIATION: The public does not know that a horizontal exit exists, they keep following the exit sign until they are out of the building or are to ldto wait. I f a horizontal exit is not required and not maintained, what need to be removed? The door?, the wall? Similarly could this be applied to non-required smoke barriers? Conversely, improperly maintained portable extinguishers could be a hazard. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITYEE ACTION:

AFFIRMATIVE: 12


101- 58- (1-11.13.2): Accept SUBM1TrER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-3

I RECOMMENDATION: In 1-11.13.2 move the position of the word "either" so as to read:

"...not required by the code, shall be either maintained or removed." SUBSTANTIATION: The change is, in effect, editorial. COMMIT]FEE ACTION: Accept• NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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N F P A 1 0 1 m F 9 9 R O C


101- 59 - (2-4 Exception): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-11 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requsts that SAF-FUN, which has main responsibility for Chapter 2 provisions, provide needed changes or offer concurrence with revision of this material given that the proposal was acted on by SAF-HEA. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Let the Committee Action on Proposal 101-11 remain as an accept. COMMITTEE STATEMENT: The SAF-FUN Committee does not object to the change in the referenced proposal. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 60 - (Chapter 3, A-3): Accept S U B ~ Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add an asterisk to the title "Chapter 3". Add the following Appendix note, with figure as A-3.

A-3 Chapter 3 of this Code provides requirements for the evaluation of a performance-based life safety design. The evaluation process is summarized in Figure A-3.

Code Criteria. On the left hand side of the figure is input from the Code. The life safety goals have been stated in Section 1-5. The objectives necessary to achieve these goals are stated in Section 1-6. Section 5-2 of this Chapter, Performance Criteria, specifies the measures that are to be used to determine whether the objectives have been met.

Input. At the top of Figure A-3 is the input necessary to evaluate a life safety design.

The design specifications must include certain retained prescriptive requirements as specified in Section 3-3. All assumptions about the life safety design and the response of the building and its occupants to a fire must be clearly stated as indicated in Section 5-4. Scenarios are used to assess the adequacy of the design. Eight sets of initiating events are specified for which the ensuing outcomes must be satisfactory.

Performance Assessment. Appropriate methods for assessing performance are to be used per Section 3-7. Safety factors must be applied to account for uncertainties in the assessment as stated in Section g8. If the resulting predicted outcome of the scenarios is bounded by the performance criteria, then the objectives have been met and the life safety design is considered to be in compliance with this code. Although not part of this Code, a design that fails to comply may be changed and reassessed as indicated on the right

I hand side of Figure A-3. Documentation. The approval and acceptance of a life safety

design are dependent on the quality of the documentation of the process. Section 3-9 specifies a minimum set of documentat ion that must accompany a submission. SUBSTANTIATION: To provide an overview of the Chapter and explain the interrelationship of its component Sections. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:


HURLEY: It was my understanding that the text that accomplishes this comment would precede the text added as a result of the action of Log #178. This ordering was not indicated on the discussion accompanying either comment.

Retained ' '. • Design

] Requirements| I ^ c .. a 3s5 / I -6ther Conditions- I

f-'" ~ - - ' ~ ] Evaluation of I

CSo~s1-5 J I Pr~l~ec~i~n~e-~gn- I *

l Change Design

Section 1-6 Section 3-7

I Performance No Criteria . . . . . . . . =

Section 3-2

Documentation N equirements| Section 3-8 J

Figure A-$ Performance-based Life Safety Code Compliance Process.


101- 61 - (Chapter 3 (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUN address the subject of reliability of systems and building fire safety features used in a performance-based design. There appear to be conflicts and inconsistencies among the provisions of g4.3.1, Exception to 3-4.3.1, 3-4.3.2, 3-5.3.8 Scenario 8, $-5.3.9 Scenario 9, and the appendix notes. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See numerous Committee Actions on a variety of comments related to proposed Chapter 3 on performance based des!~gn. COMMITrEE STATEMENT: The Committee Action on me numerous comments should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12


101- 62 - (Chapter 3): Accept in Principle SUBMITTER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add a new appendix note, A-3, as follows:

A-3 The performance opdon of this Code establishes tolerable levels of risk to occupants of buildings and structures as addressed in Section 1-2. These provisions describe how a building should perform under normal and adverse conditions (e.g., fire).

While the performance option of this Code does contain goals, objectives and performance criteria necessary to provide an acceptable level of risk to occupants, it does not describe how to meet the goals, objectives and performance criteria. Design and engineering is needed to develop solutions that meet the provisions of this chapter. The SFPE Engineering Guide to Performance- Based Fire Protection Analysis and Design provides a framework

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for developing and assessing fire protection strategies to meet the fire and life safety objectives specified this Code.

The performance-based option contained in this section was developed using a "top-down" approach (i.e., the goals, objectives and performance criteria were developed without a quantitative analysis of the "performance" of the prescriptive requirements of the code). For this reason, there may be prescriptive-based code compliant designs that would not be considered acceptable when compared to or evaluated using the goals, objectives and performance criteria of the performance-based option. SUBSTANTIATION: (First and second proposed paragraphs) The provisions of Chapter 3 contain goals, objectives and performance criteria necessary to provide an acceptable level of life safety, but Chapter $ only provides an incomplete means for meeting these goals, objectives and performance criteria. Therefore, it is necessary to provide a complete process. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design provides such a process.

(Third proposed paragraph) It has been stated by the committee chairman and NFPA staff that the ?performance" of prescriptive compliant designs has not been evaluated (at the NFPA fall, 1998 meeting in a session entitled "The Science and Methods Behind Performance-Based Life Safety Code Proposals.") Therefore, it is important that this be made clear to users of the Code. Failure to do so implies that the Code drafters have considered the "performance" option in the context of the "performance" of

rescriptive compliant designs, which has not taken place. OMMITTEE ACTION: Accept in Principle. Create a new appendix A-$ to read: A-$ The performance option of this Code establishes acceptable

levels of risk to occupants of buildings and structures as addressed in Section 1-2. While the performance option of this Code does contain goals, objectives andper fo rmance criteria necessary to provide an acceptable level of risk to occupants, it does not describe how to meet the goals, objectives and performance

I criteria- Design and engineering are needed to develop, solutions that meet the provisions of this chapter. The SFPE Engineering Guide to Performance-based Fire Protection Analysis and Design provides a framework for these assessments. Other references that may be useful include the Australian Fire Engineering Guidelines, and the British Standard Firesafety Engineering in Buildings.

To the non-mandatory references appendix (to become an annex) add the following=.

SFPE Engineering Guide to Performance-based Fire Protection Analysis and Design, Society of Fire Protection Engineers, . Bethesda, MD, 1998.

Fire Engineering Guidelines, Fire Code Perform Centre, Limited, Sydney, Australia, 1996.

Fire Safety Engineering in Buildings, DD940: Part 1, British Standards Institution, London, England, 1997. COMMITFEE STATEMENT: The Committee Action should meet the submitter's intent. By providing the reference materials in ppendix A-$, the detailed citations will no t need to be repeated, ut rather can be referenced.

NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:


EXPLANATION OF NEGATIVE: HURLEY: The action that was taken on this comment was

incorrectly labeled as "Accept in Principle." The action that was taken was "Accept in Principle in Part. ~ The language proposed to be added in the last paragraph of the comment was not included in the committee action. Furthermore, there was no reasoning for rejection of that part of the comment included in the committee statement. Similarly, no statement was made by any members in attendance at the committee meeting refuting the point of this paragraph.

It is simply responsible code writing to clearly state any background or limitations accompanying major changes or additions, it would not be difficult to come up with compliant prescriptive designs that would not be acceptable when analyzed using the performance criteria and design fire scenarios specified in Chapter 3. For example, consider placing the fire in scenario #2 blocking the longest common path permitted by one of the occupancy chapters.

A statement to the effect of that proposed as the last paragraph of the comment is needed by the design community. If there were to be a fire in a building that was designed to the prescriptive option, in which lives were lost, an argument could be made (perhaps in court) that the building would not have been acceptable when- analyzed using Chapter 3.


101- 65 - (Chapter $ (New)): Hold SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Reorganize all sections as follows:

CHAPTER 3 PERFORMANCE OPTION

5-1 Code Requirements. These shall be determined in accordance with this Code as set forth in a design contract developed between the design team and the Authority Having Jurisdiction Review Team prior to the initiation of the design and recorded in the building deed to the owner. This section is typical of the Building Code and all its systems sub-Codes and Standards. 5-1.1 g--l- General Requirements. 5-1.1.7 ~ Definitions.

Design is the final one selected amongst trial designs by the design team as satisfying all the requirements of this Code and the design conu-act. It is the only design that is submitted to the authority having jurisdiction for approval. The determination for approval is this Code has been met, that all identified hazards have been mitigated to an acceptable level of risk as approved by the Authority Having Jurisdiction Review Team.

Design Team add new sentence: No member of the Design Team can have any interest in or conflict with any members of the Review Board or Authority Having Jurisdiction Review Team.

Trial Designs are the freedom of choice by the design team in order to produce a single code compliant design by using the engineering methods of their choice in developing and testing the compliance of the these designs to the this Code. The design team will no doubtingly use cost/benefit as one of their analysis to determine which of the code compliant trials designs they will submit to the Authority Having Jurisdiction Review Team. 5-1.2 8-g Performance Criteria. 3-1.2.1 Existing Section from Proposal with my comment that this section's requirements are insufficient and lacking in specific criteria for the technical concerns that this Code should address. 5-1.2.2 For each criteria, the Authority Having Jurisdiction Review Team shall determined the level of the or degree of analysis to be

~ erformed by the design team. 1_3 gig:Prescriptive Criteria/Requirements. Desig~

3-2 Method Requirement~ These shall be selected by the Design Team and approved by the Authority Having Jurisdiction Review Team for the design submitted. This section is typical of the engineering design

r2actice. .1 Compliance For Methods.

$-2.1.1 The design shall explicitly relate and compare the application of engineering and scientific principles and good engineering practices to all aspects of the design and to the actual building conditions. 5-2.1.2 Methods shall include but are not limited to equations, calculations and models or other methods each independently and collectively as a whole. 3-2.1.$ All methods shall cite as their sources by the Desi~[n Team the technical development of the methods to the level of either their scientific equations, principles, or laws or to the level of their empirical test data, which shall also describe the test setup, procedure, and pass/fail criteria. 3-2.1.4 The design team shall establish the relationship of the following concepts to the appropriate applications of the design for each of the methods used:

1. Assumptions behind each of the methods. 2. Verification of each method used including repeatability. 3. Sensitivity Analysis of all the inputs to each method. 4. Uncertainty of inputparameters & the output results. 5. Safety factors assignedto the parameters shall be explicitly

stated and justified as to the degree chosen. 5-2.2 g-4 Assumptions.

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3-2.$ g 6 Scenarios. 3-2.4 g-6- Data. 32.4.1 Note: Code test as stated in the proposal $-2.4.2 Sensitivity analysis shall be performed by the Design Team and approved by the Authority Having Jurisdiction Review Team for all methods used in the design. $-2.4.2.1 Shall be demonstrated by the bracketing or window technique in modeling, whereby the inputs are a range of values based on possible building conditions which define the range of values as the output. 3-2.4.3 Uncertainty of data shall be performed by the Design Team and approved by the Authority Having Jurisdiction Review Team for all methods used in the design. $-3.4.2 Inputs to methods shall be performed by the design team and approved by the authority having jurisdiction review team. 3-$.4.3 Output from methods shall be performed by the design team and approved by the authority having jurisdiction review team. $-3 Compliance Requirements. All of these items shall be

erformed by the design team and approved by the Authority aving Jurisdiction Review Team for both the design submitted

and the methods used in the design. This section is typical of the lan review by the authority having jurisdiction.

.1 [$-7] Methods for Assessing Performance. 3-$.1.1 All methods shall be submitted in conformance with Section 3-2 Method Requirements. 3-3.1.2 Verification of the methods used shall be demonstration by the design team and approved by the authority having jurisdiction review team. 3-3.1.3 Repeatability of all methods shall be demonstrated by the design team and approved by the authority having jurisdiction review team. $-$.1.4 All analyses for compliance shall be performed by the design team and approved by the Authority Having Jurisdiction Review Team for the following:.

(a) All data in all methods shall be in accordance with section 3-2 of this Code.

(b) All methods shall be in accordance witli section 3-2 of this Code

(c) All building components, features, equipment, services and systems shall be analyzed and tested for their functionality in regards to themselves and to their interaction with other building components, features, equipment, services and systems including their reliability and their redundancy or backup given a degree of reliability in accordance with section 3-3.2 of this Code.

(d) Hazard/Risk assessment of the performance of the design and its systems shall be conducted in accordance with the goals & objectives of this Code for the protection against the given or determined degrees of the hazards. $-$.2 All Building Components, Features, Equipment, Services, and Systems. The design team shall predict the functionality of the systems and design in regards to its probabilistic outcome of success in the time of need to the satisfaction of the authority having jurisdiction by accounting for the below concepts:

(a) Reliability of each building features, equipment, services, & systems.

(b) Redundancy of it, based on an agreed level of reliability and on zero reliability.

(c) A coordinated interaction between and amongst all the different systems, besides the interaction of the components within a system, shall be shown.

(d) Hazard/Risk Assessment for each of above combinations. $-3.3 g-g Safety factors for designparameters can be required by the Authority Having Jurisdiction Review Team. $-3.4 gO Documentation Requirements. $-3.4.1 Design submission shall include but not be limited to: 3-3.4.1.1 Design specifications shall include but not be limited to:

1. Design Documentation report Test Reports. 2. Drawings-layout 3. Building Components, Equipment, and Material Specifications

and Lists 3-$.4.1.2 Construction specifications shall include, but not be limited to:

1. Construction Methods 2. Assembly Instructions 3. Installations Specifications

3-3.4.1.2.1 All construction methods and procedures shall be in conformance with the approved design documentation or generally accepted standards that are referenced in the approved documentation. 3-4 Administration of Enforcement. This section is typically the government 's administration requirements in enforcing the

Building Codes in section 3-4.1 and the Fire Prevention Codes in section 3-4.2. 3-4.1 Authority Having Jurisdiction Review Team for the Design. 3-4.1.1 Local Authority Having Jurisdiction Members. 3-4.1.1.1 No member of the Review Team can have an), interest in or conflict with all members of the design team or rewew board. 3-4.1.1.2 The authority having jurisdiction shall select as many of its members for its Review Team as feasible from the following methods: $-4.1.1.2.1 Potential members of the Authority HavingJurisdiction Review Team can be placed on retainer by the local jurisdiction so as to identify its members as having an interest in the jurisdiction and not enabling them to be hired as a member of the design team within its jurisdiction. 3-4.1.1.2.2 Qualified members of any level of government authority having jurisdiction by automatically providing the service through the local authorities having jurisdiction decision to opt-out to a higher level of government to provide the service, shall automatically serve as members of any Review Team within the members own higher jurisdiction. 3-4.1.1.2.$ Local authority having jurisdiction can select its members for the Review Team through any intergovernmental agreements for personnel or services, especially in providing the needed specialty engineering services. 3-4.1.1.2.4 Members of any governmental agency having jurisdiction in any portion of the building design, insurance company or government insurance regulatory agency or any other such review interests, or their agents shall be permitted to be a member of the Review Team, so as not to subject the building owner to numerous or conflicting reviews. This is easiest way for the authority having jurisdictinn to pool all the appropriate resources and data prior to the authorities having jurisdiction approval. 3-4.1.1.3 All members of the Review Team no matter how selected shall be professionally cjualified for the work they are performing by the appropriate cerufication standards or organizations as adopted by the authority having jurisdiction. $-4.1.2 Authority HavingJur'mliction Authority for Approvals. 3-4.1.2.1 The authority having jurisdiction is the lead administrator and approval authority for the Review Team. 5-4.1.2.1.1 All correspondence shall be in writing through the authority having jurisdiction to Design Team and all such correspondence shall be retained in the design documentation's addendum. $-4.1.2.1.2 The authority having jurisdiction can direct the Review Team to perform the methods the same as or differently than the Design Team's approach to the satisfaction of the authority having jurisdiction. Such work shall be subject to the same the conditions as specified in this Code. The authority having jurisdiction can then use this work to judge that of the Design Team before determining acceptability. 3-4.1.2.2 All services of the Review Team shall be paid by the building owner applicant or secured before the issuance of the Certificate of Occupancy. $-4.12.$ The Certificate of Occupancy shall be attached to both the maintenance manual, inspection manual and Fire Department Statement of Expected Services and recorded in the building owners deed by the appropriate authority having jurisdiction recording clerk for building properties. 3-4.2 Independent Appeals, Arbitration, and Review Board. 3-4.2.1 Set up by the Code Adoption Authority along with the adoption of this Code as a board independent of members and interests of all Authority Having Jurisdiction Team, Design team, building owners and operators and State Code Adoption Authority. Its members shall be qualified to perform and understand the details of such matters presented before them such as the analysis and methods and calculations not only used in the particular design before them, but also all those within the universe that could have been used in the design. Each side is to present their case to this board who shall act as judge and jury for disputes amongst the parties of the design. 3-4.2.2 No member of the design or approval teams can have any interest in or conflict with any members of the review board. $-4.$ Post-Design and Building Life Requirements. This is typically the Fire Prevention Code. The purpose of this section is to require the Design Team to make prescriptive requirements for both maintenance and inspections for the life of the building, from the performance design knowledge before the performance intent and agreements are forgotten and before there are change in .~4rsonnel of the building owner and authority having jurisdiction.

.3.1 A contract signed by the appropriate officers of both the Building Owner and Authority Ha~ang Jurisdiction shall he placed in the deed of the building and shall be conveyed to all future

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ownership parties or authority having jurisdiction regulatory parties for purposes of assuring compliance of both sections 3-4.2.2 and 5- 4.2.5. This typically is the right-of-entry. 5-4.3.2 The additional documentation of the service work in section 5-4.2.2.1(e), the maintenance manual and the Maintenance Log Book shall be retained and passed onto the next owners as stipulated in the building's deed. $-4.$.5 In the event of the sale of the building, the deed shall stipulate that along with the sale of the building contracts, the building owner shall sign the maintenance and inspection contracts as provided by the original design team. This shall be the same unless can only be amended if the building use. 5-4.5.4 Maintenance requirements shall be performed by the building owner according to the maintenance manual written by the Design Team and approved by the Authority Having Jurisdiction Review Team. 3-4.3.4.1 Maintenance manual shall include the following:

(a) Manufacturer's information for all components (b) Standards whether fully or partial used to define the

maintenance practices • (c) Schedule of maintenance as to what components or systems, at what intervals, for what specific work, and to the degree necessary.

(d) Checks and replacement criteria for each component, system, assembly, etc.

(e) Documentation required to be maintain by the building owner for review by the authority having jurisdiction shall become part of the maintenance manual. Such items are, but are not limited to, the maintenance log books, service reports by service personnel, part replacement schedule, etc. 3-4.3.4.2 Maintenance log book shall be bound and contain for each entry the dates, times, file number for any reports, person and company representing, brief description of the work performed and to the standards the work was performed by both the building owner and any hired contractor for any portion of the system or component o f the building regulated by this Code for the life of the building. Such book shall contain the following for each entry:.

(a) Chronological dates of entries of maintenance performed (b) Contractor or person performing the work, (c) Work performed and standards used (d) Report No.

.3-4.3.4.2.1 Entries in the maintenance book shall be made without skipping any lines within the book. 3-4.3.4.3 Maintain the files of original reports for all work

~ erformed by all service personnel for the life of the building. uch files shall also be maintained by systems or equipment so that

inspection and equipment problems can be identified over the course of all inspections. 3-4.3.5 Inspection requirements shall be defined by the Design Team and performed annually by the authority having jurisdiction according to the following:

(a) What shall be inspected (b) When-schedule for specific tasks (c) Acceptance Criteria (d) Repair or Replacement Criteria (e) Review Documentation by the building owner verifying the

maintenance has been performed adequately. 3-4.3.6 Fire Department Statement of Expected Services. Fire Departments may write a statement as to the level of protection they cannot be expected to provide for the design based on the building characteristics, systems, documentation and manuals. This statement shall become part of the design documentation in the maintenance and inspection manuals and shall be referenced in the deed for the building, provided the fire department has specific written Pre-Plans outlining the fire department 's standard response to an incident in the building. This Pre-Plan must be consistent with the fire department 's statement in both manuals. All of the fire department 's personnel shall be instructed and shall conduct at least annual training exercises in the execution of this Pre-Plan as defined by the fire department 's appropriate officers. 3-4.3.7 Any change in use, occupancy, conversion, alteration, additions or repair of equipment, systems or building components other than those specified in the final approved documentation can only happen after these same code requirements are again performed in accordance with this Code.

ADDENDUM'S to either: CHAPTER 3 OR THE ENTIRE CODE Comments: This Performance Section may need to have its own section in Chapter 3 for the four categories below due to the complexity and number of reference standards that will be developed and evolve from these Chapter 3 requirements.

Otherwise this information from Chapter 3 will be blended into the below four categories for the entire Code.

Referenced Publications (Mandatory) j~opendix A Explanatory Material

endix B (Non-mandatory) Referenced Publications Index SUBSTANTIATION: Reorganization. This comment also !~laces the existing text of the code proposal in the appropriate sections of this outline, along with the new material that ts already added in this outline in its appropriate section. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The material submitted introduces subjects that have not had public review and which have not been completely developed. So significant a change - proposed during the ROC preparation - needs to be held for processing during the next revision cycle. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITYEE ACTION:


GALLAGHER: This proposal, which is on file and not printed in the ROC, identifies many topics of concern that are either not addressed, not considered, or the support ing technology or engineering tools and methods have not ye tbeen fully developed to make this Performance Option Code in Chapters 1, 2, and 3 an usable and enforceable document, within the stated limitations which also are not stated in the document for the engineering methods available to do this type of design. I agree with the committee's decision to hold off on this material until next cycle. I also contend that this entire Performance Option as currently proposed should likewise be held off until the next cycle for adoption. In addition to the concepts that are missing from the current proposal, the engineering tools and knowledge to support this type of design and review have not yet been fully developed to adequately review and certify that the design satisfies the health, safety, and welfare concerns of the public as translated and enforced by the authorities having jurisdiction decision.

The SFPEDesign Guide is only a suggested process. It does not contain all the answers to either design or rewew a performance design as of yet. The Society of Fire Protection Engineering (SFPE) recognizes this fact, in that numerous new task ~ o u p s have been formed to start developing the missing engineering data, methodologies, and design material necessary to support this performance option design. Presently, the engineering for a performance approach only exists for some fire protection components on a subsystem level of Level I as defined in the SFPE Design Guide.

Thus it is my opinion that this Performance Option approach in Chapter $ as currently proposed should be held over for the next review cycle in order to continue its development and state the limitations of its use within the code, before it is released for general use to the public designers and authority having jurisdiction reviewers.


101- 64 - (Chapter 3 Title): Accept SUBMITTER: MorganJ. Hurley Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Change the title of Chapter $ to "Performance-Based Oesign- Qp.tig_a". SUBSTANTIATION: The proposed title overlooks the difference between codes and design and implies that Chapter $ is a design methodology versus what it really is, which is a performance-based code.

Codes should describe how a building should perform under normal and adverse conditions (e.g., fire) in meeting the perceived needs of the community. Engineering (i.e., design) is the process of demonstrating that the needs of the community are met through the application of accepted tools and methodologies.

This change would make the title of Chapter 3 consistent with the wording used in proposed 1-8.3 in Proposal 101-3. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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101- 65 - (Chapter 3 various): Accept in Principle SUBMITTER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Change the term "fire scenario" to "design fire scenario" in paragraphs 3-1.7 and 3-9.5.

Change "specified fire scenario" to "design fire scenario" in paragraphs 3-2.1, A-5-2.1 and A-3-2.5.

Change "scenario" to "design fire scenario" in A-3-4.1, A-3-4.2 and 3-4.3.1.

Change "design fire" to "design fire scenario" and "scenario" to "design fire scenario" in 3-5.1.

Change "design fires" to "design fire scenarios" and "scenario" to "design fire scenario" in 3-5.2 and A-3-5.2.

Change "required scenarios" to "design fire scenarios" and "scenarios" to "design fire scenarios" in 3-5.5.

Change "scenario" to "design fire scenario" in each occurrence in 3-5.3.1 through 5-5.$.9 and associated appendices.

design fire scenario" in 3-6.4 and Change "scenario" to subparagraphs, and in 3-6.7...

Change "scenario" to "design fire scenario" in A-5-7 and subparagraphs of 3-7,

Change "scenario" to "design fire scenario" in 3-9.10.9. Change the definition of "Fire Scenario" (proposed to be changed

to "Design Fire Scenario") as follows: Design Fire Scenario. A set of conditions that defines or

describes the factors critical to determining outcomes of a trial design, typically'including, but not limited to, building characteristics, occupant characteristics and fuel and fire characteristics. Design fire scenarios are the set of fire scenarios used to evaluate trial designs. These represent a group of fire conditions that are deemed threatening to a building or its occupants and hence must be addressed explicitly in the design.

Add a new definition for "Fire Scenario" as follows: Fire Scenario. A set of conditions that defines the development of

fire and the spread of combustion products throughout a building or part of a building. The fire scenario describes factors critical to the outcome of the fire such as fire protection features, ignition sources, nature and configuration of the fuel, ventilation, characteristics and locations of occupants, and conditions of the supporting structure and other equipment. SUBSTANTIATION: 1. This change would condense the variety of terms that appear to mean the same thing into a single term.

2. In addition to the (design) fire scenarios specified in 3-5, several other fire scenarios will need to be considered as part of the evaluation of trial designs. It is important to distinguish between the fire scenarios that are brainstormed by the design team and the authority having jurisdiction, and may or may not be considered in the evaluation of trial designs, and (design) fire scenarios that are used to test the achievement of performance criteria. A companion proposal to 3-5 describes the process of characterizing possthle fire scenarios and filtering them into design fire scenarios. The set of design fire scenarios, both those specified in 3-5 and those developed by the engineer will form the "load" that the

~ efformance-based design must withstand. This proposal will also armonize terminology used in NFPA 101 with the SFPE

Engineering Guide to Performance-Based Fire Protection Analysis and Desi~gn.

3. If this comment is accepted, the term "fire scenario" (as opposed to "design fire scenario") would only be used in paragraphs 34.4.1, A-34.8 and A-$-5. In 3-4.4.4 and A-34.8, it is appropriate to use the broader term "fire scenario", of which "design fire scenarios" are a subset. A-3-5 describes the process of characterizing possible fire scenarios and filtering them into design fire scenarios. COMMITTEE ACTION: Accept in Principle.

In 3-1.7 Change the definition of Fire Scenario to read: Fire Scenario.* A set of conditions that defines the development

of fire, the spread of combustion products throughout a building or part of a building, the reactions of people to fire, and the effects of combustion products.

In 3-1.7 Add a definition of Design.Fire Scenario to read: Design Fire Scenario. A fire scenario selected for evaluation of a

proposed design. In A-3-1.7 Change the text associated with the definition of Fire

Scenario to read: A-3-1.7 Fire Scenario. A fire scenario defines the conditions

under which a proposed design is expected to meet the fire safety goals. Factors typically include fuel characteristics, ignition sources, ventilation, building characteristics, and occupant locations and characteristics. ~Fire scenario" includes more than

the characteristics of the fire itself but excludes design specifications and excludes any characteristics that do not vary from one fire to another; the later are called assumptions. T h e term "fire scenario" is used here to mean only those specifications required to calculate the fire's development and effects, but in other contexts, the term may be used to mean both the initial specifications and the subsequent development and effects (i.e., a complete description of fire fi'om conditions prior to ignition to conditions following extinguishment).

In $-2.1 Change "specified fire scenario" to "design fire scenario". In A-3-2.1 Change "specified fire scenario" to "design fire

scenario". In A-5-2.5 Change "specified fire scenario" to ~design fire

scenario". In 3-9.5 Change " fire scenario" to "design fire scenario". In A-5-4.1 Change "scenario" to "fire scenario". In A-5-4.2 Change "scenario" to "fire scenario". In 3-4.3.1 Change "scenario" to "design fire scenario". In 3-5.$.1 through 3-5.3.9 Change "scenario" to "design fire

scenario". In $-6.4 and associated subparagraphs: Change "scenario" to

"design fire scenario". In 5-6.7 and associated subparagraphs: Change "scenario" to

"design fire scenario". In 34.4.1 Leave terminology as is. In A-34.8 Leave terminology as is. In A-3-5 Leave terminology as is. In 3-9.10.2 Leave terminology as is. In 3-5.3 Change to read: Required Design Fire Scenarios.

Scenarios selected as design fire scenarios shall include... In 5-5.1 Change ~design fires" to "design fire scenarios". Change

"scenarios" to "design fire scenarios". Drop "...location, size, and

""In 3-5.2 Change to read: "Design fire scenarios shall be evaluated using...".

In A-5-5.2 In the first reference to "scenario" change to "design fire scenario". In the second and third references, drop the words "by the scenario" and "in the scenario".

In 5-7 Make no change to the terminology in this reference. In A-3-7, first paragraph of A-3-7 change to read: "...$-4 identify

required design fire scenarios among the design fire scenarios within which...". COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITYEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12


101- 66 - (3-1): Reject SUBMITFER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add text as follows:

"Review board shall be set up by the Code Adoption Agency of members from any conflicts of the appearing pardes. This shall be a board of competent engineering members to judge the requests before them. They shall arbitrate any differences between the authority having jurisdiction and design teams based on technical documented merit." SUBSTANTIATION: 'Missing from the document. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: It is not within NFPA 101's scope to require review boards. Such administrative processes need to be

of the code adoption language. BER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12



101- 67- (3-1.2): Reject SUBMITrER: GregoryW. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add:

"The degree of engineering analysis must be established for all objectives as approved by the authority having jurisdiction. SUBSTANTIATION: No one knows how far to engineer the systems to what degree, or detail. Methods may also not be able to establish this degree by itself. The methods themselves are not known today.

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COMMITI'EE ACTION: Reject. COMMITTEE STATEMENT: The subject is adequately addressed I~VuMB$-I.2, Ll1.1, 8-7.I, and 3-9.1.

ER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPIANATION OF NEGATIVE: GALLAGHER: I do not believe that the four provisions

mentioned in the committee statement adequately cover my concern. I believe the degree of calculations is defined by other material that is not fully developed in the code, such as uncertainty analysis, sensitivity analysis, and variability analysis of either input or output data; bounding, redundancy and reliability analyses of components and systems; risk and hazard analyses of the overall design and other possible required analyses yet to be determined. Redundancy analysis can be considered as determined by scenario 8, but the authorit)~ having jurisdiction needs to know that he can make further reqmrements of the design depending on the outcomes of scenario 8.

Without these topics more fully defined in the code, it would be difficult for an authority having jurisdiction to know to what level or to what degree of engineering is required in selecting the calculation methods in $-6.1 (old 3-7.1) without being considered overly restrictive, over-analyzing and requiring excessive engineering of a design. This perceived "additional" or ~over-'engineering will undoubtedly be argued against by the design teams, due to the added costs and additional time required for the "build as you go (or approve)" or for the concurrent engineering/design/construct ions projects. (Section $-9.1 mentioned in the committee statement is now $-8.1).

Documentation is only for work that is completed or for what has been done engineered or designed. It does not address to what level to require the engineering and design analysis before it is completed.


101- 68- ($-1.4): Reject SUBMITI~R: Carol A. Caldwell, Caldweli Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

$-1.4 Independent Review. The authority having jurisdiction shall be permitted to require an approved, independent third-party to review the proposed design and provide an evaluation of the design to the authority having jurisdiction. The independent third harry reviewer shall have oualifications as appropriat~ for aADnroved Oualification" to nerform the design. SUBSTANTIATION: It is important that the third party reviewer has an appropriate level of qualifications to review the design. This review system is difficult at best and having an unqualified reviewer who is basing decision upon comfort level and not technical issues makes a mockery of the system. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The wording suggested by the submitter is awkward and doesn't help the code user. It is not necessary to repeat the concept of "approved". NUMBER OF COMM/TTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 69- ($-1.4): Reject SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add text as follows:

'q 'he authority having jurisdiction team members are selected by the authority having jurisdiction and paid by the design applicants. The authority havingjursidiciton team work under the direction of the authority having jurisdiction with all correspondence to the design team through the authority havingjurisdicition only and in writing for all requests and answers for information. The authority having jurisdiction must correspond to his members in writing also." SUBSTANTIATION: Missing from the Code. COMMITTEE ACTION: Reject.

COMMITTEE STATEMENT: This is an administrative issue outside the scope of the code. The proposed wording would allow only one method via an authority having jurisdiction-led team. The appendix note adequately explains the intent. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: I believe a documentation trail of what is

discussed or agreed upon must be established and maintained, similar to a contract negotiation. This documentation emil must be exchanged throughout all the stages of the performance design. This includes the initial conception and definition of the scope of work with the code concerns, the selection of the engineering methods and degree of engineering analysis, the compliance analysis and methodologies, the development of the documentat ion and owner's operat ion/maintenance manual, and the construction and testing inspections. The authority having jurisdiction must have control in selecting the appropriate design professionals needed to assist them in their review of the performance design, without inflicting additional financial burdens on the jurisdiction.


101- 70- ($-1.4): Reject SUBMITrER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace the word "third party" with "authority having jurisdiction review team" and add more rules defining the working relationship between these two parties and who is in charge of what. SUBSTANTIATION: The authority having jurisdiction must be able to control the review team yet the review team can practice engineering beyond the authority having jurisdiction knowledge. Review team have no interests or conflicts with design team in past or future. A balance needs to be struck unaddressed here. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The term ~third party" is common and well understood. It needs to be retained. Also see the Committee Statement for the rejection of Comment 101-69 (Log #$89). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: I do not believe the "third party" review system

will be ~independent" and perform the necessary critiques of the design submissions to the level necessary for the authority having jurisdiction, unless the authority having jurisdiction has direct control of the direction of their work. This review system is no t well understood and a single report of the design by a third party is not adequate. The authority having jurisdiction must have his own team of qualified design professionals that matches the design team expertise, design discipline for review discipline. This review team must be able to address and quantify all the authority having jurisdiction's concerns and questions to the level necessitated by the authority having jurisdiction. This is a continuous interactive process, not a single report. These qualified review professionals must have sole professional allegiance to the jurisdiction they are representing without having any other interest before that same jurisdiction at any other time. Thus, these review professionals must not be allowed to submit their own designs before the jurisdiction that they represent as its reviewer. It is my opinion in talking with professionals in the countries that have third party reviews that the system is not working as well nor as independent as it should.


101- 71 - ($-1.5): Accept SUBMITTER: Kenneth E. lsman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete "be permitted to" so that the sentence starts, ~The authority having jurisdiction shall make the final...".

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SUBSTANTIATION: By saying that the authority having jurisdiction shall be permitted to make the final determination, it implies that somebody else might also be the one to make this decision. By definition, only the authority having jurisdiction has the final word. COMMITTEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMI'II"EE ACTION:

AFFIRMATIVE: 12


101- 72 - (3-1.7 Authority Having Jurisdiction Team): Reject SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add a definition of Authority Having Jurisdiction Team as inside government agreements, opt out to high level, or independent engineering contract service or engineering retainer seraces, such that all specialties are represented in the authority havingjurisdictaon team. One cannot perform on both the authority having jurisdiction and design team. SUBSTANTIATION: Authority havingjurisdlction needs to balance the technical expertise of the design team, one-person. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The material is not needed. See the Committee Statement for the rejection of Comment 101-70 (Log #394). NUMBER OF COMMITTEE MEMBERS EHGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: 1 do not believe in the third party review system as

being totally independent to adequately review designs for tl~eir who will ultimately review their own design. (See my Explanation of Negative on Comment 101-70 (Log #394). It is then ultimately incumbent upon jurisdictions or groups of jurisdictions to join together to hire the necessary qualified review professionals to represent the review interest of the public without compromising their many professional interests as design professionals.

However, I d o understand the short-term problem of jurisdictions not able to fund such design professionals or not being able to offer salaries competitive enough to hire or even retain experienced review professionals in all areas of expertise. Therefore, jurisdictions must start to plan now before adoption of performanced-option codes in order to resolve these code administration hiring issues. When performance design options are adopted, the jurisdictions should ideally already have experienced qualified professionals on staff, or a system in place to use those on staff in other jurisdictions as "mutual aid agreements". The hiring of professionals should precede the adoption of performance design option codes and standards.

Personnel on the review authority having jurisdiction team must be held to the same professional registration criteria of practice within their area of specialty as established by experience and expertise as the design teams. This will be difficult for some smaller local jurisdictions who cannot afford to fund such positions. Thus the joining of jurisdictional support for common positions over several jurisdictions by a higher level of government may be necessary. Then the special expertise can be shared by all lower or equal jurisdictions.

SUBSTANTIATION: Although Table A-3-5(a) is referenced in A-3-5 under the discussion of ~Rate of Growth in Fire Severity", it seems appropriate toprovide clear definitions for the three "rates". The definitions provided in NFPA 72, and other data in NFPA 72 are referenced by many other NFPA codes and standards, and it seems appropriate to bring the definitions into the Life Safety Code for use with Chapter 3. The more definitions of terms used in Chapter 3 and its appendix the better for most authorities having jurisdiction. COMMITI"EE ACTION: Accept in Principle.

Add a second paragraph to appendix A-3-5.3 to read: ~The descriptors used in the Fire ~Type" column of Table A-3-

5(a) are meant to be qualitative and are intended to provide a relative measure of how quickly various fires may grow. The use of these descriptors is not meant to imply a specific correlation or quantification method for the associated heat release rate curve. For example, a "Slow Developing Fire" is meant to indicate that the fires described in that row o f Table A-3-5(a) develop slowly, not that they are, necessarily, a slow t-squared fire. While these fires may be characterized by a slow t-squared fire, this is not a requirement. One example of this is that of a cigarette between the cushions of upholstered furniture. The smoldering phase for this fire may not follow the growth rate of a slow t-squared fire and, therefore, such a correlation may be inappropriate for that particular scenario." COMMITTEE STATEMENT: The Committee Action should satisfy the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 74 - ($-1.7 Fuel Load): Accept in Principle SUBMITTER: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In new A-3-1.7, with regard to "Fuel Load", expand on the "heat units" commonly used, and on what is commonly used as "the equivalent weight in wood". SUBSTANTIATION: I want the Code to be clear on what various terms mean. There will be many users of the Code and it is very important that all are clear as to what various terms mean. This is very important in appendix notes that are being provided to clarify Code provisions. Several provisions of the appendix notes to the new Chapter 3 are a little "wordy" and may be considered "technical jargon". Fire educators are often criticized about this. It would be very helpful if the notes were more clearly phrased. I urge the committee to review the notes from the standpoint of authorities having jurisdiction, architects, and building owners. The more clear the provisions the greater the acceptance of

erformance based provisions. OMMITTEE ACTION: Accept in Principle. Drop the last sentence in A-3-1.7 Fuel Load so that it reads: A-3-1.7 Fuel Load. Fuel load includes interior finish and trim.

COMMITTEE STATEMENT: It is not the intent to focus on the method used. As such, the second sentence can be deleted. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 73 - (3-1.7 Fast Developing Fires, Moderate (or) Medium Developing Fires, and Slow Developing Fires): TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed to ~REJECr" because the language to which this comment is tied has been deleted from the performance-based option chapter via the action on Comment I01-115 (Log #187) and Comment 101-125 (Log #CCI0). Thus, the subject is moot. SUBMITTER= George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In new 3-1.7, provide definitions for "Slow Developing Fires", "Moderate (or) Medium Developing Fires", and "Fast Developing Fires". The definitions in B-2.2.3.2.1, B-2.2.3.2.2, and B-2.2.3.2.3 of NFPA 72, are suggested.


101- 75 - (3-1.7 Heat Release Rate (HRR) (New)): Accept in Principle SUBMITTER: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Either in new 3-1.7 or in new Chapter 2, the definition of Heat Release Rate and or Peak Heat Release Rate needs to be included in the Code. The following definition from NFPA 921 is suggested "Heat Release Rate (HRR). The rate at which heat energy is generated by burning. The heat release rate of a fuel is related to its chemistry, physical form, and availability of oxidant and is ordinarily expressed as Btu/sec or kilowatts (kW)." SUBSTANTIATION: Heat release rates or peak heat release rates are currently mentioned in Chapter 6 of the I~C and will be referred to in Chapter 3 in Appendix notes of the 2000 edition. The term or terms should be defined to aid the users of the Code.

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COMMITTEE ACTION: Accept in Principle. In Chapter 2 add a definition of heat release rate to read: Heat Release Rate (HRR).* The rate at which heat energy is

generated by burning. Create an appendix item associated with the Chapter 2 definition

to read: Heat Release Rate (HRR). The heat release rate of a fuel is

related to its chemistry, physical form, and availability of oxidant and is ordinarily expressed as Btu/sec or kilowatts (kW). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 76 - (3.1.7 Performance Criteria): Reject SUBMITTER: Norman E. Groner, Santa Cruz, CA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise the definition of "Performance Criteria" in 3.1.7 as follows:

Performance Criteria.* Performance objectives that define the means by which a fire safety design is exnected to accomplish the goals and obiectives sDecified in Sections 1-5 and 1-6. Performance criteria shall be soecified wherever ,tactical for individual products, systen~, assemblies, emergency procedures, or areas that are further quantified and stated in engi=ccr'ng tcr~.~ objectively measurable terms. SUBSTANTIATION: The changes clarify that performance criteria are the measurable means by which the design team intends to pursue the more abstract goals and objectives specified in Chapter 1. Further, the meaning for the term "performance criteria" needs to be dearly differentiated from "assumptions" and expanded to include objectives that govern human and organizational performance.

l ne expression "engineering terms" is deleted to avoid the implication that performance criteria are restricted to physical engineering methods. (Most code users will be unfamiliar with the term "human factors engineering" and its synonyms.) The fundamental feature of performance criteria is that they must be objectively measurable, regardless of whether the criteria refer to the performance of people or physical systems.

The revised wording explicitly permits the use of criterion measures of human and organizational performance as means to pursue performance objectives. Establishing performance criteria for emergency procedures is an important, and often essential, feature of performance-based design solutions. For example, a proposed design might provide 156 minutes (including a.safety mar~in) to evacuate an area in response to a scenario involving a fire m an unoccupied adjacent room. However, in response to a scenario involving an incendiary fire in an exit, the proposed design (include safety margin) can provide a longer time of 30 minutes to evacuate the same area. Therefore, the design team might want to establish a performance criterion of 10 minutes to evacuate the area in response to one scenario and a different criterion of 20 minutes for the second scenario, keeping in mind that one egress route has been eliminated. The current wording can be interpreted as prohibiting the establishment of performance criteria for human performance. In the current wording, human performance is only covered in the section for assumptions. Since assumptions are not allowed to vary across scenarios, the current wording could easily be interpreted as prohibiting the setting of different egress time criteria for different scenarios. Design teams and authorities having jurisdiction needs to dearly distinguish between performance criteria (allowed to vary according to scenario) and assumption (invariable across scenarios). COMMITTEE ACTION: Reject. COMMI'VI'EE STATEMENT: The Committee believes that the submitter has misunderstood the intent. The proposed wording is not needed. See Comment 101-78 (Log #CC14). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


GALLAGHER: I do not agree in full with the committee statement. The submitted has some valid concerns. Emergency procedures and the human elements can be represented in the criteria if they are part of the design to satisfy the objectives. The words "objectively measurable terms" is a better description than

"engineering terms". Not all design professionals understand what are "engineering terms", especially when it comes to the human elements of the design. However, they do understand what are "objectively measurable terms".


101- 77 - (3-1.7 Performance Criteria): Reject SUBMITTER: Norman E. Groner, Santa Cruz, CA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise proposed appendix as follows:

A-3.1.7 Performance Criteria. ~-:~nccr]=g Objectively measurable terms ~re derived firom data that is obieetiveiv verifiable, and include temperatures, radiant heat flux, ae, d- levels of exposure to fire products, movement times, and the existence of ¢lnergency procedures. Performance criteria provide threshold values which are treated as data for calculations used to develop a proposed design. Changes in Derformance criteria are permitted to vary across scenarios.-For examnle, the design team may need to establish higher levels of nrotection in resoonse to certain

SUBSTANTIATION: The expression "engineering terms" is deleted to avoid the implication that performance criteria are restricted to physical engineering methods. (Most code users will be unfamiliar with the term "human factors engineering" and its synonyms.) The fundamental feature of performance criteria is that they must be objectively measurable, regardless of whether the criteria refer to the performance of people or physical systems.

The revised wording explicitly permits the use of criterion measures of human and organizational performance as a means to ~oUrSue performance objectives. Establishing performance criteria

r emergency procedures is an important, and often essential, feature of performance-based design solutions. For example, a proposed design might provide 15 minutes (including a safety mar[gin) to evacuate an area in response to a scenario involving a fire m an unoccupied adjacent room. However, in response to a scenario involving an incendiary fire in an exit, the proposed design (including safety margin) can provide a longer time of 30 minutes to evacuate the same area. Therefore, the design team might want to establish performance criteria of 10 minutes to evacuate the area in response to one scenario and a different criteria of 20 minutes for the second scenario, keeping in mind that one egress route has been eliminated. The current wording can be interpreted as prohibiting the establishment of performance criteria for human performance. In the current wording, human performance is only covered in the section for assumptions. Since assumptions are not allowed to vary across scenarios, the current wording could easily be interpreted as prohibiting the setting of different egress time criteria for different scenarios. Design teams and authorities having jurisdiction need to clearly distinguish between performance criteria (allowed to vary according to scenario) and assumptions (invariable across scenarios). COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: The proposed text does not improve the material. See Comment 101-78 (Log #CC14). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12


101- 78 - (3.1.7 Performance Criteria): Accept SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise the definition of "Performance Criteria" in 3.1.7 to read:

(3-1.7) Performance Criteria.* Threshold values on measurement scales based on quantified performance objectives.

Create associated Appendix item as follows: A-3.1.7 Performance Criteria. Performance criteria are stated in

t~t.'anneering terms. Engineeering terms include temperatures, t heat flux, and levels of exposure to fire products.

Performance criteria provide threshold values used to evaluate a proposed design. SUBSTANTIATION: The revised definition clarifies intent. Additional material has been added to the advisory appendix, which would not be appropriate for the main definition.

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COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


GALLAGHER: I do not believe that this contains all the performance criteria that is necessary to satisfy the intent of this code. This sentence in the appendix should contain the words that are underl ined in the following sentence: "Engineering terms include, but are not limited to. temperatures, radiant flux, and levels of exposure to fire products." The criteria should also contain "engineering terms" or "objectively measurable terms" (see my Comment on Affirmative on Comment 101-76 (Log #214) for the human factors and the emergency and operational procedures that are required in the design. Additional criteria may need to be developed to adequately qualify the design and should be so stated in the provision and discussion that the authority having jurisdiction can require additional criteria as needed.


101- 79 - (3-1.7 Proposed Design): Accept in Principle SUBMITrER: Morgan J. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add the following as an Appendix note for 3-1.7 Proposed Design:

A-3-1.7 Proposed Design. The design team will develop a number of trim designs that will be evaluated to determine if they meet the performance criteria. One design will be selected from among those that meet the performance criteria for submission to the authority having jurisdiction as the proposed design. SUBSTANTIATION: The term "proposed" implies that the design is being submitted for approval. In fact, the design will not be submitted to the authority having jurisdiction for approval until after the design team is satisfied that it meets the performance criteria. Therefore, the term "trial design" is proposed to differentiate between designs being developed and evaluated by the design team and the design submitted to the authority having jurisdiction for approval. Also, this change would harmonize with the terminology used in the SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design. COMMITTEE ACTION: Accept in Principle.

[ Add the following as an Appendix note for 3-1.7 Proposed [ Design: ] A-3-1.7 Proposed Design. The design team may develop a ] number of trial designs that will be evaluated to determine if they ] meet the performance criteria. One of the trial desil~ns will be I selected from those that meet the performance criteria for ] submission to the authority having jurisdiction as the proposed I design.

COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: Appendix sentence should be modified to read:

"that meet the performance goals, objectives, criteria, and scenarios submission to the authority having jurisdiction".


101- 80 - (3-1.7 Proposed Design (New)): Accept in Principle SUBMITTER: Norman E. Groner, Santa Cruz, CA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add new appendix text:

A-3-1.7 Pronosed Desiwn. The nronosed design is not necessarily limited to fire nrotect ion hardware and buildin~ features, but also includes any comnonent of the nronosed desit,~ that is installed. ¢~tablished. or maintained for ~ e vumose of]fie safety, without which the nronosed design could fail to achieve specified nerformance criteria. As such. the vrovosed desima often includes emergency nrocedure.~ and orwaniT~fionai structur-es that arc u~eded ~9 meet the performance criteria snecified for th¢ proposed

SUBSTANTIATION: The appendix note is needed to clarify that the scope of a proposed design is not necessarily restricted to physical components, but may also include emergency procedures or other aspects of human and organizational performance. If this proposal is accepted, the submitter also suggests that the Technical Committee edit t hep roposed Chapter 3 to replace several uses of the term "building design" with "proposed design." This will help ensure that design teams do not feel compelled to restrict their considerations to hardware and building features, and but may also include emergency procedures as part of the proposed design. COMMITrEE ACTION: Accept in Principle.

Add the following as a s e c o n d p a r ~ a p h to the new appendix note being added by the Committee Acuon on Comment 101-79 (Log #180).

"The proposed design is not necessarily limited to fire protection systems and building features, but also includes any component of the proposed design that is installed, established, or maintained for the purpose of life safety, without which the proposed design could fail to achieve specified performance criteria. As such, the proposed design often includes emergency procedures and organizational structures that are needed to meet the performance criteria specified for the proposed design." COMMIIq'EE STATEMENT: The Committee Action should meet the submit~er's intent. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


WOODWARD: This may also be appropriate to put as an appendix note at 3-4.2.2 or to provide a cross reference to it at that location.

Committee:(LS°£# 101- 81 - (3-1.7 Radiant Heat Flux (New)): Reject SUBMITTER= George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In new 3-1.7, provide a definition for the term "Radiant Heat Flux" as used in A-3-1.7 Performance Criteria or place it in A-3-1.7. SUBSTANTIATION: I want to be clear on what the committee means regarding "radiant heat flux" as used in A-3-1.7. The term "critical radiant flux" is defined in existing Chapter $ for use with provisions in Chapter 6. It would seem helpful to define "radiant heat flux" as used in the new provisions of the Code to avoid confusion. The more definitions of terms used in Chapter 3 and its appendix the better for most authorities having jurisdiction. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: It is not necessary to define an item that appears as part of the list that begins with the word "includes". For example, the document will not define the term "temperature". NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


GALLAGHER: I sympathize with the submitter. Since performance codes is a new topic, there is not total agreement upon terms and definitions. There are different terms used for the same concepts. This is another reason to delay this Chapter 3 for the next revision cycle. This comment substantiates that the technology and engineering methods, terms and definitions have not all been fully developed to support this performance option for both the design and the review.


101-82 - (3-1.7 Rate of Hazard Development (New)): Reject SUBMITTER: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In new 3-1.7, provide a definition for the term "Rate of Hazard Development" as used in 3-4.2.2, unless this is intended to refer to the term "rate of growth in fire severity" as used in A-3-5. SUBSTANTIATION: I want to be clear on what the committee means regarding "rate of hazard developmenC. The more definitions of terms used in Chapter 3 and its appendix the better for most authorities having jurisdiction. COMMITrEE ACTION: Reject.

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COMMITrEE STATEMENT: The expression is self-explanatory and further clarification is not needed. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


GALLAGHER: I sympathize with the submitter. Since performance codes is a new topic, there is not total agreement upon terms and definitions. There are different terms used for the same concepts. This is another reason to delay this Chapter 3 for the next revision cycle. This comment substantiates that the technology and engineering methods, terms and definitions have not all been fully developed to support this performance option for both the design and the review.


101- 83 - (3-1.7 Trial Design (New)): Reject SUBMITI'ER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101d2 RECOMMENDATION: Add a new definition of "Trial Design" to A-3-1.7 as follows:

Trial Design. A fire safety system design intended to achieve the stated fire safety goals and expressed in terms that make it possible to assess whether the fire safety goals have been achieved. SUBSTANTIATION: The term "proposed" implies that the design is being submitted for approval. In fact, the design will not be submitted to the authority having jurisdiction for approval until after the design team is satisfied that it meets the performance criteria. Therefore, the term ~trial des!gn" is proposed differentiate between designs being developed and evaluated by the design team and the design submitted to the authority havin~jurisdiction for approval. Also, this change would harmonize with the terminology used in the SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design.

Companion proposals to paragraphs A-1-9.2, A-3-1.7 (proposed design), $-1.7 (fire scenario), A-3-4.1, A-3-5 and .4.-3-7 suggest areas where the term "trial design" should be used. COMMITTEE ACTION: Reject. COMMIIq'EE STATEMENT: The definition of ~trial design" belongs in the SFPE Design Guide. A trial design is one of the preliminary, off-line steps taken by the designer prior to submitting a design to the authority having jurisdiction for approval. As such, it is not needed in the Life Safety Code. Also, see Comment 101-79 (Log #180). NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #392) Committee: SAL~'~'FU N

101- 84- (3-2): Reject SUBMI'VI'ER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Section $-2 needs more detail as to the technical requirements of the Code that must be met. More

measurable technical points that meets Life Safety of the de.

SUBSTANTIATION: The entire code is too vague with no clear understanding of the methods to be used to determine compliance. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has not recommended any specific text. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTER ACTION:


EXPLANATION OF NEGATIVE: GAIA~GHER: The committee statement illustrates my point,

that not all the details and technology have been developed, nor have all the decisions been made for this performance option to be usable and enforceable. I have not found all the technology data, engineering methods and code provisions sufficient to address all my concerns as an authority having jurisdiction reviewer to require of the design professionals.

(Log #117) Committee: SAF-MER

101- 85 - ($-2 Covered Mall Building): Accept in Part SUBMITTER: James P,. Quiter RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-736 RECOMMENDATION: 1. Add a sentence to the proposed appendix material on the definition of Covered Mall Building so that it reads:

A-$-2 Covered Mall Building. Covered mall buildings are occupied primarily by mercantile occupancies, however, may indude other occupancies s u c h as drinking and dining establishments, entertainment and amusement facilities, offices, and similar uses which are incidental to the primary use of the building. It is intended that the nhrase ~occuvied vrimarilv by mercantile occupancies ~ be interoreted to mean that not less than half of the ~ross leasable area ((;LA~ is for mercantile use.

2. Move the definition of Covered Mall from 24-1.3 and 25-1.3 to Section 3-2 so as to read:

3-2 Covered Mall. A covered of roofed interior area used as a vedestrian way and connected to a building(s) or nortious of a Ipuilding housing single or multinle tenants. SUBSTANTIATION: I served as Chair of the Life Safety Covered Malls Task Group that was convened by the Technical Correlating Committee on Safety to Life. Task group participants, and the life safety technical committees represented by the participants, at the December 1998 meeting included myself--Jim Quiter (SAF-AAC), Jim Antell ($AF-HEA), Carl Baldassarra (SAF-RF_S), Greg Miller (SAF-AXM), Ed Schultz (SAF-MER), Cathy Stashak (SAF-END), Greg Thomas (SAF-IND), and Bill Hiotaky (former chair of SAF- MER). This proposal was drafted by the task group.

Item (1) in the above recommendation. The new term - ~occupied primarily by mercantile occupancies ~ - that is being addedby the action on Proposal 101-736needs further clarification. The task group consensus is that not more than half of the gross leasable area should be used by occupancies other than mercantile. At more than 50 percent use by occupancies other than mercantile, the mercantile presence becomes minor.

RE: Item (2) in the above recommendation. The definitions of both "Covered Mall" and "Covered Mall Building" should be kept together in one place for ease of use. COMMFITEE ACTION: Accept in Part.

Accept part two of this comment on the definition of covered mall.

3-2 Covered Mall. A covered or roofed interior area used as a nedestrian way and connected to a buildin~(sl or nortions of a buildin~ housin~ single or multiDle tenant~ COMMITTEE STATEMENT: The Committee did not accept the first part of this comment as they are not satisfied that the specified percentage would effectively address the issue. The committee had debated this issue during the ROP stage and finally accepted the term "primarily ~ as an acceptable darification of how the current application of covered mall building is viewed and applied. The submitter of this comment did not provide adequate justification as to why this particular percentage should be used. The committee also believes even though this statement is located in the appendix that it will be applied. I f this percentage is applied on existing facilities then it is possible that a facility could be treated as not being in compliance. It should also be noted that the applicable provisions of other occupancy chapters apply if they are found within a cover mall building and this proposed revision does not add any additional clarification. It is also the understanding of this technical committee that there may be further study done by the Life Safety Covered Malls Task Group which may address this issue. NUMBER OF COMMITlrEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 17 NOT RETURNED: 2 Holmes, Moon

(Log #5) Committee: SAF-FUR

101- 86 - (3-2 Critical Radiant Flux): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-28 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUR reconsider its action so as to make the material being moved to the appendix read as full sentences. Currently, the wording of the first "sentence" is only a phrase. SUBSTANTIATION: See the above recommendation.

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N F P A 101 ~ F9 9 R O C

COMMITI'EE ACTION: Accept in Principle. I egin the new al~)pendix language with:

"The critical radiant flux is the property determined by the test procedure... ". COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 13 NOT RETURNED: 2 Hogan, Lingenfelter

(Log #$09) Committee: SAF-IND

101- 87- (3-2 High Hazard Industrial Occupanc]t): TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC), for correlation purposes, directs that the action on this comment be changed so that the definition reads: ~High Hazard Industrial Occupancy.* Industrial operations having high hazard materials, processes, or contents. ~

Further, add the following as a new third sentence of 28-1.1: aIncidental high hazard operations protected in accordance with

Section 6-4 and 28-3.2 in occupancies containing low or ordinary hazard contents shall not be the basis for high hazard industrial occupancy classification. ~ SUBMITTER: James 1L Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-801 RECOMMENDATION: Revise the definition of High Hazard Industrial Occupancy in 3-2 as follows:

High Hazard Industrial Occupancy.* Includes buildings having high hazard materials, processes, or contents. Incidental ~ high hazard operations in occupancies containing low or ordinary

^_~d. 2~ ~.2 shall not be the basis for high hazard industrial occupancy c.;'zrz2! c.cz:Fa=~c 7 classification. SUBSTANTIATION: Eliminates reference to section in the definition and properlyrefers to low or ordinary hazard contents. COMMITTEE ACTION: Accept in Principle.

Revise the definition for High Hazard Industrial Occupancy to read:

High Hazard Industrial Occupancy.* Indudes buildings having high hazard materials, processes, or contents. Incidental h igh hazard operations protected in accordance with Section 4-0.6-4 and 28-$.2 in Occupancies containing low or ordinary . . . . . . . . -: . . . . "~ shall not be the basis for high hazard industrial Occupancy c.;'cr~2I c.cc~:F~'zc 7 classification. COMMITTEE STATEMENT: The recommendation introduces the term ~protected" without establishing the criteria needed to define what a ~protected high hazard operation ~ is. The revised text still uses the term protected but it establishes the acceptable criteria in defining what is considered a "protected high hazard operation" by referencing 6-4 and 28-3.2. The current reference to 4-2 was revised to provide a direct reference to the special hazard protection of 6-4. It is noted that currendy 4-2.1.3 provided a reference to 6-4 but it was found in the exception. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:


(Log #6) Committee: SAF-MEA

101- 88 - (3-2 Level of Exit Discharge (New)): Accept in Principle SUBMITFER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: The Technical Correlating on Safety to Life (SAF-AAC) requests that SAF-MEA evaluate the merits of the recommendation prepared by SAF-END in Proposal 101-51 and revise its action on Proposal 101-50 as needed. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Principle.

Retain the TCC's rejection of Proposal 101-51. COMMITTEE STATEMENT: The words ~without vertical travel" create additional problems. The action on Proposal 101-51 is adequate. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 NOT RETURNED: 1 Paolucci


101- 89 - ($-2 Level of Exit Discharge (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-48 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA evaluate the merits of the recommendat ionprepared by SAF-MER in Proposal 101-48 and revise its action on Proposal 101-50 as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

To Section 3-2 add a definition of Level of Exit Discharge to read: Level of Exit Discharge. A story from which at least 50 percent of

the required number exits and at least 50 percent of the required egress capacity from that story discharge directly outside at grade

Where, due to differences in grade t¢~elsr two or more stories meet the criteria of this definition, the lower story is the level of exit discharge. Where no such story meets the criteria of this definition, the level of exit discharge is that story with the smallest elevation change needed to reach thegrade levek. COMMITTEE STATEMENT: The Committee agrees with the substantiation presented in Proposal 101-48. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:


(Log #CC103) Committee: SAF-FIR

101- 90 - (3-2 Smoke Partition): Accept SUBMITI'ER: Technical Committee on Fire Protection Features COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Add a new definition and an appendix note that read:

(3-2) Smoke Partition*. A continuous membrane that is designed to form a barrier to limit the transfer of smoke.

A-3-2 Smoke Partition. A smoke partition is not required to have a fir e resistance rating. SUBSTANTIATION: The definition was added for darification Pdurposes. The term "smoke partition" is a new term that was

eveloped in conjunction with the committee-generated Proposal 101-290 as found in the 1999 November ROP and the related comments received: Comments 101-258 (Log #414), 101-259 (Log #39) and 101-264 (Log #$56). COMMrITEE ACTION: Accept. NUMBER OF COMMITI'EE MFaMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMIq[q'EE ACTION:

AFFIRMATIVE: 24 NOT RETURNED: 3 Holmes, Jilg, King


101- 91 - (3-2.1): Accept in Principle SUBMITEER: Jonas L. Morehart , Punta Gorda, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

"...move, or be moved to...". SUBSTANTIATION: In facilities with persons who are unable to egress without assistance, such as hospitals, staff assistance is required to complete the movement

Appendix may need similar rewording. COMMITTEE ACTION: Accept in Pnnciple.

See Comment 101-94 (Log #182). COMMITTEE STATEMENT: The action on the referenced Comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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N F P A 101 - - F9 9 R O C

(Log #217) Commit tee : SAF-FUN

101- 92 - ($-2.1): Reject SUBMn1"ER: N o r m a n E. Grone r , Santa Cruz, CA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

3-2.1" General Pe r fo rmance Cri ter ion. A des ign shall mee t the objectives specified in Section 1-6 if, for each specified fire scenar io a n d the specif ied assumpt ions , each occupant ' s calculated t ime to mc.;'z t.n =+ -~rc !-v.~+2v.n n ro tec t ion f rom nroduc t s of combus t ion is less t han tha t occupant ' s t ime to incapacitat ion, as calculated in 3- 2.2. Addit ional ne r fo rmance criteria shall be soecifled wherever pVaCt, i¢~ fop individual products , systems, assemblies, emer~encv nrocedures , or areas tha t contr ibute to the realization of the genera l n e r f o r m a n c e criterion. SUBST.~ITIATION: First, the wording has been revised to avoid the implicat ion that mov ing people is the only acceptable as a m e a n s for pro tec t ing t h e m f rom produc t s of combust ion . In m a n y instances, the bet ter life safety strategy involves keep ing certain bu i ld ing occupants in-place, e i ther because thei r m o v e m e n t would interfere with the safety of o ther m o r e endange red occupants or because they can be better pro tec ted where they are.

Second, the revised wording makes it clear tha t occupants ' t imes to incapaci ta t ion is no t the only pe r fo rmance criteria tha t needs to be specified. Rather, it is only the mos t general of pe r fo rmance criteria. Addit ional m o r e specific pe r fo rmance criteria n e e d to be explicitly identif ied as the m e a n s by which the design team in tends to pu r sue this genera l goal.

Third , the proposal also re fe rences "emergency procedures" as an example of more specific pe r fo rmance to ensure tha t users may choose to inc lude aspects of h u m a n a n d organizat ional Pcerformance as par t of t he p roposed design.

OMMITTEE ACTION: Reject. COMMITTEE STATEMENT: T he proposed language does no t improve the documen t . An addi t ional level o f pe r fo rmance criteria is n o t necessary. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON C O M M I T T E E ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: I disagree with the commi t t ee ' s s ta tement . I do

no t beiieve the criteria as stated in the code is adequa te to complete ly evaluate the safety o f a p roposed des ign accord ing to the Life Safety Code.

(Log #344) Commit tee : SAF-FU N

101- 93- (3-2.1): Reject S U B M I T T E ~ James R. Qui ter , R o l f J e n s e n & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add a second sen tence as follows:

"A factor of safety, as approved by the author i ty having jur isdict ion, shall be inc luded in this calculation." S U B S T A N T I A T I O N : As cur rendy worded, the sect ion implies that, as long as the pe r son has escaped before be ing incapacitated, we have me t the pe r fo rmance criteria. The re are two flaws with this implicat ion:

1. The calculations are no t exact. T hey conta in some level of uncertainty.

2. An occupan t could be exposed to smoke inhala t ion or excess hea t pr ior to b e c o m i n g incapacitated. This shou ld n o t be cons idered universally acceptable. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: T h e subject is adequate ly covered by 3-8.1. It is possible to at tach a safety factor to any i tem. Therefore , it is dange rous to single ou t - in one place - a r e q u i r e m e n t that a factor o f safety be appl ied yet r ema in si lent in o ther instances. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 V O T E ON COMMITTEE ACTION:


GALLAGHER: Section $-8.1 is now $-7.1 in the commi t t ee ' s s ta tement . I agree in principle with the commit tee ' s s ta tement , bu t I disagree with the use of the t e rm "safety factor" anywhere in the code. Since the code does n o t detail how to establish the level o f safety of a design, it c anno t establish the use of an addi t ional level of the same unde f ined t e rm- - sa fe ty factor. No realistic concept for safety factor has been developed as a safety factor in the ' p e r fo rmance opt ion of this code. T h e te rm has no m e a n i n g bu t to

deceive the public tha t such a concep t does exist, whe n in fact it is undef inab le in the p resen t state of technology and eng ineer ing m e t h o d s available.


101- 94 - (3-2.1, $-2.2, 3-2.3, a n d 3-2.5): Accept in P r indp le SUBMITTER: Morgan J. Hurley, Society of Fire P ro t ecuon Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

3-2.1" General. A des ign shall mee t the objectives specified in Section 1-6 if, for each specified fire scenario, a s sumpt ion an d

tha t c=='_'pant': +".='me +:v :nc=p==:./," "~ ~ c-~2~'='-:'!==~ ~..~ ~ 2.2. the oe r fo rmance criteria in 3-2.2 are met .

of t ime ~n uhc "nz~nw-'=¢~'.:: =n~ cu:r.'-'!=~-'= exF.~:'.='r~ ~f e=ch

3-2.2* Performance Criteria. T 'mc t~ !n:at==c':=~c.-=. For each design fir{ pt;~nari9 and the des ign snecifications, condi t ions an0, a~ l /mpt ions , the desim~ t eam shall demons t r a t e tha t each r o o m or area shall be fully evacuated before the onse t of un tenab le condi t ions . T~..c "2=r.: :~. "n..'~Fa~w.*2~=~ f~r a n ~:c~=Fant :~z]! ~c

S~m.a.~.-~ Te'ot +~.{:+-+~.cJ for Dc;'zlc#:=.g T=--c P ; t z n c y ~---: f ; ; U ; : ":a .~ .c H~---~ard M^.d.acl'n-.

A-3-2.2 One o~ the following m e t h o d s shou ld be used to avoid exnos in+ occuoants to un tenab le condit ions: Thc cu~c: : : , !995 edid~n ~f N.m..-A 2~0, S-'-----:dm.-d Toot Mc~c .d ft.: ~cvclop'==+ T+::ic

1. The des ign team could set detai led pe r [o rmance criteria tha,~ would ensure tha t occuoants are no t incanaci ta ted bv fire effects. The SFPE En~ineer in~ Guide to Performance-Based Analysis and Design descrilaes a Drocess of establishin~ tenabili ty limits.

2. For each des ien fire scenario a n d the des ign snecifications. condi t ions and assumnt ions , the des ign t eam coul(l demons t r a t e tha t each r o o m or a rea shall be fully evacuated before the smok~ and toxic ~as laver in tha t r o o m descends to a level lower t h a n ~ ft (1.8 m] above the floor. This will reouire tha t no occunan t be exnosed to fire effects. It renuires calculation of t~h¢ 19~i~igns. movemen t , a n d behavior of occunants , because it keens fire effects and occunants senara te by movin~ t h e occunants . A level of 5 ft (1.5 m! is of ten used in calculations, b u t with tha t level, a large fraction of the nonu la t ion would no t be able to stand, walk. or r u n ~0rmally a n d still-avoid inhala t ion of toxic ~rases. Thev would have [9 b e n d over or otherwise move their heads closer to the floor

~. For each desi~m fire scenario a n d the desi~,n soecifications a n d assumpt ions , the tlesi~a t eam could demons t r a t e t.b~t t.h¢ smoke and toxic ~as laver will no t descend to a level lower than 6 ft (1.8 m! above the floor in any occun ied room. T h e advantage of this n rocedure is tha t it conservatively reoui res tha t no occunan t n e e d be exnosed to fire effects, re~,ardless of where occunants are or where they move. This removes the n e e d to make any calculations rewarding occuoants , inc lud ing thei r behavior, m o v e m e n t locations, ore-fire characteristics, a n d react ions to fire effects. This i~ even m o r e conservative and s imnler t han the p rocgdure in #9. because it does no t allow fire effects in occun ied rooms to develon to a n o i n t where oeoole could be affected even after there are n o people p resen t to be affected.

4. For each design fire scenario a n d the des ign spgcification~ a n d assumnt ions , the desi~,n team could demons t r a t e tha t no fire effects will reach any occuoied room. The advantage of this n rocedure is

93

N F P A 1 0 1 - - F 9 9 R O C

that it removes the need to make any calculations rei_,arding occunants, including their behaviorl movement, locations, nre-fire characteristics, and reactions to fire effects. A further advat~taee is that is also removes the need for some of the modeline of fire effects, because it is not necessary to model the filling-of rooms. only ~ snread of fire effects to daose rooms. This is even more conservative and simnler than the nrocedures in #2 and #3. because it does not allow any fire effects in occupied rooms.

~ . . . . . j . . . . . . . . . . . . . . . . . . . . . . . . j . . . . . . . . . . . . . . . . . . . . . . .

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A p r o p o : ^" to 3~.~.. ~ . :':o'.:'l~ :r¢^Xc = :+~.--~a-.~d fo r : u c h

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conf idence "= @.e : : proccd 'are=. !t := e x p e c * ~ *&at ~ ' te r=z@:e

or area i0 --...2'c',:!:t:~ to 5c fu!! 7 :'.'=c'==tcd '-.~=fcrc "&c : r o o k : ^-rid told .... ' . . . . . :_ .t. ...... ..1 ..... a .... ,_..^, , ....... t.^_ ~ c. ~ ,~ o

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..... : ......... -_~+.

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spe-f ied fire =ce.n~!= "-~".d "_he =pe=:.fied ===u..'n.p'_:=n=, =o fire aft=c= . . . . . . . . . . . :..~ .... "r~.. -a . . . . . . . ~.f th'= proc=durc "= .... rcach =n 7 . . . . v .................... "~o~

that h =2=~ rcm~'.'~ ~ e == :~ f~r =~m: =f ~ = ...::.:~.u.==g =£ fi:'e

^ ~ 1 . , ; I . . . . . . . . . i ^6 " ~ - - - - - - ~ ^ ~ . . ^ +1. , . . . . . . . .

"q'Z:7"." : ~ : Z - = , Z : Z I T , 2 . = Z L : : = 227:,-L"C-. ",. . . . . . . , . ^ . - _2dTLCZ~ ' -Z -ZTZ2 "J ~ Z - L ' Z - £ 1 ^ - - Z . - ' 2 T Z ' . - ~ D Z ~ : ZTC'-7. .-:~. ,

SUBSTANTIATION: I. The use of NFPA 269 as the basis for

rformance is outside of the scope and purpose of NFPA 269. 269 is intended to "provide a means for assessing the lethal

toxic potency of combustion products produced from a material or ~lrOduct ...% not to assess the performance of building designs.

ost compartments will contain a myriad of products (furnishings, linings, floor coverings, transient items, etc..), and NFPA 269 does not address how to consider multiple products simultaneously.

2. Theoretically, the effects from multiple products could be considered by adding the "partial" FED from each product in a room. However, this would require individual mass losses from each product (as a function of time) which could not be predicted with any semblance of certainty. Coupled with the inherent uncertainty in the NFPA 269 approach (see 3-1.4) this is a very unreliable and non-robust approach.

$. Tenability analyses are only used in a limited number of cases, for example in atria designs. However, for many types of scenarios, there are no fire models available that predict toxic species production with the required degree o f accuracy. Full scale testing, addressed by A-12-2.3, is not a cost effective design tool.

4. The test method in NFPA 269 does not consider the effects of aging or smoke transport (See 3-1.6), while it specifically mentions that "most fire deaths due to smoke inhalation in the U.S. occur in areas other than the room of origin..." (3-1.2)

5. The fractional effective dose is a measure of lethal toxic potency, and does not consider incapacitation. (See NFPA 269, paragraapJh 3-1.8) . .

Therefore, other analyses methods should be pertained and gwen the same "weight" in the code as conducting a tenabiiffy analysis. In this comment, the "alternative" methods in the appendix of Proposal 101-12 are proposed to be given equal footing to the option of setting tenability limits.

For the cases where conducting a tenability analysis is appropriate, NFPA 269 should not be referenced as the for the reasons cited in # 1, 2 and 5 above. A more rational approach would be to provide reference to a document that addresses setting tenability analysis, a process for which can be found in the SFPE Engineering Guide to Performance-Based Analysis and Design. COMMITTEE ACTION: Accept in Principle.

Replace Section ~-2 and its appendix, in total, with the following: Section 3-2 Performance Criteria. 3-2.1 General. A design shall meet the objectives specified in

Section 1-6 if, for each spedfied fire scenario, assumption and design specification, the performance criterion in 3-2.2 is met.

8-2.2* Performance Criterion. No occupant not intimate with ignition shall be exposed to instantaneous or cummulative untenable conditions.

A-3-2.2 One of the following methods can be used to avoid exposing occupants to untenable conditions: 1. The design team could set detailed performance criteria that

would ensure that occupants are not incapacitated by fire effects. The SFPE Engineering Guide to Performance-Based Analysis and Design describes a process of establishing tenability limits.

2. For each design fire scenario and the design specifications, conditions and assumptions, the design team could demonstrate that each room or area shall be fully evacuated before the smoke and toxic gas layer in that room descends to a level lower than 6 ft (1.8 m) above the floor. This will require that no occupant be exposed to fire effects. It requires calculation of the locations, movement, and behavior of occupants, because it keeps fire effects and occupants separate by moving the occupants. A level of 5 ft (1.5 m) is often used in calculations, but with that level, a large fraction of the population would not be able to stand, walk, or run normally and still avoid inhalation of toxic gases. They would have to bend over or otherwise move their heads closer to the floor level.

3. For each design fire scenario and the design specifications and assumptions, the design team could demonstrate that the smoke and toxic gas layer will not descend to a level lower than 6 ft (1.8 m) above the floor in any occupied room. The advantage of this ~rocedure is that it conservatively requires that no occupant need

e exposed to fire effects, regardless of where occupants are or where they move. This removes the need to make any calculations regarding occupants, induding their behavior, movement

94

N F P A 101 - - F 9 9 R O C

4ocations, pre-fire characteristics, and reactions to fire effects. This is even more conservative and simpler than the procedure in #2, because it does not allow fire effects in occupied rooms to develop to a point where people could be affected even after there are no people present to be affected.

4. For each design fire scenario and the design specifications and assumptions, the design team could demonstrate that no fire effects will reach any occupied room. The advantage of this procedure is that it removes the need to make any calculations regarding occupants, including their behavior, movement, locations, pre-fire characteristics, and reactions to fire effects. A further advantage is that it also removes the need for some of the modeling of fire effects, because it is not necessary to model the filling of rooms, only the spread of fire effects to those rooms. This is even more conservative and simpler than the procedures in #2 and #$, because it does not allow any fire effects in occupied rooms. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMII~I'EE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: The appendix Note #1 should read: 'q 'he design

team and authority having jurisdiction should set detailed performance criteria...".


101- 95 - (3-2.2): Reject SUBM1T1T, R: Jonas L. Morehart, Punta Gorda, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: ~:evise text:

3-2.2* Time to Incapacitation. The time to incapacitation for an occupant shall be calculated as that occupant's time to reach the limits of survivable conditions as defined for quick rfspon~¢ p,~tomatic snrinlders, c. 'v . . . . :^__, 'E,.ta-^~.:..̂ r~^.^ tv~r~x ^r ~ n

r~^..^,^_:__ -r^..:_ pc.tcz.z 7 Date fc.r Uzc "n .~rz Hzz:.-5 .~?.cSc!':~g Exception: Adjustments as specified in 3-2.3.

SUBSTANTIATION: The following fire gases: hydrogen cyanide, hydrogen chloride, hydrogen bromide, and anoxia effects; have not been shown, either in full scale tests or studies of actual fire deaths, to be a definition of survivable conditions, COMMITTEE ACTION: Reject. COMMITYEE STATEMENT: The suggested language is not needed. See the Committee Action on Comment 101-94 (Log #182). NUMBER OF COMMITTEE MI~BERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 96 - (5.2.2): .Reject SUBMITTER: Jonas L. Morehart, Punta Gorda, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

A-5.2.2 The cu~cz.t, !995 ea-":e~ ef.~.r.m2A 2~9, C,n~a~..~ "r~.,

survivable conditions which have been established during full scale testing of quick response automatic sprinklers are:

1. Maximum gas temperature at eye level of 200°F (gB°C). 2. Maximum ceiling surface temperature of 500°F (260°C). $. Maximum carbon monoxide concentration of 1,500 parts per

million. SUBSTANTIATION: Fire gases such as hydrogen cyanide, hydrogen chloride, hydrogen bromide, and anoxia effects; have not

een shown, either in full scale tests or studies of actual fire deaths, to be a definition of survivable conditions. Realistic full scale testing has shown that survivable conditions are primarily limited

y c t ~ e s at eye level for a typical, standing person. ACTION: Reject.

COMMITTEE STATEMENT: The submitter's suggested alternative criteria are not more soundly based than that originally proposed.

NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

12


101- 97- (3-2.2): Accept in Principle SUBMITFER= Gordon E. Hartzell, Hartzell Consulting, Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Recommend deletion of Section 5.2.2 on Time to Incapacitation. SUBSTANTIATION: By definition in NFPA 269, a Fractional Effective Dose (FED) of 1.0 corresponds to 50 percent ~ o f rats in a test method. The time to reach an FED of 1.0 would, therefore, estimate time to death, not time to incapacitation. NFPA 269 does not address incapacitation at all. Works are in

~ ro~ress in ASTM and ISO to do so, however, in the meantime, ecuon 5.2.2 and reference to it in 5.2.1 should deleted.

COMMITTEE ACTION: Accept in Principle. See Comment 101-99 (Log #CC6) which moves FED discussion to

the appendix and revises suggested threshold values. COMMITTEE STATEMENT: The referenced Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12


101- 98 - (3-2.2): Accept in Principle SUBMITTER: Richard G. Gann, U.S. Dept. of Commerce, NIST COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: I request that the appropriate NFPA 101 committee revisit and revise this section accordingly. The value, about 0.8, should be indicated first in Section $-2. SUBSTANTIATION: I am disturbed by the application of NFPA 269 in NFPA 101, Section 3-2.2.

An FED ffi 1.0 determined using NFPA 269 is related to the exposure that would lead to the survival of half of the people. It is possible to use the test data, combined with laboratory experience, to estimate what FED just related to an e~posure that would lead to the survival of, say, virtually all of the people. This value, about 0.8, should be indicated first in Section 5.2.

There is a summary of literature on the relationship between exposures leadingto death and those leading to incapacitation [Kapla,n et al.,J. Fire Sci. 2 286-$05 (1984)]. They found that rodents susceptibility is similar to human's and that for the wircotic gases (CO and HCN), incapacitation occurs at one third to one half of the lethal exposure. Carbon monoxide dominates the lethality of fire smoke, since most U.S. fire deaths occur remote from the fire room from fires that have proceeded past flashover [Gann et ai., Fire and Materials, 18 193 (1994)]. Thus, were an FED value of'0.8 used for a non-lethal exposure, an FED of 0.3 would be reasonable for a non-incapacitating exposure. C O ~ ACTION: Accept in Prindple.

See Comment 101-99 (Log #CC6) which expands the appendix material to include much of the information provided in the submitter's substantiation. COMMITIT, E STATEMENT: The referenced Committee Action should satisfy the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

C (Log #CC6)

ommittee: SAF-FUN 101- 99 - (3-2.2): Accept SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In the appendix material that accompanies $-2.2, add the following after subparagraph (1), but before subparagraph (2):

The guide references D. A. Purser, "Toxicity Assessment of Combustion Products," Chapter 2-8, The SFPE Handbook of Fire Protection Engineering, National Fire Protection Association, Quincy, MA, 1995, which describes a Fractional Effective Dose

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N F P A 101 - - F 9 9 R O C

(FED) calculation approach also contained in the 1996 edition of NFPA 269, Standard Test Method for Developing Toxic Potency Data for Use in Fire Hazard Modeling. FED addresses carbon monoxide, hydrogen cyanide, carbondioxide, hydrogen chloride, hydrogen bromide, and anoxia effects. It is possible to use the test data, combined with laboratory experience, to estimate what FED would lead to the survival of virtually all people. This value is about 0.8.

There is a relationship between exposures leading to death and those leading to incapacitation. Kaplan [Kaplan et al., Journal of Fire Science, 2 286-305 (1984)] found that rodent susceptibility is similar to human and that for the narcotic gases (CO and HCN), incapacitation occurs at one-third to one-half of the lethal exposure. Gann [ G a n n e t al., Fire and Materials, 18 193 (1994)] found that carbon monoxide dominates the lethality of fire smoke, since most fire deaths occur remote from the fire room from fires that have proceeded past flasbover. Thus, were an FED value of 0.8 used for a non-lethal exposure, an FED of 0.3 would be reasonable

f o r a non-incapacitating exposure. I If the authority having jurisdiction or the design professional is concerned with potential toxic fire effects other than those addressed by the FED procedure as documented, then the calculation procedure can be expanded by adding additional terms to the Fractional Effective Dose (FED) equation, each term having

i the form of a ratio. The numerator of the ratio is the cumulative exposure to that fire effect, measured as an integral of the product of instantaneous exposure (concentration for toxic products) and time. The denominator of the ratio is the quantity of cumulative exposure for which FED equals the chosen threshold value (e.g., 0.8 or 0.3) based on that fire effect alone.

ASTM is actively considering standards that would extend the list of toxic fire effects with standard values.

If the authority having jurisdiction or the design professional is concerned with potential fire effects other than toxicity, then the calculation procedure can be modified to include other fire effects, such as thermal effects.

For buildings where an unusually large fraction of the occupants will be expecially vulnerable, the calculation procedure should be modified to use FED values lower than those cited above. SUBSTANTIATION: The expanded appendix material is necessary to support the Committee Action taken on Comment 101-94 (Log #182). COMMITTEE ACTION: Accept. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12


101- 100 - (3-2.2 and 3-2.3): Accept in Principle SUBMITTER: DanielJ. O'Connor, Schirmer Engineering Corp. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete 3-2.2 and 3-2.3. SUBSTANTIATION: These sections of the newly proposed chapter are prescribing the FED method as the single most appropriate method o f determining time to incapacitation. There are many other approaches and acceptable methods that can be used which may not even require that incapacitation be considered. These proposed sections prescribe a narrow approach and are not amenable to wide variety of approaches that could be applied. This seems to diminish the performance approach concept put forth by this chapter. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-94 (Log #182). COMMITTEE STATEMENT: The replacement material being added by the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #183)- Committee: SAF-FUN

101- 101 - (3-2.4): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) notes that the subject text will appear not as A-3-2.4, but as A-3-8.2 based on the action on Comment 101-94 (Log #182) which deletes the remainder of the 3-2's. See also Comment 101-103 (Log #361). This can be seen in the draft of the performance-based option chapter that follows Comment 101-161 (Log #CC8). SUBMITTER~ MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace A-3-2.4 with the following:

A-3-2.4 The sources, methodologies and data used in performance-based designs should be based on technical references that are widely accepted and utilized by the appropriate professions and professional groups. This acceptance is often based on documents, which are developed, reviewed and validated under one the following processes:

(a) Standards developed under an open consensus process conducted by recognized professional societies, codes or standards organizations, or governmental bodies.

(b) Technical references that are subject to a peer review process, and are published in widely recognized peer-reviewed journals, conference reports or other publications.

(c) Resource publications such as The SFPE Handbook of Fire Protection Engineering which are widely recognized technical sources of information. The following factors are helpful in determining the acceptability of the individual method or source:

(a) Extent of general acceptance in the relevant professional community. Indications of this acceptance include peer-reviewed publication, widespread citation in the technical literature, and adoption by or within a consensus docum~ent.

(b ) Extent of documentation of the method, including the analytical method itself, assumptions, scope, limitations, data sources and data reduction methods.

(c) Extent of validation and analysis of uncertainties. This includes comparison of the overall method with experimental data to estimate error rates as well as analysis of the uncertainties of input data, uncertainties and limitations in the analytical method, and uncertainties in the associated performance criteria.

(d) Extent to which the method is based on sound scientific pr inciples .

(e) Extent to which the proposed application is within the stated scope and limitations of the supporting information, including the range of applicability for which there is documented validation. Factors such as spatial dimensions, occupant characteristics,

I ambient conditions, etc., may limit valid applications. In many cases, a method will be built from, and include

numerous component analyses. These component analyses should be evaluated using the same factors as are applied to the overall method as outlined above.

A method to address a specific fire safety issue, within documented limitations or validation regimes, may not exist. In such a case, sources and calculation methods can be used outside of their limitations provided the design team recognizes the limitations and addresses the resulting implications.

The technical references and methodologies to be used in a performance-based design should be closely evaluated by the design team and the authority having jurisdiction, and possibly by a third party reviewer. The strength o f the technical justification should be judged using criteria listed above. This justification may be strengthened by the presence of data obtained from fire testing. SUBSTANTIATION: Stating that there is a hierarchy associated with the strength of technical review of references is not appropriate. This hierarchy could lead authorities having jurisdiction to require references from the top level in the hierarchy, and not accept anything less.

Also, the hierarchy stated in the ROP would not necessarily bold true in all cases. A consensus standard may have increased potential for technical review, but this review may not take place in all instances. Similarly, a laboratory report may receive significant review prior to release from the laboratory's staff and management.

Lastly, the level of "technical review" is not necessarily proportional to accuracy in all cases.

For these reasons, it is not appropriate to list a hard-and-fast hierarchy. Instead, it is appropriate to list the factors that should be considered in evaluating the applicability of a reference.

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COMMITTEE ACTION: Accept in Principle. I Do what the submitter requests. Additionally, add the word "of"

in the second sentence so as to read: "...reviewed and validated under one of the following

processes. .f . COMMITTEE STATEMENT: The Committee Action does what the submitter requests and additionally makes one editorial correction. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 102- (3-2.4): Accept in Principle SUBMITI'ER: Carol A. Caldwell, Caldwell Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise appendix A-3-2.4 Independent Review, Paragraph 3 to read:

"Handbooks and guides of the Society of Fire Protection Engineers and official design guides of other countries have the greatest official recognition by groups recognized as expert in the elements of performance-based design, ~cc~ad ~a!)" :~ c~-qzc~"u~

SUBSTANTIATION: Consensus standards are not necessarily better then Handbooks etc. Each source of information needs to be considered on its own merits. The development and review of consensus standards is not necessarily scientifically rigorous. It is appropriate to delete the inference that consensus standards are better. COMMITTEE ACTION: Accept in Principle.

See Comment 101-101 (Log #183). COMMITTEE STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 103- (3-2.4): Accept TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) notes that the subject text will appear not as 3-2.4, but as 3-8.2 based on the action on Comment 101-94 (Log #182) which deletes the remainder of the 3-2's. See also Comment 101- 101 (Log #183). This can be seen in the draft of the performance- based option chapter that follows Comment 101-161 (Log #CC8). SUBMITI'ER: Howard Hopper, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

3-2.4* S~'~rce= 2f D c c u m e ~ . Technical References i~q~ Resources. The authority having jurisdiction shall be provided with sufficient documentation to support the validity, accuracy, relevance, and precision of the proposed methods. The en~ineerin~ standards, calculation methods and other forms of scientific information vrovided shall be avvrooriate for the narticular aoDlication and methodolotries used. ?m clcmc~,t in

SUBSTANTIATION: (a) Delete the term "Sources of Documentation" from the tide. This terms does not clearly define the ,kind of documentation being addressed by this section. This documentation may be confused with the input data covered b~ Section 3-6. The phrase "Technical References and Resources is consistent with the proposed tide of Section 1.5 of the December 1998 draft of the SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design.

(b) The additional proposed text is based on criteria included in Section 1.5 of the December 1998 draft of the SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design. It clarifies that this section covers engineering standards, calculation methods and other forms of scientific information used in performance based design,

(c) The last sentence is being deleted because it is more explanatory in nature, and is better suited as Appendix material. It is not necessary to move this to the appendix, since it is already included almost verbatim in the first sentence in A-3-2.4.

COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

12


101- 104- (3-2.5): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In appendix A-3-2.5, second and fourth paragraphs, change "lower than 6 ft above the floor" to "lower than 8 ft above the floor". SUBSTANTIATION: The purpose of this statement is to be conservative and make sure that smoke does not descend to a point where an), member of the population has to bend over to stay out of the smoke while egressing. Since a large number of the population of the world is over 6 ft tall, and a significant number is over 7 ft tall, the conservative approach would be to make sure that the smoke stays at least 8 ft off of the floor. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The minimum ceiling height reguired by the code is 7 ft-6 in. The 6 ft criterion is conservative enough given the minimum specified by the code. It is more conservative than the early 5 ft value. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12


101- 105 - (3-2.5): Accept in Principle SUBMITTER: James R. Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add a final paragraph to proposed appendix A-3-2.5 to read:

"Since the orescrintive code reouirements of the other chanters of this code are deemed to satisfv the nerformance reauirements. another alternative desima am)roach would be to comvare a orovosed desima with the orescriDfive code. ff the results of the nrooosed design analysis a~re enual to or better than the results of the-orescriDtive code. the desimq can be considered accentable." SUilSTAN:rIATION: This approach is logical, particulaa'ly in the first years of use of the performance code approach, and in light of the fact that the performance methods need much improvement. While the comparative approach is not ideal, it is a reasonable approach for the short term. COMMITI'EE ACTION: Accept in Principle.

See Committee Action on Comment 101-34 (Log #176) on 1-9.2. COMMITTEE STATEMENT: The Committee Action on the referenced comment should meet the submitter's intent. Also, one has the option of using the equivalency provisions of Chapter 1 in lieu of fuilperformance-based design. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMI1q'EE ACTION:

AFFIRMATIVE: 12


101- 106 - (3-$): Accept SUBMITTE~ Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12

[ P~COMMENDATION: Change the tide of section 3-$ from , Design Specifications" to "Retained Prescriptive Requirements ;

delete 3-$.1; and renumber 3-$.1.1 and 3-$.1.2 as 3-5.1 as 3-3.2. SUBSTANTIATION: The section addresses retained prescriptive requirements rather than design specifications. As such the tide of the section can be changed. Rather than repeating the term "retain prescriptive requirements" twice, it is better to reformat as described above. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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N F P A 101 - - F 9 9 R O C


I01- 107- (3.3.1.I): Reject SUBMITrER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise 3-3.1.1 as follows: 3-3.1.1 Means of Egress. The design shall comply with the

following requirements in addition to the performance criteria of Section 3-2 and the methods of Scctions 3-4 through 3.9: Changes in Level in Means of Egress - 5-1.6 Exit Senaration - 5-1.3.2 Guards- 5-1.7 Doors - 5-2.1 Stairs - 5-2.2 Exception: The provisions of 5-2.2.5.1, ~ 5-2.2.6.3,

5-2.2.6.4 and 5-2.2.6.5 shall be exempted. Horizontal Exits - 5-2.4.1 Ramps - 5-2.5 Exception: The provisions of 5-2.5.3.1, 5-2.5.5 and 5-2.5.6.2 shall

be exempted. Fire Escape Ladders - 5-2.9 Alternating Tread Devices - 5-2.11 Areas of Refu~e - 5-2.12 Capacity of Means of Egress - 5-3 Exception: The provisions of g-g~4m& 5-3.4 shall be exempted.

SUBSTANTIATION: SAF-MEA specifically addressed performance exceptions and the hst provided by SAP-FUN needs to be adjusted to correlate with that action. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: It is unclear what Chapter 5 intended in the five locations in which it introduced options for

erformance-based design. Assodated comments, generated by FUN, request that the five Chapter 5 proposals be rejected.

Thus, the additional entries to 3-3.1.1 are not needed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITYEE ACTION:

AFFIRMATIVE: 12

(Log #184) Committee: SAP-FUN

101- 108 - (34): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) notes that the verbia~_ of $-4.1.2 and ~4.1.3 addressed in the committee action vail not be implemented because it was deleted by the action on Comment 101-147 (Log #GCI$). SUBMITrER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Rename section "Design Specifications, Conditions and Assumptions."

Revise section as follows: 3-4.1" General.

desima snecifications, conditions and estimations will form the innut to evaluation of trial desimas (see Section ~-0), Whet* B feature is not known, a reasonable estimation may be made. However. the desial~ team will need to take stens to ensure that the estimation is valid durin~ the life of the building. Any estimations need to be documented, (See Section 3-9l.

3-4.1.1 Clear Statement. DesKm snecifications, conditions and ~. . .v~u.:^-- estimations used in the performance-based design shall be clearly stated.

3-4.1.2 Data Sources. Desien snecifications, conditions and =.~t:.~.pSc.ne estimations shall be documented as to sources of data.

3-4.1.$ Topics. Desien snecifications, conditions and a.~"umpfign: ¢stimations shall include,-but not be limited to the topics addressed in 3-4.2 through 3-4.9.

~ t A O~¢ A 0 11 3-4.2 . . . . . ~ump~on~ ..cgar~!ng Building Characteristics.

LU~.L~L~3 "72 ~. _"L~A 2T,E~..'.. ,°Z _L- ~Z.. L= . . . . . . . . . . . . . . . . 34.2.1 .&~=:;,-n~.~; .7.~aut L~,c b u : l ~ g ~ dimensions,

construction materials, furnishings, spatial geometry, number of openings and sizes of openings, and other details that are input into calculations or models shall be explicitly identified, andshall

match like criteria included in the building plans, spedfications and shop drawings.

3-4.2.2 Az=ump~en= regxrding ch~":cteH:*2~ Characteristics of the building or its contents, equipment, or operations not inherent in the design specifications, but that affect occupant behavior or the rate of hazard development shall be explicitly identified.

3 - 4 . 3 . . . . . . . v . . . . . . . b . . . . . b Operational Status and Effectiveness of Building Features and Systems.

A-3-4.3 This category cf ~=.ump:2an:. applies both to systems and features required by the Code, that reference applicable standards, and to any additional systems or features included in the design at the discretion of the builder. The referenced standards are hereby expected to state maintenance, testing, and other requirements needed to provide positive assurance of an acceptable level of reliability. The referenced standards themselves may be prescriptive or performance based.

3.4.$.1 All fire protection systems and features of the building shall comply with applicable NFPA standards for those systems and features and, based on compliance with such standards, shall be assumed to be fully operational and reliable.

Exception: The assumption of full operability and reliability shall not apply to those systems or features for which a scenario is specifically and explicitly defined to involve the impairment of that system or feature.

3-4.3.2* ?~ump~o~: :.bout t.hc The performance of fire protection systems and building features shall reflect the documented performance of the components of those systems or features unless ~[,~i~-n specifications are incorporated to modify the expected pqFfgrmance.

A-3-4.3.2 Systems addressed by this requirement include automatic fire suppression systems and fire alarm systems. Performance issues that need to be documented might include response time indexes, discharge densities and distribution patterns. Calculations should not include an unlimited supply of extinguishing agent if only a limited supply will be provided in the actual structure or building.

3-4.4 ?~ump~en~ . .~r '~ '~ :~ . . t , Occupant Characteristics. 34.4.1" General. The selection of occupant characteristics to be

used in the design calculations shall be approved by the authority having jurisdiction and shall provide an accurate reflection of the expected population of building users. Occunant characteristics . . . . . . . . ~ . . . v ~ . . ~ : ~ - shall represent the normal occul~ant profile, unless design sDecifications are used to modify the expected occupant features. Occupant cb~vacterisdcs eed- shall not vary across fire scenarios except as authorized by the authority having jurisdiction.

A-3-4.4.1 Examnles of desicm features that might be incoroorated to modify exoected OCCUPant characteristics inc]ude training, use of staff to assist with notification and movement, or woe of - notification annliance used.

3-4.4.2* Response Characteristics. a . . . . . . . : . . . . t.~u t.^ ~^.~_ . . . . . . ~ e , . . . . a : . . . . . t , . . . . . ~- Each each of the following basic performance characteristics shall be considered: sensibility, reactivity, mobility, and susceptibility. These ===t:mp~e~ estimations shall reflect the expected distribution of characteristics of a population appropriate to the use of the building. The source of data for these characteristics shall be documented. A-3-4.4.2 <existing text> 3-4.4.3 Location. It shall be assumed that in every normally

occupied room or area at least one person shall be located at the most remote point from the exits.

3-4.4.4* Number. It shall be assumed that every normally occupied room or area, the average maximum density of occupancy shall be present.

Ao3-4.4.4 The average maximum density of occupancy is the occupant load factor specified in Table 5-$.1.2.

3-4.4.5 StaffAss, stance . . . . . . . . v . . . . . . . . . . . . . . . . . . . T h e ability of trained employees to be included as part of the fire safety system shall be identified and documented.

A-34.4.5 For example, in hospitals, staff characteristic such as number, location, quality and frequency of training should be considered.

3-4.5 A~umpt!o: : P.cgm-~ng Emergency Response Personnel. De=ig'n Frvpc=a!~L - =ha!! =~te tS.eir ==:--'.='mp~en= r~-~g~ding ~ : The availability, speed of response, effectiveness, roles, and other characteristics of emergency response personnel shall be considered.

~t A D .4 3-4.6 .=~ump'don~ ..cg-~---a'ng Post-construction Conditions.

during the life of building that affect the ability of the

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N F P A 101 - - F9 9 R O C

building to meet the stated goals and objectives sh~l be considered.

A-3-4.6 Desigrl proposals need to state explicitly any rig, riga snecifications or :~umpdc. := estimations regarding building fire s~fety plans, inspection programs, or other ongoing programs whose performance is necessary for the building, when occupied and operational, to meet the stated goals and objectives. Programs of interest include any maintenance, training, labeling, or certification programs required to assure operational status or reliability in building systems or features.

3-4.7 A~um~'.5~.~ D~__a:__..~ ~. .~ Off-site Conditions.

esources or conditions outside the property being designed that affect the ability of the building to meet the stated goals and objectives shill be considered.

3-4.8* Consistency of Assumptions. The design shall not include mutually inconsistent assumptions.

A-&-4.8 This includes assumptions about the interrelations between the performance of building elements and systems, occupant behavior, or emergency response actions that conflict with each other. For each fire scenario care needs to be taken to assure that conflicts in actions do not occur. Typical conflicts could include (1) assuming a fire door will remain closed during the fire event to contain smoke, while this same door is used by occupants during egress from the area. (2) assuming fire apparatus will arrive immediately from a distant location to charge fire department connections to provide water, and similar situations.

For example, an assumption that compartmentation blocking the passage of fire and smoke will be maintained at the door to a stairwell cannot be paired with an assumption that evacuation through that door will extend over many minutes.

3-4.9* Special Provisions. Additional provisions not covered by the above desit~n snecifications, conditions, estimations and assumptions but that are required for the design to comply with the performance objectives shall be documented.

A-3-4.9 This includes provisions that are in excess of basic requirements covered by referenced codes and standards, typical design requirements, and operating procedures. It includes things such as more frequent periodic testing and maintenance to increase the reliability of fire protection systems; redundant systems to increase reliability, on site guard service to enhance detection of fires and aid in fire response procedures, staff training, availability and performance of emergency response personnel, and other factors. SUBSTANTIATION: In a performance-based code, the emphasis should be on consideration of the features that can be used (design specifications), the characteristics of the building occupants and environment (conditions), and on estimations based on technical references, not on making assumptions regarding h o w equipment, people, etc will behave. The changes proposed by this comment are consistent with the differentiation of "design specifications" and "assumptions" in Section 3-6 of Proposal 101-12. COMMITI'EE ACTION: Accept in Principle.

Add to the 3-1.7 definitions, a definition of Design Specifications and an associated appendix to read:

($-1.7) Design Specifications* Building characteristics and other conditions that are under the control of the design team.

A-3-1.7 Design Specifications. Design specifications include both hardware and human factors, such as the conditions produced by maintenance and training. For purposes of performance-based design, the design specifications of interest are those that affect the ability of the building to meet the stated goals and objectives.

Revise Section 3-4 to read: Section 3-4 Design Specifications and Other Conditions. 3-4.1 * General. A-3-4.1 The design specifications and other conditions will form

the input to evaluation of proposed designs (see Section 5-6). Where a specification or condition is not known a reasonable estimation may be made. However, the design team will need to take steps to ensure that the estimation is valid during the life of the building. Any estimations need to be documented. (See Section 3-9.)

3-4.1.1 Clear statement. Design specifications and other conditions used in the performance-based design shall be clearly stated and shown to be realistic and sustainable.

3-4.1.2 Data Sources. Design specifications and other conditions shall be documented as to sources of data and assumptions estimations shall be documented as to sources of data.

3-4.1.3 Topics. Design specifications and other conditions shall include, but not be limited to the topics addressed in 3-4.2 through 3-4.9.

3-4.2 Building Characteristics. 5-4.2.1 Characteristics of the building or its contents, equipment,

or operations not inherent in the design specifications, but that affect occupant behavior or the rate of hazard development shall be explicitly identified.

3-4.3* Operational Status and Effectiveness of Building Features and Systems.

A-3-4.3 This category applies both to systems and features required by the Code, that reference applicable standards, and to any additional sy~.tems or features included in the design at the discretion of the ~auilder. The referenced standards are hereby expected to state malnfenance, testing, and other requirements needed to provide positive assurance of an acceptable level of reliability. The referenced standards themselves may be prescriptive or performance based.

3-4.3.1" The performance of fire protection systems and building features shall reflect the documented performance of the components of those systems or features unless design specifications are incorporated to modify the expected performance.

A-3-4.&.l Systems addressed by this requirement include automatic fire suppression systems and fire alarm s~stems. Performance issues that need to he documented might include response time indexes, discharge densities and dismbution patterns. Calculations should not include an unlimited supply of extinguishing agent if only a limited supply will be provided in the actual structure or building.

3-4.4 Occupant Characteristics. 3-4.4.1" General. The selection of occupant characteristics to be

used in the design calculations shall be approved by the authority having jurisdiction and shall provide an accurate reflection of the expected population of building users. Occupant characteristics shall represent the normal occupant profile, unless design

~ ecifications are used to modify the expected occupant features. ccupant characteristics shall not vary across fire scenarios except

as authorized by the authority having jurisdiction. A-3-4.4.1 Examples of design features that might be incorporated

to modify exl~ected occupant characteristics include training, use of staff to assist with notification and movement or type of notification appliance used.

5-4.4.2* Response Characteristics. Each of the following basic performance characteristics shall be considered: sensibility, reactivity, mobility, and susceptibility, These estimations shall reflect the expected distribution of characteristics of a population appropriate to the use of the building. The source of data for these characteristics shall be documented.

A-3-4.4.2 <existing text> 3-4.4.3 Location. It shall be assumed that in every normally

occupied room or area at least one person shall be located at the most remote point from the exits.

3-4.4.4* Number. It shall be assumed that every normally occupied room or area, the average maximum density of occupancy shall be present.

A-3-4.4.4 The average maximum density of occupancy is calculated using the occupant load factors specified in Table 5-3.1.2.

3-4.4.5* Staff Assistance. The ability of trained employees to be included as part of the fire safety system shall be identified and documented.

A-3-4.4.5 For example, in hospitals, staff characteristic such as number, location, quality and frequency of training should be considered.

3-4.5 Emergency Response Personnel. Design characteristics or other conditions related to the availability, speed of response, effectiveness, roles, and other characteristics of emergency

response personnel shall be specified, estimated, or characterized sufticiendy to evaluate the design.

3-4.6* Post-construction Conditions. Design characteristics or other conditions related to activities during the life of building that

i affect the ability of the building to meet the stated goals and objectives shall be specified, estimated, or characterized sui~cienfly to evaluate the design.

A-3-4.6 Design proposals need to state explicitly any design specifications or estimations regarding building fire safety plans, inspection programs, or other ongoing programs whose performance is necessary for the building, when occupied and operational, to meet the stated goals and objectives.

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Programs of interest include any maintenance, training, labeling, or certification programs required to assure operational status or reliability in building systems or features.

3-4.7 Off-site Conditions. Design characteristics or other conditions related to resources or conditions outside the property being designed that affect the ability of the building to meet the stated goals and objectives shall be specified, estimated, or characterized sufficiendy to evaluate the design.

3-4.8* Consistency of Assumptions. The design shall not include mutually inconsistent assumptions, specifications or statements of conditions.

A-3-4.8 This includes assumptions about the interrelations between the performance of building elements and systems, occupant behavior, or emergency response actions that conflict with each other. For each fire scenario care needs to be taken to assure that conflicts in actions do not occur. Typical conflicts could include (1) assuming a fire door will remain closed during the fire event to contain smoke, while this same door is used by occupants during egress from the area, (2) assuming fire apparatus will arrive immediately from a distant location to charge fire department connections to provide water, and similar situations.

For example, an assumption that compartmentation blocking the passage of fire and smoke will he maintained at the door to a stairwell cannot be paired with an assumption that evacuation through that door will extend over many minutes.

, 3-4.9 Special Provisions. Additional provisions not covered by the above design specifications, conditions, estimations and assumptions but that are required for the design to comply with the performance objectives shall be documented.

A-3-4.9 This includes provisions that are in excess of basic requirements covered by referenced codes and standards, typical design requirements, and operating procedures. It includes things such as more frequent periodic testing and maintenance to increase the reliability of fire protection systems; redundant systems to increase reliability, on site guard service to enhance detection of fires and aid in fire response procedures, staff training, availability and performance of emergency response personnel, and other factors. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 109 - (3-4.1.1): Accept in Principle SUBMITTER: James R. Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

~Assumptions used in the performance based design shall be clearly stated ~r~d shown to be realistic and sustainable." SUBSTANTIATION: It is not enough to make assumptions. They must be realistic, and it must be shown that they will not change. COMMITTEE ACTION: Accept in Principle.

See Comment 101-108 (Log #184). COMMITTEE STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE= 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 110 - (3-4.1.1 (New)): Accept in Principle SUBMITTER: Norman E. Groner, Santa Cruz, CA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add the following Appendix note:

A-3-4.1.1 Assumotions should be clearly stated and the tvoe clearly indicated. In general, there are two different tvoes of assumntions: desima assumntions and uncontrolled assur~p~otlS, Design assumntions are assumotions about system comoonents or oarameters that are controlled by the desima team and /o r building management. An assumt)tion is a desit, a assumption if i~ v~lue must be established and maintained for the nronosed desima to meet oerformance criteria. Design assumotions may be subject to maintenance reouirements such as those established in 1-10~7 an~

1-11.10.2. Uncontrolled assumntions are assumntions that are not harts of the oronosed design, either because the desitra team decides that they do not need to be controlled or because they are intractable. The values selected for uncontrolled assumntions should be realistic, but conservative. SUBSTANTIATION: The distinction between design and uncontrolled assum[~tions needs to be clearly stated so that the authority having jurisdiction knows precisely which values can and should be monitored after the building is occupied. The distinction is especially crucial as regards human and organizational performance. Take, for example, the presence of persons with disabilities in a building. The number and types of such persons is usually an uncontrolled assumption because governing the number of occupants with disabilities is often not legally permitted. However, a provision to protect persons with disabilities is a design assumption, because it is tractable and directly affects the ability of the design to meet performance criteria. As such, it should be identified for the authority having jurisdiction and provisions should be made for its periodic evaluation. COMMITTEE ACTION: Accept in Principle.

See Comment 101-108 (Log #184). COMMITTEE STATEMENT: The Committee Action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 111 - (3-4.$.1): Accept SUBMITTER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12

[ RECOMMENDATION: Delete the paragraph. SUBSTANTIATION: This paragraph does two things: (1) requires that systems comply with applicable NFPA standards and (2) specifies that systems that comply with NFPA standards are (sufficiently) reliable.

1. A requirement that systems comply with applicable NFPA standards is contained in 1-10.6. Therefore, this portion of 5-4.3.1 is redundant.

2. Assuming that any system that complies with NFPA standards is sufficiently reliable is in direct conflict with the provisions of 3- 4.3.2. Additionally, systems that comply with NFPA standards are not necessarily sufficiently reliable, and this requirement would remove improving the reliability of systems from the options available to the design team. COMMYrTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 112 - (3-4.3.1): Accept in Principle SUBMITTER: James 1L Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

"All fire protection systems and features of the building shall comply with applicable NFPA standards for those systems and features, at=d S.~cd c.n ccmpl'=.ncc... The reliability and ooerational features necessary to maintain those systems shall be considered in the design."

v

Delete the Exception. SUBSTANTIATION: Not all NFPA standards provide the same degree of redundancy or reliability. The approach described in the current text would assume 100 percent reliability of all such systems. Clearly, adding redundancy beyond that required in the standards may increase the reliability of the system. COMMITTEE ACTION: Accept in Principle.

See Comment 101-111 (Log #185). COMMITTEE STATEMENT: Paragraph 3-4.3.1 is being deleted by the Committee Action on the referenced comment. This should meet the submitter's intenL NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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101- 113 - (5-4.4.4 and A-$-4.4.4): Accept in Principle SUBMrlq'ER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENI)ATION: Replace .5-4.4.4 with the following:.

3-4.4.4* Number. The design shall be based on the maximum number of people that every occupied room or area is expected to contain.

Revise A-3.4.4.4 as follows: "The number of people expected to be contained in a room or

area shall be based on information from appropriate references (see A-5-2.4) or may be derived using the occupant load factor specified in Table 5-3.1.2 t~e =;'erzge m.~Sm~m ~en:'~" cf

Where success or failure of the design is contingent on the number of occupants not exceeding a certain number, operational controls shill be used to ensure a greater number of occupants could not be present." SUBSTANTIATION: The only concern in a performance-based design should be if success or failure is contingent on the number of occupants present in a room or area. If it is, then restrictions should be in place to ensure that a large enough number of occupants can not be present such that the design could fall. If it is not, then any source that meets the documentation requirements should be acceptable.

Also, "A survey of Occupant Load Factors in Contemporary Office Buildings" by Milke and Caro (Journal of Fire Protection Engineering, 8 (4), pp. 169-182) brings the occupant load factors used for business occupancies into question. With the change proposed here, information from reliable sources (such as the J. of FPE) could be used in lieu of table 5-3.1.2. Additionally, the term "average maximum density" used in the Proposal 101-12 is not dear as to its meaning. COMMITTEE ACTION: Accept in Principle.

Replace 5-4.4.4 with the following:. 3-4.4.4* Number. The design shall be based on the maximum

number of people that every occupied room or area is expected to contain. Where success or failure of the design is contingent on the number of occupants not exceeding a certain number, operational controls shall be used to ensure a greater number of occupants could not be present.

Replace A-5-4.4.4 with the following: A-3-4.4.4 The number of people expected to be contained in a

room or area should be based on the occupant load factor eCified in Table 5-3.1.2 or other approved sources.

MMITTEE STATEMENT: The revision improves the material. However, the committee notes that the referenced survey may not be valid for business occupancies outside the United States and for business occupancy uses such as reservations centers. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMI~I'EE ACTION:

AFFIRMATIVE: 12


101- 114- (3-4.5): Reject . SUBMITTER: Jonas L. Morehart, Punta Gorda, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the entire paragraph. SUBSTANTIATION: There are no laws in this country which require any emergency response personnel to attend any situation to which they normally function in their official roles. If an emergency response unit is busy with another emergency, they cannot respond. Should a governing body enact such a law, that government would be legally liable when they did not respond. To place the proposed paragraph 5-4.5 into the Life Safety Code, which would be adopted as law by a governing body, might legally cause problems for the governingbody, its emergency response personnel, and even the NFPA. The purpose of this comment is to protect emergency responclers from liabihty when they are unable to respond due to the occurrence of other responses. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Emergency response is not limited to public fire departments. It can include fire brigades whose characteristics can be described and evaluated. For example, large industrial facilities and those of DOE, DOD, and VA might benefit from this. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12

COMMENT ON AFFIRMATIVE: GALLAGHER: Performance option design cannot dictate the

level of performance of either a fire department or any other emergency responders. That is dictated by the management decisions of the responding agencies. If the emergency services cannot perform to the level of the design, then the fault is with the design team for making a design dependent upon unachievable conditions. No design should depend on any emergency services for its success. The emergency services should only be needed if there are critical factors in the design that were not accurately accounted for, which caused the design to fail. Thus, no design should count on the need of the emergency services, only as a last resort to cover for the inherent and missed shortcomings of the design. If the design is successful, the emergency services would not be needed. I agree in principle with the submitter that this should be indicated somewhere in the performance option code, hut I do not necessarily agree with his substantiation.

I also agree with the committee's statement for private fire brigades. The building owner (for whom the designer is working when the assumptions and characterizations of the fire and emergency services and responses are made, has complete control over the private fire brigade under the same management responsibility that must enforce ALL the design assumptions and characterizations into the daily building operations. However, the code should be clarified by differentiating between the different types of fire and emergency services and responses, as guidance to designers who would not necessarily know these differences when embarking on their design characterizations and assumptions.


101- 115 - (5-5): Accept in Principle SUBMITTER: Morgan J. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Change the title of Section 5-5 to " ~ J g a F ~ Scenarios."

Replace A-5-5 with the following: A-5-5 Design fire scenarios define the challenge a building is

expected to withstand. Design fire scenarios capture and limit value judgments on the type and severity of the fire challenge to which a proposed fire safety system needs to respond. The system includes any and all aspects of the proposed design that are intended to mitigate the effects of a fire: egress system , automatic detection and suppression, barriers, staff training, placement of manual extinguishers, etc. Design fire scenarios come from two sources: those that are specified in paragraphs 3-5.$.2 through 3-5.$.9, and those that are developed by the design team based on the unique characteristics of the building as required by 3-5.3.1. In most, if not all cases, more than one design fire scenario will be developed to meet the requirements of 5-5.3.1. "

The process of developing design fire scenarios is first to characterize the "universe" of possible fire scenarios through the use of fire protection engineering tools. These fire scenarios are then reduced into a manageable number of design fire scenarios using probabilistic and deterministic methods.

A probabilistic approach typically deals with the statistical likelihood that a fire will occur and the resultant outcome i fa fire does occur. The decision whether to select a given fire scenario as a design fire scenario is based on grouping scenarios which are similar. Grouped sets of scenarios can potentially be eliminated from further evaluation if the design team and authority having jurisdiction agree that the risk or outcome is acceptable.

A deterministic approach relies on analysis or judgment based on physics and chemistry, or correlations developed from testing to predict the outcome of a fire. Fire scenarios can be evaluated for use as design fire scenarios by determining whether a given scenario can produce effects that exceed the performance criteria or are bounded by other design fire scenarios. Those scenarios that do not exceed the performance criteria or are bounded by other design fire scenarios need not be used to evaluate trial designs.

Once the set of design fire scenarios are established, both those specified by 5-5.3.2 through 5-5.3.9 and those that are developed as required by 5-5.$.1, they must be quantified into a format that can be used for the evaluation of trial designs. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design outlines a process and identifies tools and references that can be used at each step of this process."

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Revise A-3-5.3.1 as follows: A-3-5.3.1 Scenario 1 An example of such a scenario for a health

care occupancy would involve a patient room with two occupied beds; fire initially involving one bed; room door is open. This is a cursory example in that much of the explicitly required information indicated in 3-5.3.1 can be determined from the information provided in the example. Note that it might-will

be necessary to consider more than one scenario to capture the features and conditions typical of an occupancy. SUBSTANTIATION: 1 With the exception of the first paragraph (which this comment proposes to maintain) the text proposed in A-3-5 is an engineering approach to solving a problem and not explanatory material for the code itself. Also, the proposed method is not complete, and does not include references to the literature. Without references to the literature, it may be impossible for engineers and authorities having jurisdiction to further develop the incomplete concepts. A general discussion of the process of developing design fire scenarios is proposed, along with a reference to the SFPE Engineering Guide to Performance- Based Fire Protection Analysis and Design, which contains a far more comprehensive treatment of the subject than was proposed in the ROP.

2. The change to A-3-5.$.1 will amplify that more than one design fire scenario will typically be required.

$. A companioa comment proposes to change the terminology (fire scenario, design fire scenario) throughout Chapter 3 of Proposal 101-12. COMMITIT, E ACTION: Accept in Principle.

Change the title of Section 3-5 to "Design Fir~ Scenarios." Replace A-3-5 with the following: A-3-5 Design fire scenarios define the challenge a building is

expected to withstand. Design fire scenarios capture and limit value judgments on the type and severity of the fire challenge to which a proposed fire safety system needs to respond. The system includes any mad all aspects of the proposed design that are intended to mitigate the effects of a fire: egress system, automatic detection and suppression, barriers, staff training, placement of manual extinguishers, etc. Design fire scenarios come from two sources: those that are specified in paragraphs $-5.$.2 through $-5.$.9, and those that are developed by the design team based on the unicjue characteristics of the building as required by 3-5.3.1. In most, tf not all cases, more than one design fire scenario will be developed to meet the requirements of 3-5.$.1.

Once the set of design fire scenarios are established, both those specified by 3-5.3.2 through 3-5.3.9 and those that are developed as required by 3-5.5.1, they must be quantified into a format that can be used for the evaluation of proposed designs. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design outlines a process and identifies tools and references that can be used at each step of this process.

Revise A-3-5.3.1 as follows: A-3-5.3.1 Scenario 1 An example of such a scenario for a health

care occupancy would involve a patient room with two occupied beds; fire initially involving one bed; room door is open. This is a cursory example in that much of the explicitly required information indicated in 3-5.3.1 can be determined from the information provided in the example. Note that it m~ht-will

be necessary to consider more than one scenario to capture the features and conditions typical of an occupancy. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: WOODWARD: The existing appendix text provides an overview

of the process which can assist the authority having jurisdiction by providing a good basic discussion of the various issues. While this text may not provide complete discussion of the concepts, I feel that it provides a simple discussion of them for the lay people who will be trying to enforce these provisions for the first time in the 2000 edition. Yes, a more detailed discussion is available in the SFPE Engineering Guide, and additional references are also available there, but the target audience of that publication and of the existing appendix text are greatly different. It would be better to add additional discussion to the existing text which would serve

as a springboard to the SFPE documents and the concepts and systems discussed there for the advanced users. See the action on Comment 101-152 (Log #195) which provides an example of how this can be worked to include both levels of information. This method would maintain the introductory level discussion to provide the authority having jurisdiction with enough information to begin the discussions and let them know where to turn for further development. This combination would serve both targeted groups without limiting either. COMMENT ON AFFIRMATIVE:

GALLAGHER: I agree with the committee action in part for the improvements from Mr. Hurley, but also not to delete certain material for Mr. Woedward's concerns. Both levels of information from both Mr. Hurley and Mr. Woodward should be included for the first draft.


101- 116 - (3-5): Reject SUBMITTER: Carol A. Caldweil, CaldweU Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add to appendix A-3-5 the following:

"It should ~enerallv be considered that adiacent materials will i~nite and one of the tvvical t-souared heat release rate curves should be used. There-are relatively rare circumstances when the first material imaited is the only material itmited. The tvvical heat release rate cu~rve of the t-sauared fire includes mgre ~ n lust the first material ignited." SUBSTANTL~TION: The explanation in paragraph two of this section, on the development of heat release rate curves, tends to imply that each scenario should have a specific heat release rate curve developed. It is likely to more conservative to use a t-squared fire growth than specific item by item scenarios, which are difficult to develop with good accuracy. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The proposed material is not needed given that much of the appendix on this item is being deleted. See the Committee Action on Comment 101-115 (Log #187). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12


101- 117- (3-5): Reject SUBMITTER: Carol A. Caldwell, Caldwell Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise appendix Table A-$-5(a) as follows:

Table A-3-5(a) Fire ~Type" Exposed is in Room of Origin, but Not Intimate Fast Ultraf~t Developing Fire Flammable Liquids

SUBSTANTIATION: 3-5.3.2 Scenario 2 an ultrafast flammable liquid fire, why in this section is a flammable liquid fire only a fast fire? It would be appropriate to keep the flammable liquid fire growth consistent as an uitrafast fire. COMMITTEE ACTION: Reject. COMMrVrEE STATEMENT: The proposed material is not needed given that much of the appendix on this item is being deleted. See the Committee Acuon on Comment 101-115 (Log #187). NUMBER OF COMMN~rEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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101- 118- (3-5): Reject SUBMITTER: Carol At. Ca/dwell, Ca/dwell Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise appendix Table A-3-5(a) as follows:

Table A-3-5 (a) Fire "Type" Exposed is in Room of Origin, but Not Intimate Ultrafast Develoning Fire Some furniture

Flammable liouids SUBSTANTIATION: There is the need for ~m ultrafast category. AS noted in NFPA 72, Table G-2-2.2.2.2, furniture heat release rates, some furniture has an ultrafast heat release rate. Flammable liquids reasonably fall into this category. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The proposed material is not needed given that the majority of the appendix on this item is being deleted. See the Committee Action on Comment 101-115 (Log #187). NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMM/TTEE ACTION:

AFFIRMATIVE: 12


101- 119 - (3-5): Reject SUBMITTER: Carol A. Caldwell, Caldwell Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise appendix Table A-3-5(a) as follows:

Table A-3-5 (a) Fire "Type" Exposed is in Room of Origin, but Not Intimate

F ~ t Developing Fire Open flame ignition of upholstered furniture

SUBSTANTIATION: It would be expected that Generalized Scenarios would be reasonable conservatives. There are many items of furniture that when exposed to an open flame ignition source burns with a fast or ultrafast fire growth. Refer to NFPA 72, Table G-2-2.2.2, Furniture Heat Release Rates. COMMITI'EE ACTION: Reject. COMMrlTEE STATEMENT: The proposed material is not needed given that the majority of the appendix on this item is being deleted. See the Committee Action on Comment 101-115 (Log #187). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 120 - (3-5): Accept in Principle SUBMITTER: Thomas W. Jaeger /Thomas W. Gardner, American Health Care Assn. (AHCA) COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Because this is new material and a new concept, my comment has no specific proposed wording. I am requesting that the Technical Committee on Fundamentals revisit the nine scenarios. SUBSTANTIATION: The scenarios, particularly Scenarios 5, 8, and 9 seem only to address failure of some major fire protection features but not other major fire protection features. For example, none of the scenarios address the failure of fire rated enclosures of vertical openings or fire rated partitions. Also, none of the scenarios address the failure o f the fire resistance of structural members. In other words, none of the scenarios address the failure of the passive fire protection features of the building. Obviously, these passive fire protection features play a major role in providing adequate fire safety in a building.

Scenario 2 seems to be overly restrictive. If Scenario 2 is valid and has a high enough probability of occurring, then a scenario for an explosion and resulting fire in the primary means of egress is equally valid and may have a higher probability of occurring than the ultra fast-developing flammable h"quids fire.

It is my opinion that i f you want to inhibit the use of the performance based approach in the Life Safety Code, you have done so by mandating the current nine scenarios. I do not believe that the Exception to Section 3-5.$ gives adequate direction to

authorities having jurisdiction. Therefore, the authorities having jurisdiction will require evaluation of all n ine scenarios.

Evaluation of all nine scenarios will result in the performance based approach being more restrictive and costly than the current prescripuve requirements in the Code. Why would anyone want to do that other than to try to document that the current prescriptive requirements of the Code are inadequate? COMMITTEE ACTION: Accept inPrinciple.

See the numerous Committee Actions that revise proposed Chapter $. COMM/TrEE STATEMENT: The numerous Committee Actions taken on other comments should satisfy the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

Committee: (Ls°~g # F ~ 101- 121 - (3-5.1 and 3-5.2): Reject SUBMITrER: James R. Quiter, RoifJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise as follows:

"...for each ~ scenario that is evaluated." SUBSTANTIATION: Requiring a series of 9 scenarios for every project is unrealistic. The authority having jurisdiction and the designer should mutually decide which scenarios to evaluate. COMMITI'EE ACTION: Reject. COMMrITEE STATEMENT: The submitter 's recommendation would remove the required scenarios. The overall effect would be to examine fewer scenarios but that will not capture the intent. Such deletion would transfer too much power from the authority having jurisdiction to the designer. The committee feels that the required scenarios need to be specified and the exception to 3-5.$ provides relief if the scenario can be documented as not needed. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 122- (3-5.3): Reject SUBMITTER: Carol A. Caldwell, Caldwell Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

3-5.3 Required Scenarios. Scenarios shall ~ . g ? . i ~ d ~ but not be limited to, those specified in 3-5.$.1 through ~-5.3.9. SUBSTANTIATION: The number and prescripuve nature of the required scenarios are inappropriate for aperformance-based design. These scenarios may be consideredhowever, it should be up to the design team that would include the authority having jurisdiction to determine what scenarios are appropriate for use. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement associated with the rejection of Comment 101-121 (Log #$46). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 123 - ($-5.3): Accept in Principle SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise appendix A-3-5.5 as follows:

A-3-5.3 It is desirable to run a wide variety of different fire scenarios to evaluate the complete life safety capabilities of the building or structure. Fire scenarios should not be limited to a single or a couple of "worst case" fire scenarios. Scenarios 8 and 9 may be omitted if fire protection systems are demonstrated to be sufficiendy reliable to justify such omission in the judgment of the authority having jurisdiction, but only where a sensitivity analysis has been nerformed to determine the effect of the failure of soch

103


SUBSTANTIATION: If sprinkler systems a n d / o r fire alarm systems could be built and maintained 100 percent reliable we do not need anything else in the Code. In other words, if we sprinkler the building (especially with a smoke detection system) and we say it is always going to work, what do we need exits for? Before allowing the omission of Scenarios 8 or 9 the authority having jurisdiction should know the consequences of such failure. It should be noted that scenarios 8 and 9 are not required to be run simultaneously and nei ther scenario is a "challenging" scenario. COMMITTEE ACTION: Accept in Principle.

See revised Section 3-5. COMMITTEE STATEMENT: The revision to Section 3-5, being made by other comments, should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 124- (3-5.3): Reject SUBMITTER: James R. Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

"3-5.3 R-eetuir-ed- Scenarios. Scenarios ~uch as those described in 3-5.3.1 through 3-5.3.9 shall be considered for each design. include, ~'.:t n~t ~c l 'mltc~ t~...". SUBSTANTIATION: A performance code should not mandate which scenarios to consider. It can provide a list of potential scenarios. A better location would be the appendix. COMMITFEE ACTION: Reject. COMMITIEE STATEMENT: See the Committee Statement assodated with the rejection of Comment 101- 121 (Log #346). NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 127- (3-5.3 through 3-5.3.9): Reject SUBMITTER: DanielJ. O'Connor, Schirmer Engineering Corp. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete all text in the proposed new 3-5.3 to 3-5.3.9. SUBSTANTIATION: The required scenarios should be eliminated in total as they are prescriptive scenarios which effectively diminish the intended performance nature of the new Chapter 3. Several of the scenarios are not only challenging but are unreasonable from the perspective of associated assumptions such as failure and lack of reliability of fire protection systems or a ultra fast flammable liquids fire in a primary means of egress. These currently stated scenarios if applied in the context of buildings built to comply with the prescribed requiremenm of the Life Safety Code can result in gross failures. For example consider an ultrafast flammable liquids fire in the corridor doorway of a 1-story unsprinklered daycare facility. Rather than prescribing very narrowly nine scenarios with assumed failure modes and fire growth rates it should be possible that the designers can use a recognized process such as that being developed by the Society of Fire Protection Engineers to identify, recognize, discuss, and agree upon the factors o f concern such as fire size, system reliability, etc. with the authority having jurisdiction. The required scenarios as currently structured grossly limit the process. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See the Committee Statement associated with the rejection of Comment 101-121 (Log #346). Also see the revision to scenarios 8 and 9. The prescriptive based provisions have not been evaluated against the performance criteria applicable to performance based designs. Comparisons between prescription and performance based solutions are not reasons to lower the thresholds established forper formance based design. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 125- (3-5.3): Accept . SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add the following as a new paragraph to the end of the appendix material associated with 3-5.3 (i.e. A-3- 5.3):

The descriptive terms used to indicate the rate of fire growth for the scenarios are intended to be generic. Use of t-squared fires is not required for any scenario. SUBSTANTIATION: The proposed appendix material further clarifies intenL COMMrYrEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 126 - (3-5.3 Exception): Accept SUBMITTER= MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO; 101-12

I RECOMMENDATION: Revise the Exception as follows: Exception: Scenarios a.a.~cumente~ demonstrated by the design

team to the satisfaction of the authority having jurisdiction as inappropriate for the building use and conditions. SUBSTANTIATION: The current wording in the ROP is not clear as to who is resEonsible for documenting that a scenario is inappropriate. T h e change proposed by this comment would clarify that the design team is responsible to demonstrating to the authority having jurisdiction that a scenario is inappropriate. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 128- (3-5.3.2): Reject SUBMITTER= Jonas L. Morehart~ Punts Cords, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the word, "ultrafast-" in the first line. SUBSTANTIATION: The word, "ultrafast", when used to describe a fire is well known to persons who are modeling fires; and .when defined as a "T-Squared" fire does not provide anything similar to the description intended in the Appendix paragraph. "T-Squared" fires are not as severe as real fires and could lead to much greater times before the incapacitation of the occupants. The description in the Appendix is sufficient guidance without resorting to graphical definitions intended only to allow training in fire modeling. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: It is the intent to make the scenarios challenging. The term "flammable liquids" has been deleted from this scenario via the Committee Action on Corhment 101-131 (Log #298), so "ultrafasC needs to be retained to meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 129- (3-5.3.2): Reject SUBMITrER: Carol A~ Caldwell, Caidweli Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the following text:

SUBSTANTIATION: Delete this scenario. ~ is above and beyond what is currently required in prescriptive codes. If the authority having jurisdiction believes that an arson fire is appropriate then, that needs to be discussed and agreed to by the design team. It is also not a fair judge of a "reduction in the number of available

104

N F P A 1 0 1 ~ F 9 9 R O C

egress". An ultrafast fire in a doorway is not likely to occur, doorways are normally kept clear for use by building occupants. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See the Committee Action on Comment 101-131 (Log #298). The scenario is credible. The exception will allow exemption for documented cases. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 130 - (3-5.3.2): Reject SUBMITrER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete all of 3-5.3.2, Scenario 2. SUBSTANTIATION: This is not a likely scenario and might incur huge additional costs to a design. I submit this Code can not and should not be expected to protect occupants against terrorist type attacks to include arson by flammable liquids. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: A corridor fire is a realistic scenario documented in fires. It doesn't require a terrorist attack to fulfill this scenario. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMI~I'EE ACTION:

AFFIRMATIVE: 12


101- 131 - (3-5.3.2): Accept in Principle SUBMITrER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the words "flammable liquids". SUBSTANTIATION: The flammable liquids scenario is not appropriate. Code can not protect against terrorist type events. But, a fast growing fire within a primary means of egress is a reasonable event. COMMITTEE ACTION: Accept in Principle.

I Delete the words "flammable liquids". Also, revise appendix A-3- 5.3.2 to read:

A-3-5.3.2 Scenario Two. Examples of such scenarios are a fire involving ignition of gasoline as an accelerant in a means of egress, clothing racks in corridors, renovation materials or other fuel configurations that can cause an ultrafast fire. The means of egress chosen... COMMITFEE STATEMENT: The Committee Action should meet the submitter's intent. It deletes the words requested but also modifies the appendix to give additional examples. NUMBER.OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

as a descriptor is needed. See the new appendix material. Slowness is important for this scenario for it exacerbates the fire and gives a delay in suppression system activation. Thus, the concept must be retained. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 133- (3-5.3.5): Accept SUBMITTER= MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12

I RECOMMENDATION: Revise as follows: 3-5.5.5* Scenario 5. A slow developing fire, shielded from fire

protection systems, in closeproximity to a high occupancy area. This scenario shall address the concern of a relatively small ignition source causing a significant fire, eiu~.er ~ e m : life -~_7_%~, viev~. 'nt or f r c ~ "..~.c ; ' c ~ c i n t cf de!---Ted ---~-'.~'.J~.r= cf "~h,c zu-~reezion ;7~tc.,'n, if prczc=:t. SI,~'I~STANTIATION: The scope of this code is life safety. Suppression systems are one of many possible tools that may be employed to achieve life safety. The impact of delayed activation of a suppression system would become evident in the evaluation of trial designs. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE:, 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 134 - (3-5.3.6): Accept in Principle SUBMr['FEPa Jonas L. Morehart, Punta Gorda, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the word, "ultrafast-" in the first line. SUBSTANTIATION: The word, "ultrafasC, when used to describe a fire is well known to persons who are modeling fires; and when defined as a "T-Squared" fire does not provide anything similar to the description intended in the Appendix paragraph. "T-Squared" fires are not as severe as real fires and could lead to much greater times before the incapacitation of the occupants. The description in the Appendix is sufficient guidance without resorting to graphical definitions intended only to allow training in fire modeling. COMMITTEE ACTION: Accept in Principle.

See Comment 101-135 (Log #264). COMMI'Iq'EE STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 132 - (3-5.3.5): Accept in Principle SUBMITFER: Jonas L. Morehart, Punta Gorda, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the word, "slos¢' in the first line. SUBSTANTIATION: The word, "slow", when used to describe a fire is well known to persons who are modeling fires; and when defined as a "T-Squared" fire does not provide anything similar to the description intended in the Appendix paragraph. "T-Squared" fires are not as severe as real fires and could lead to much greater times before the incapacitation of the occupants. The description in the Appendix is sufficient guidance without resorting to graphical definitions intended only to allow training in fire modeling. COMMITTEE ACTION: Accept in Principle.

Change "a slow developing fire" to read "a slowly developing fire". COMMITTEE STATEMENT: The words "slowly developing" are more generic than the words "slow developing" which might be mistakenly interpreted to denote a t-squared fire. The generalized lengthy appendix A-3-5 is being mostly deleted so the word "slowly"


101- 135 - (3-5.3.6): Accept SUBMITFER= Carol A. Caldwell, Ca/dwell Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise text:

3-5.3.6 Scenario 6. ? ~ :=!~-afagt ~c;'c!c~i:g The most s~vere fire resulting from the largest possible fuel load characteristic of the normal operation of the building. This scenario shall address the concern of a rapidly developing fire with occupants present. SUBSTANTIATION: ff an ultrafast fire is not feasible for the building and contents as provided in the performance based design then it is inappropriate to require it to be modeled. What is appropriate is to model the worst likely fire development in the braiding or area. COMMITrEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 12

105



101- 156 - ($,-5.$.6 and A-3-5.3.61: Accept in Principle SUBMITTER: Morgan J. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace $-5.$.6 with the following:.

3-5.3.6 Scenario 6. A fire which represents the worst credible event resulting from the ignition source and fuel load conditions characteristic of the normal operation of the building.

Add the following at the end of A-3-5.3.6: "The SFPE Engineering Guide to Performance-Based Analysis and

Design describes a process for determining worst credible fires." SUBSTANTIATION: Although a fast growing fire with occupants present may be a challenge to life safety systems, a slow, smoldering fire may pose a larger challenge to life safety in some cases, such as in residential occupancies at night. The revised wording focuses on selection of a fire scenario that appropriately challenges a trial design for whatever the worst credible hazard event might be. COMMITEEE ACTION: Accept in Principle.

See Comment 101-1~5 (Log #264). COMMITTEE STATEMENT: The referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 137- (3-5.$.7): Reject SUBMITTER: Carol A. Caldwell, Caldwelt Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the following text:

SUBSTANTIATION: Why is it now important to model a mandatory exterior exposure fire when the prescriptive documents do not address the same concern. This makes the performance design as having to achieve design goals that are beyond the prescril?tive. For the limited times this is a necessary design fire, the design team can bring it up, it does not deserve specific mention as a mandatory design fire. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Exposure fires can occur. Th~ scenario helps avoid a single exit design where an exposure would prevent occupants from leaving the building. NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITIT, E ACTION:

AFFIRMATIVE: 12


101- 158- ($-5.3.8): Reject SUBM1TTER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete all of 3-5.3.8, Scenario 8. SUBSTANTIATION: This is an unreasonable non-creditable event. Reliability of systems must be evaluated separately from the time based performance-based life safety analysis. COMMITI"EE ACTION: Reject. COMMITTEE STATEMENT: Scenarios with failed systems are needed. However, see the rewrite effected by Comment 101-141 (Log #CC7), especially the new exception. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

Committee: 101- 159 - (3-5.$.8): Accept in Principle SUBMITTER: James R. Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete paragraph and replace with the following:

"Scenario 8. Where automatic snrinkler systems are included as a oart of the design, the reliability of the comoonents and the overall satstem shall be considered in the scenarios." SUBSTANTIATION: Assuming an entire system is not operational is not appropriate i f adequate safeguards have been provided. If performance-based design (PBD) requires one to assume systems won't work, the owner might as well not install them. COMMITTEE ACTION: Accept in Principle.

See Comment 101-141 (Log #CC7) that rewrites scenarios 8 and 9 into a new scenario 8 with an exception. COMMITTEE STATEMENT: The referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 140 - ($-5.~.8 Exception (New)): Accept in Principle SUBMITTER: Gregory W. Gallagher, NYS Dept+ of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add an Exception to read:

Scenario 8: Sprinklers Exception: When an approved reliability analysis for the system

~ roves this scenario is extremely unlikely to occur or the other uilding features that are redundant can compensate for the

hazards addressed by this scenario. SUBSTANTIATION: (None provided) COMMITTEE ACTION: Accept in Principle.

See Comment 101-141 (Log #CC7), that rewrites scenarios 8 and 9 into scenario 8 with an exception. COMMITTEE STATEMENT: The referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTF~ 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12

C (Log #CC7)

ommittee: SAF-FUN 101- 141 - (3-5.3.8, 3-5.3.9): Accept SUBMITI'ER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace Scenarios 8 and 9 with one new scenario (Scenario 8) that tests the performance of the design against a less-challenging, ordinary combustibles fire while the passive or active fire protection systems are rendered - one by one - unavailable. Expand information on the associated appendix material while retaining parts of the existing appendix language originally developed for scenarios 8 and 9. The wording will read as follows:

~ @ f l t a ~ . . . . - ~ ' ^ N & # ~ . . ^ ^ - = ' ~ . = - - ^ + : - - - - = - - ^ . A : . . . . . . . k . . . + : T . l ^ . ; ~

A fire orlt, inatln~ in ordinary combustibles in a room or area with each trassive or active fire nrotection system rendered - one bv one - ullayailable, This set of scenarios shall address the concern of each fire nrotection svstem or fire nrotection feature, considered indivldual-lv, bein~ unreliable or unavailable. ExceOtion:* Fire Orotection ~sterns for which both the ~,vd of rellabilit~ and the desia~ ~rfo~rnance in the absence of the s~stem a~e acceptable to the authorit~ havi'nt~ iuKsdiction. A-3-5.$.8 ~:enarlo 8 This scenario addresses a set of conditions with ~ typical fire ori~inatin~ in the buildin~ with any one nassive or active fire protection system or feature bein~ ineffective.

106

N F P A 101 ~ F9 9 R O C

Examples of this inc lude unn ro t ec t ed open ings between floors or b~tween fire walls or fire barr ier walls, r2ated fire doors fail to close a~,ltomatically or are blocked onen . spr inkler system water supply ~but-off. fire a larm system is non-oneradve , smoke managrement system no t operat ional , or au tomat ic smoke d a m n e r s b locked 9pen. This scenario shou ld r en re sen t a reasonable chal lenge to the o ther bui ldin~ features nrovided bv the design and n r e s u m e d to be available.

The concept of a fire o r i o n a t i n g in 'o rd inary combust ibles ' is intent ional lv selected for this event. This fire. a l t hough nresen t in~ a realistic chal lenge to the bui ld ing and the associated bui ldin~ systems, does no t r en re sen t the worst case scenario or the mos t ch~llengin~ fire event for the building.

(a) A fire or iginat in~ in ordinarv combust ibles in the corr idor of pa t ien t wing of a hosoital. S t a f f is a s sumed no t to close any

n a d e n t r oom doors u n o n detec t ion of fire. The basel ine occunan t characteristics for the n roner tv are assumed, and the na t ien t rooms off the corr idor are a s sumed to be filled to canacitv. At imaidon. dogrs 1;9 patieIlt Foollas arc n o t equ i pped witl~ self<losing devices a n d are a s sumed to be open t h r o u g h o u t the smoke comnar tmen t .

(b} A ~ ~.~.~ Sccne~o ~ ?m cx-~'n.ple cf a'.:ch a :zcnat{a "a c. A fire or iginat ing in ordinary combust ibles in a large assembly r o o m or area in the inter ior o f the building. The au tomat ic suppress ion systems are a s sumed to be ou t of operat ion. T h e basel ine occupan t characteristics for the proper ty are assumed, and the r o o m of origin is a s sumed to be filled to capacity. At ignition, doors are a s sumed to be closed t h r o u g h o u t the building.

(c) A ~ . $ . a Scc :~- :e 9 ?m cxa:'ap!c afauzh a zzcn-~---a ": a A fire or ig inat ing in ordinary combust ib les in an u n o c c u p i e d small func t ion r o o m adjacent to a large assembly room or area in the inter ior of the budding. T he au tomat ic de tec t ion systems are a s sumed to be ou t o f operat ion. T he baseline occupan t characteristics for the proper ty are assumed, the r o o m of origin is a s s u m e d to be unoccupied , a n d the assembly r o o m is a s s u m e d to be filled to capacity. At ignit ion, doors are a s sumed to be closed t h r o u g h o u t the building. A-$-5.8 Exeea t ion The Except ion is appl ied to each active or oassive fire pFgtection svstem-individualiv and reo_uifg~ ~w9 ciifferent woes of in format ion to be d e v d o n e d by analysis and annroved by the anthor i tv having iurisdiction. Svstemrel iabi l i tv is to be analyzed a n d accented. Desiwn ne r fo rmance in the absence of the system is also to be analvzed-an-d accented, bu t accentable pe r fo rmance n e e d n o t m e a n fully mee t in~ the stated goals a n d objectives. It may no t be nossible to m e e t fully the goals a n d obiectives with a key system unavailable, and vet no system is totally reiiable. The auth0r i tv hav ine iurisdiction will de te rmine what level of ne r fo rmance , possibly shor t of the s tated ~oals and obiectives, is accentable, given the very low probability (i.e.. the system's unreliabil i ty nrolaabilitv) tha t this s i tuat ion will occur.

Revise $-5.3 a n d A-3-5.3 as follows:

$-5.3* Requi red Scenarios. Scenarios shall include, bu t n o t be l imited to, those specified in $-5.~.1 t h r o u g h $ - 5 . $ . 8 ~ . Exception." Scenarios documented t~ the desien team to the satisfaction of ehe authori~ having jurlsdi~tion as inappropriate for the building use and conditions. A-3-5.$ It is desirable to r u n a wide variety o f different fire scenarios to evaluate the comple te life safety capabilities of the bui ld ing or s tructure. Fire scenarios shou ld no t be l imited to a single or a couple of "worst case" fire scenarios. Scena=-~c= ~ =rid 9

L L ' Z L - S 2 7 . L~ZZ-.:.~ _LL : ' Z : ~ _ " . . . . . . . . . . . . . . . . . . . . ~ - - ~ ' . . . . . . . c . . . .

Revise and move material f rom 3-4.3.1 to Secdon 3-$ Design Specifications, as follows:

$-$.1 Reta ined Prescriptive Requirements . ~ Systems and Features . All fire pro tec t ion systems

and features o f tlae bui ld ing shall comply with applicable NFPA s tandards for those systems a n d features , ~ .~ , _ = c ~ c a

system., cr f ~ a ~ . z . ~ Means of Egress. The des ign shall comply with the

f o | l o w i n g r e q u i r e m e n t s in addi t ion to the pe r fo rmance criteria o f Section $-2 and the m e t h o d s of Sections $-4 t h r o u g h $-9: . . . ( re ta in list as in ROP) $-~.l.$g-g,-l-~ Equivalency. Equivalent des igns for the features covered in the re ta ined prescriptive r equ i r emen t s m a n d a t e d by 3-3.1.1 shall be addressed in accordance with the equivalency provisions o f Section 1-9. A - ~ $ . I . 1 A - ~ 4 ~ This r eou i r emen t c=tegeD" vf a ~ u m p ~ v n = applies bo th to systems and features requ i red by the Cod~ tha t reference applicable s tandards, and to any addi t ional systems or features inc luded in the design at the discret ion of the design t eam ~ 4 d ~ . The referenced s tandards are hereby expected to state ma in tenance , testing, and o ther r equ i r emen t s n e e d e d to provide positive assurance of an acceptable level o f reliability. T h e re fe renced s tandards themselves may be prescriptive- or pe r fo rmance-based .

Revise $-4.3 and A-~4 . ] as follows:

$-4.5* Assumpt ions Regard ing Opera t ional Status an d Effectiveness o f Bui lding Features a n d Systems. ~- ~.~.! bl! fire prctecdvn :)=tern.= -_nd fezV.::~ cf ".he b'.=i!a--nZ :h=2! comply . . . . . . v r . . . . . . . . . . . . . . . . . . . . . . . . . . . I . . . . . . . . .

V.Lq2~27 ~q.2qZ..--~2".LL~'IT~7.;iLL~':-U:,~L..-~ .^,:~:,:~..~.,,

. . . . . k ' ~ ' " I . . . . . . . . 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ . o

Assumpt ions abou t the pe r fo rmance o f fire protec t ion systems and bui ld ing features shall reflect the d o c u m e n t e d pe r fo rmance of the components of those systems or features. A-~-4.3 . . . . . . . . ~ . ~ . . . . . . . . pt: . . . . v r . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . t l . . . . . . • . . . . ~ . . . . . . . . . . . . . . . r ' / ~ ' : '

~ ^ ~ . 1 ^ . 3 ~ . . . . . , , : . .1 . . . . :~: . . . . . . . . . . . . . . C ....... + ~ k l ~ 1 ^ . . ^ 1 ^C

re! 'a~L'v' . The re fe renced :'^..-~dard~ ".hzm=cl':z= m=.-" 5e ...... :~1 . . . . . . . . . 4 " . . . . . . . I - . ~ . ^ A l l " . . . . . " I t " . . . . . J l :" . . . . " " . . . . . . . . . . .

Systems addressed by this r e q u i r e m e n t inc lude automat ic fire suppress ion systems a n d fire a la rm systems. Pe r fo rmance issues tha t n e e d to be d o c u m e n t e d m i g h t inc lude response t ime indexes, d ischarge densi t ies a n d dis t r ibut ion patterns. Calculations shou ld no t inc lude an un l imi ted supply of ex t inguish ing ag en t if only a l imited supply will be provided in the actual s t ructure or building. S U B S T A N T I A T I O N : The revisions were m a d e in response to n u m e r o u s public comments . The mater ia l fu r the r explains the in ten t of SAF-FUN that a set of scenar ios is n e e d e d which addresses failure of systems a n d bui ld ing features. COMMITTEE ACTION: Accept . N U M B E R OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 12 VOTE ON C O M M I T T E E ACTION:

AFFIRMATIVE: 12

(Log#191) Commit tee : SAF-FUN

]01- 142 - (5-5.3.8 and $-5.5.9): Accept in Principle SUBMITTER: Morgan J. Hurley, Society o f Fire Protect ion Engineers COMMENT O N PROPOSAL NO: 101-12 R E C O M M E N D A T I O N : Add the following at t he e n d of pa ragraph A-$-5.$.8:

"This scenar io shou ld no t be r equ i red where an analysis shows that the suppress ion system is sufficiently reliable tha t its i m p a i r m e n t will no t reasonably be expected to o c c u r ?

Add the following at the end o f pa rag raph A-$-5.$.9: "This scenar io shou ld n o t be r equ i red where an analysis shows

that the de tec t ion system is sufficiently reliable tha t its im p a i rm en t will no t reasonably be expected to occur." SUBSTANTIATION: As written, it does no t appear tha t any au tomat ic suppress ion system-based except ions to prescriptive r equ i r emen t s that are current ly allowed will con t inue to m ee t the i n t ended objectives. Similarly, it does no t appear that any fire detect ion system-based except ions to prescriptive r equ i r emen t s that are current ly allowed will con t inue to m e e t the i n t ended objectives. Fu r the rmore it is doubt fu l that the goals and objectives stated in Sections 1-5 and 1-6 of Proposal 101-3 can be me t for residential

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occupancies if fire detection systems are assumed to be unavailable. COMMITTEE ACTION: Accept in Principle.

See Comment 101-141 (Log #CC7) that rewrites scenarios 8 and 9 into a new scenario 8 with an exception. COMMITTEE STATEMENT: The referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 143 - (3-5.3.8 and 3-5.3.9): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete scenarios 8 and 9. SUBSTANTIATION: It is inappropriate to assume that the fire detection and suppression systems will not be functioning in lieu of an appropriate reliability analysis. Detection and suppression systems installed and maintained in accordance with NFPA standards provide an acceptable level of reliability without the need for considering redundant requirements. COMMITTEE ACTION: Reject. COMMrrFEE STATEMENT: Scenarios with failed systems are needed. However, see the rewrite effected by Comment 101-141 (Log #CC7), especially the new exception. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12


101- 144 - (3-5.3.9): Accept in Principle SUBMrI'rER: James IL Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete paragraph and replace with the following:

"Scenario 9. Where automatic fire alarm systems are included as a hart of the desires, the reliability of the comnonents and the overall system shall be considered in the scenarios." S U B S T ~ T I A T I O N : Assuming an entire system is not operational is not appropriate if adequate safeguards have been provided. If performance-based design (PBD) requires one to assume systems won't work, the owner might as well not install them. COMMITTEE ACTION: Accept in Principle.

See Comment 101-141 (Log #CC7). COMMII~'EE STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 145 - (3-5.3.9 Exception (New)): Accept in Principle SUBMITTER: Gregory W. Gallagher, NYS Dept. of State COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add an Exception to read:

Scenario 9: Alarm Exception: When an approved reliability analysis for the system

proves this scenario is extremely unlikely to occur and the other building features that are redundant can adequately compensate for this scenario. SUBSTANTIATION: (None provided) COMMITTEE ACTION: Accept in Principle.

See Comment 101-141 (Log #CC7). COMMITTEE STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 146 - (3-5.3.10 (New)): Accept in Principle SUBMITTER: Kenneth F~ Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add a scenario 10 as follows:

"A fire originating in ordinary combustibles in a room adjacent to a cridcal nonoccupied area and the fire-resistive construction has been breached by penetrations and fire doors (including automatic closing doors) have been propped open. This scenario shall address the concern of the fire possibly escaping the room of fire origin when the compartment is either unreliable or unavailable." SUBSTANTIATION: Proposed scenarios 8 and 9 address possible failures of detection and suppression systems, but nowhere does the performance based code require the user to consider failures in compartmentation.

A study by CIGNA on 368 randomly selected Highly Protected Risks found fire door failures or obstructions in 6 percent of their properties. If this is the percentage for Highly Protected Risks, what is the percentage for ordinary occupancies?

Penetrations in fire resistive construction have been the cause of many catastrophic fires in recent history including the fire at 1 Meridian Plaza in Philadelphia. In this Type 1 Fire Resistive Construction, the fire started near the electrical system utility shaft and burned its way into this shaft through penetrations in the fire resistive construction. Just as the fire department arrived on he scene, the fire burned through the electrical wiring cutting power to the building and the electric motor driven fire pump. The fire continued up seven more floors through penetrations in fire resistive floors and ceilings burning everything in its path.

Buildings such as the one at 1 Meridian Plaza should not be capable of passing the performance based option of the code, but without this scenario, we are afraid that they will. COMMITTEE ACTION: Accept in Principle.

See Comment 101-141 (Log #CC7). COMMITTEE STATEMENT: The acdon on the referenced comment should meet the submitter's intent. NUMBER OF COMMrI'TEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #CC1 $) Committee: SAF-FUN

101- 147 - (?,-6): Accept SUBMITI'ER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete SECTION 3-6 DATA by distributing its contents as follows:

Move paragraphs 3-6.1 through ?,-6.$ to SECTION 3-7 under a new paragraph ?,-7.$ Input Data, and renumber as 3-7.3.1 through 3-7.3.3. Reriumber current 3-7.3 and 3-7.4 as $-7.4 and 3-7.5 respectively.

Move paragraph ?-6.4 Scenarios Data to SECTION 3-5 SCENARIOS and renumber as 3-5.4.

Move paragraph 3-6.5 Assumptions Data to SECTION 3-4 ASSUMPTIONS and renumber as ?,-4.2. Delete current 3-4.1.2 and 3-4.1.3. Renumber paragraphs ~4.2 through 3-4.9 accordingly.

Move paragraph $-6.6 Design Specifications Data to SECTION 3-3 DESIGN SPECIFICATIONS and renumber as 3-3.1. Renumber current paragraph 3-3.1 as 3-3.2.

Move paragraph 3-6.7 Sources of Data to SECTION 3-1 and renumber as 3-1.5. Renumber current paragraphs ?-1.5 through 3-1. as 3-1.6 through 3-1.8.

Renumber SECTIONS 3-7 through 3-9 as 3-6 through 3-8. SUBSTANTIATION: As seen in Figure A-3 Sections 3-2 through 3-9, with the exception of Section 3-6, are all a part of a process. The requirements in Section 3-6 could be better located in the respective Sections to which they relate. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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101- 148 - (3-6.1): Reject SUBMITTER: Jonas L. Morehart , Punta Gorda, FL COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Delete the entire paragraph, by turning it into an Appendix paragraph, and changing the word "shall" to "may". SUBSTANTIATION: A straight-out requirement to use ASTM E 1591 would limit a fire modeler's capability to consider new information until it was published by ASTM. By allowing ASTM E 1591 through the use of the word "may" in the Appendix would provide more flexibility. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: ASTM E-1591 tells generally bow to develop input criteria for fire models. It provides a framework, so the submitter's snbstantiadon is incorrect. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 149 - (3-6.1): Accept in Principle SUBMITrER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Add new text after the existing text as follows:

"Data for use in analytical models that are not computer based shall be obtained using appropriate measurement, recording, and storage techniques to ensure the applicability of the data to the analytical method be ing used." SUBSTANTIATION: The intent of this statement is to ensure that any data used in the analysis is appropriate to the situation (e.g., similar test and application geometries and conditions, recording of uncertainty bands, etc.). COMMI'FrEE ACTION: Accept in Principle.

Revise 3-6.1 to read: 3-6.1 Data. Input data for computer fire models shall be obtained

in accordance with ASTM E 1591 Standard Guide for Fire Models. Data for use in analytical models that are not computer-based fire models shall be obtained using appropriate measurement, recording, and storage techniques to ensure the applicability of the data to the analytical method being used. COMMITIT_~ STATEMENT: The Committee Action accomplishes what the submitter suggested but also makes further modifications to specify that these are fire models. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 150 - (3-6.3 and A-3-6.5): Accept in Principle SUBMITTER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace 3-6.3 and A-3-6.5 with the following:

3-6.5* Accounting for Known Variations and Unknown Effects. Any uncertainty in input data shall be considered to ensure confidence in the final design.

A-3-6.3 The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design outlines a process for identifying and treating uncertainty. SUBSTANTIATION: T h e present wording only says that data must be conservative, but it does not identify how to ensure that it is conservative. The referenced document outlines a process for identifying and treating uncertainty (see Section 10-5). COMMITTEE ACTION: Accept in Principle.

I eplace 3-6.5 and A-3-6.5 with the following: 3-6.5* Uncertainty and Conservatism of Dat~ Uncertainty in

input data shall be analyzed and, as determined appropriate by the authority having jurisdiction, addressed through the use of conservative values.

I A-3-6.3 Procedures used to develop...(continue with ROP text)...dealing with uncertainty. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design outlines a process for identifying and treating uncertainty. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 151 - (3-7): Accept SUBMITTER: Morgan J. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Change the title of Section 3-7 to "Evaluation of Proposed Designs". SUBSTANTIATION: The new language will better describe the proce~ of "assessing performance" of proposed designs to determine if they are acceptable. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMI'I'FEE ACTION:

AFFIRMATIVE: 1 2


101- 152 - (3-7): Accept in Principle SUBMITrER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace appendix A-3-7 with the following:

A-3-7 The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design describes a process for evaluating whether trial designs meet the performance criteria during the design fire scenarios. SUBSTANTIATION: The text proposed in A-3-7 describes analysis (engineering) methods and is not explanatory material for the code requirements. The language in the appendix only lists tools that may be used in evaluation, but does not indicate how the tools may be used. Also, there are no references to the literature. Without references to the literature, it may be impossible for engineers and authorities having jurisdiction to further develop the incomplete concepts. The SFPEEngineering Guide to Performance-Based Fire Protection Analysis and Design identifies probabitistic and deterministic evaluation methods, identifies tools that can be used in evaluation, and gives guidance on the used of the tools and methods identified. As such, it gives a far more comprehensive treatment of the subject.

A companion comment suggests adding a new paragraph at the beginning of A-3-7, which, if accepted, would precede this text. COMMITTEE ACTION: Accept in Principle.

Retain proposed appendix A-~-7 and add the following to the beginning o f it:

"The SFPE Engineer ingGuide to Performance-Based Fire Protection Analysis and Design outlines a process for evaluating whether trial designs meet the performance criteria during the design fire scenarios." COMMITTEE STATEMENT: The material proposed by the submitter is appropriate for inclusion into the appendix material; however, the remainder of the appendix material needs to be retained. This should meet part of the submitter's concern. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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101- 153 - (3-7): Accept in Principle SUBMITTER: N o r m a n E. Groner , Santa Cruz, CA C O M M E N T ON PROPOSAL NO: 101-12 RECOMMENDATION: Add the following to append ix A-3-7 u n d e r the subsec t ion en t ided "Test":

" H u m a n and Organizat ional Per fo rmance Tests. Certain tests de te rmine whe the r innu t s used to de t e rmi ne h u m a n performar , g¢ criteria r emain valid du r i ng the occunancv of a building. Tests of h u m a n and oreanizafional nerforrnance mi gh t inc lude anv of the following: Evacuat ion t imes m e a s u r e d du r ing fire drills: ouervln~ emert tencv response team m e m b e r s to de te rmine whe the r they know reoui red nrocedures : and. field tests to ensure that emergency resoonse team m e m b e r s can exe~ot;q tasks within n r e d e t e r m i n e d t imes a n d accuracy limits. Des ign t~rooosals shou ld i n d u d e descr iot ions of any tests tha t are n e e d e d to de te rmine whe the r s tated goals, objectives a n d ne r fo rmance criteria are be ing met ." S U B S T A N T I A T I O N : T h e cu r r en t absence of any provision for tests of h u m a n and organizat ional pe r fo rmance may be in te rpre ted as a prohib i t ion on thei r use. W h e n a p roposed des ign includes pe r fo rmance criteria for h u m a n a n d organizat ional per formance , co r respond ing "tests" shou ld be inc luded to m e a s u r e that pe r formance . If the design d e p e n d s on h u m a n or organizat ional

~ er fo rmance to mee t pe r fo rmance criteria, t hen those aspects of u m a n pe r fo rmance shou ld be subjected to tests, a n d shou ld no t

be t reated s imply as assumpt ions . COMMITTEE ACTION: Accept in Principle.

I Add the wording sugges ted by the submi t te r bu t do so so tha t it is pos i t ioned j u s t before the material on "mode l ing ' . COMMITTEE STATEMENT: T h e Commi t t ee Act ion accepts the language submi t ted and specifies exactly where it is to be

sit ioned. This shou l d m e e t the submit ter ' s intent . ER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12



101- 154- (3-7): Accept SUBMYrTEP¢ George M. Lanier , R ome Fire Dept. , GA COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In new append ix A-3-7 on page 81 of the ROP, if appropria te , in the last l ine o f the four th pa rag raph in the r ight co lumn, revise the last sen tence to read:

"The room enclosure surfaces themselves also contr ibute to this r ~ a f i o n feedback effect". S U B S T A N T I A T I O N : I want to be clear on what the commi t tee means . I have no t ed in o ther publ icat ions the use of the te rm "radiat ion feedback" be ing used to describe what is discussed in the paragraph . I felt the word "radiation" shou ld be inser ted to be consis tent with o ther publ ica t ions if such is appropr ia te . T h e more clear the te rm used in Chapte r 3 and its append ix the bet ter for mos t author i t ies hav ing jur isdic t ion. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 V O T E ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 155 - (3-7): Accept SUBMITTER= Carol A. C~dwell , Caldwell Consul t ing Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise a p p e n d i x A-3-7, ROP page 80, r ight co lumn, second a n d th i rd pa ragraphs to read:

"CFD mode l s provide the mos t accurate predict ions of all t he determinis t ic models because they divide a given space into t housands of smal ler volumes. However, s ince these are still models , they are no t absolute in their depic t ion of reality. In addit ion, they are m u c h more expensive to use because theory are computa t iona l ly intensive.

Zone mode l s are more widely u sed t han CFD mode l s because they provide reasonably accurate predic t ions in m u c h less t ime.

cnc lo :urc . Because zone mode l s sacrifice accuracy for ease of use

J their predic t ions require a greater a m o u n t of scrutiny t h an do those o f CFD models ." S U B S T A N T I A T I O N : The sen tence is inaccurate . Zone mode l s are typically two zones, an uppe r layer a n d lower layer. T h e re ference to 10 volumes does no t make sense. COMMI'VrEE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #271) Commit tee: SAF-FUN

101- 156 - (3-7): Accept in Principle SUBMITTER: Carol A. Caldwell, Caldwell Consul t ing Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise append ix A-3-7, ROP page 80, r ight co lumn, s econd and th i rd paragraphs to read:

"CFD mode l s provide the mos t accurate predic t ions o f all the determinis t ic mode l s because they divide a given space into t housands of smal ler volumes. However, s ince these are still models , they are n o t absolute in their depic t ion of reality. In addit ion, they are m u c h more expensive to use because they are computa t ional ly intensive. Because 9f thei r expense , complexity. a n d intensive comouta t iona l needs. CFD mode l s r eau i r e m u c h ureater scrut iny t h e n do zone models . It is m u c h m o r e difficult to Qrovide mui t io le runs o f CFD mode l s to check sensitivitv to a warietv of factors such as desima fire cell resolution, ventilation. The 9 ~ p u t can be a pretty, p ic ture vet. for the un i fo rm ed the flows could be totally wrong.

Zone mode l s are more widely used t h a n CFD models because they provide reasonably accurate predic t ions in m u c h less t ime. It is m u c h easier to assess sensitivity o f d i f ferent uaramete rs with zone mode l s because they general ly r u n m u c h faster and the o u to u t is m u c h easier to intei 'oret. Predic t ion o f fire ~rowth a n d sn read has

large n u m b e r 9 f variables associated with it. conseouen t lv the ~QB¢ lllq~l¢]~ with their c rudeness and soeed has advantages over the m o r e comvlex CFD models . 7 ^ _ ~ - ~ . ~ 1 . ~ - : ~ . . . ,:.~ t~.. t_h.a.n tcn ;'~!~m~= t~ dcF 'c t : gi; 'cn cnc!c.:ur¢. E¢ .~u:c z~nc m~$cl= mcr 'Ncc :zz~raz7 f~.r caz¢ ~f ~:c, "&clr p r c ~ c ~ ¢ n : requlrz a g r c a t e r m.'nc.u:~: c.f :zr='2.'~ 7 "..~.---=: ~c. khc.~c c.f C.r~ ..'nc.~c!:." SUBSTANTIATION: The in format ion p resen ted on zone an d CFD mode l s is misleading. Zone mode l s are very crude but they certainly are adequa te for a majori ty o f compu te r mode l ing that may be necessary. Due to their c rudeness the speed is r educed an d checking o f d i f ferent scenar ios is simplified. The original wording implied tha t CFD mode l s will provide more valid results with less change of an error. However, because the CFD mode l s are m o re precise the accuracy o f the i npu t da ta is m u c h m o r e impor tant . The i r complexi ty actually can increase the chance of unde t ec t ed errors. COMMITTEE ACTION: Accept in Principle.

Revise a p p e n d i x A-3-7, ROP page 80, r ight column, second an d third paragraphs to read:

"CFD mode l s provide the mos t accura te predic t ions of all the determinis t ic mode l s because they divide a given space into thousands o f smal ler volumes. However, s ince these are still models , they are no t absolute in their depic t ion o f reality. In addit ion, they are m u c h more expensive to use because they are computa t ional ly intensive. Because o f thei r exoense , comnlexi tv and intensive comtmta t iona l needs . CFD mode l s reoui re m u c h greater scrut iny t h e n do zone models . It is m u c h m o r e difficult to

! ~rovidg II~ulti_n'le runs of CFD mode l s to check sensitivity to a variety of factors such as design fire cell resolut ion, ventilation.

Zone mode l s are more widely used t han CFD mode l s because they orovide reasonably accurate nredic t ions in m u c h less t ime. It i~ m u c h easier to assess sensitivitv o f different r~arameters with zone mode l s because they general ly r u n m u c h faster an d the o u tn u t is m u c h easier to inte~oret. Predict ion of fire growth and snread has a large o t jmber of variables associated with it. consecmentlv the zollg models with their c rudeness a n d sneed have advantages over ~ e m o r e complex CFD models . 7 ^ _ ^ - - . ^ . ~ ^ t . . - : ~ . . . . . . . ~ .

t h : = :z:. -:c2=mc~ tc. ~¢p'~ct :. g ' vcn ¢:c!~==r:. E = ~ ' ~ ¢ : ~ : z

= -rcr.=cr a==~:nt c£ :cr='2= 7 tkcm ~.~ "&c~zz c.f mc~..z!:." C~MMITTEE STATEMENT: T h e Commi t t ee Act ion accompl ishes tha t which the submi t t e r suggested, however, omits

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the last sentence of the first paragraph because it is open to misinterpretation. This should meet the submitter's intent. NUMBER OF COMM1TI'EE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 157 - ($-7.1): Accept SUBMFFFER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise as follows:

3-7.1 General. A proposed design's performance shall be assessed relative to each performance objective in Section 1-6 and each applicable scenario in Section 3-5, with the assessment conducted through the use of appropriate calculation methods, cara..putcrize~ .'..c~el:ng prcg.~:..:. The authority having jurisdiction shall approve the choice of assessment methods. SUBSTANTIATION: The text as it presently reads would require the use of computer fire models. There will be situations where hand calculations, fire tests, etc. will be suitable in lieu of computer fire models.

A companion proposal would change "fire scenario" to "design fire scenario" in this paragraph. COMMITTEE ACTION: Accept. NUMBER OF COMMITIT~ MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #269) Committee: SAt-FUN

101- 158 - ($-8.1): Accept in Principle SUBMITTER: Carol A. Caldwell, Caldwell Consulting Ltd. COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Revise appendix A-$-8.1 fourth paragraph, Reasonableness Check, to read:

"A margin of safety can be developed using the results of the sensitivity analysis (to provide the possible range of when a condition is estimated to occur) in conjunction with the performance criteria. ..Where i: ..~-'-'c.h !.n *,.he !'te.--_~re Lhat ~ a ! : ;;-=.h t.hc :a~ia: af :a£c-'7 ~c . . "z =::d ..'x~-a--.':~ ,~f az, fc.%'. SUBSTANTIATION: The sentence should be deleted. There is not much information in fire literature on safety factors and margins of safety. That sentence would imply to the authority having jurisdiction that there is a lot of information on the topic as it relates to fire. Yet, the SFPE Handbook and the Nb-'PA Handbook do not provide any information on these topics. These are two of the most widely used sources of information and they do not address the topic. COMMITTEE ACTION: Accept in Principle.

I Do what the submitter requested and additionally editorially, revise ROP page 82, A-$-8.1, second paragraph from the bottom of the left column from "to safely evacuation" to "to safely evacuate". COMMITTEE STATEMENT: The Committee Action does everything the submitter requested and additionally performs the one editorial correction. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 159 - (3-8.1, A-$-8.1): Accept in Principle in Part SUBMITrER: MorganJ. Hurley, Society of Fire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace $-8.1 with the following:

3-8.1 Safety F~/ctors. Safety factors shall be used as identified during the uncertainty analysis required by 3-6.3.

With the exception of the last two paragraphs, delete all of A-3.8.1. SUBSTANTIATION: With the exception of the last two paragraphs (which this comment proposes to maintain) the text in A-3.8.1 is an engineering approach to solving a problem and not explanatory material for the code itself. Also, the proposed method is not complete, and does not include references to the

literature. Without references to the literature, it may be impossible for engineers and authorities having jurisdiction to further develop the incomplete concepts. The SITPE Engineering Guide to Performance-Based Fire Protection Analysis and Design contains a far more comprehensive discussion of the process o f identifying and accounting for uncertainty, and gives guidance on the used of the tools and methods identified. See companion comment on paragraph 3-6.3. COMMITTEE ACTION: Accept in Principle in Part.

In lieu of doing what the submitter requested, add the word "data ~ to current $-8.1 so that it reads:

"...to reflect uncertainty in the assumptions, data and other factors associated with...". COMMITFEE STATEMENT: The Committee Action accomplishes part of what the submitter requested. Safety factors are intended to cover more than just input data. They need to cover uncertainty wl~la respect to assumptions arid models. NUMBER OF COMMITEEE MEMBERSELIGIRLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

Committee: 101- 160 - ($-9): Accept in Part SUBMITI"ER= MorganJ. Hurley, Society o f F ire Protection Engineers COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: Replace appendix A-3.9.1 with the following:

A-3.9.1 The SFPE Engineering Guide to Performance-Based Fire Protection Analysis andDes ign describes the documentation that should be provided for a performance-based design.

Proper documentation of a performance design is critical to the design acceptance and construction. Proper documentation will also assure that all parties involved understand what is necessary for the design implementation, maintenance, and continuity of the fire protection design. If attention to details is maintained in the documentation, then there should be little dispute during approval, construction, starmp and use.

Poor documentation could result in rejection of an otherwise good design, poor implementation of the design, inadequate system maintenance and reliability, and would provide an incomplete record for future changes or if the design were forensically tested.

Delete $-9.2 through $-9.13. SUBSTANTIATION: The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design provides a more thorough treatment of the documentation that should be provided to support a performance-based design.

Also, the present wording in A-$-9.1 casts a disparaging light on "design professionals." The wording proposed in this comment would more accurately reflect the purpose of documentation. COMMITTEE ACTION: Accept in Part.

I Replace A-$-9.1 with the wording proposed by the submitter. However, do not delete $-9.2 through 3.9.13. COMMITTEE STATEMENT: The submitter's verbiage improves the document. However, the list of design aspects to be documented needs to be retained. This should meet part of the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #CCS) Committee: SAt-FUN

101- 161 - (3-9.3): Accept SUBMITFER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-12 RECOMMENDATION: In two place change "survivability" to "performance" so as to read:

$-9.3 Performance Criteria. Performance criteria, with sources, shall be documented. SUBSTANTIATION: The change in terminology is being made for agreement with other changes. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

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The following draft of proposed CHAPTER 3 PERFORMANCE- BASED OPTION incorporates the Committee Actions on Comments 101-60 through 101-84 and Comments 101-91 through 101-161. The draft is provided as an aid to the reviewer.

CHAPTER 3* PERFORMANCE-BASED OPTION

SECTION 3-1 GENERAL REQUIREMENTS

3-1.1 Application. The requirements of this chapter shall apply to life safety systems designed to the performance-based option permitted by 1-8.3.

3-1.2 Goals and Objectives. The performance-based design shall meet the goals and objectives of this Code in accordance with Sections 1-5 and 1-6. '~

3-1.3" Approved Qualifications. The performance-based design shall be prepared by a person with qualifications acceptable to the authority having jurisdiction. ( See also 3-8.12.)

3-1,4" Independent Review. The authority having jurisdiction shall be permitted to require an approved, independent third-party to review the proposed design and provide an evaluation of the design to the authority having jurisdiction.

3-1.5 Sources of Data. The source shall be identified and

In.put Data Specification. Information required by the verification method.

Occupant Characteristics. Abilities or behaviors of people before and during a fire.

Performance Criteria.* Threshold values on measurement scales based on quantified performance objectives.

Proposed Design.* Design developed by a design team and submitted to the authority having jurisdiction for approval.

Safe Location. Location remote or separated from the effects of a fire such that those effects no longer pose a threat.

Safety Factor. Factor applied to a predicted value to ensure that a sufficient safety margin is maintained.

Safety Margin. Difference between a predicted value and the actual value when a fault condition is expected.

Sensitivity Analysis. Analysis performed to determine the degree to which a predicted output will change given a specified change in an input parameter, usually in relation to models.

Stakeholder. An individual, or representative of same, having an interest in the successful completion of a project.

documented for each input data requirement that must be met .~.~::, using a source other than a design fire scenario, an assumption, or Uncertai..~_~r""~.dsis. Procedure undertaken to determine the a building design specification. Such data shall be characterized as degree t # ~ j c h a predicted value might vary. to the degree of conservatism reflected, and a justification for the .~" ":%.~:=:~ source shall be provided. V e ~ t i o n " ~ h o d . Procedure or process used to indicate that

t l X ~ s e d c l ~ ~ meet the specified criteria. . . . . . . . . . . . ~. - -,~ .:,~.::~.-:'.~', $-1.6 Final Determination. The authority havangjunsdiction shall d;" ,. ':~g'-': make the final determination as to whether the performance ~i.-':. ":~:'-% SECT-ION 3-2 PERFORMANCE CRITERIA objectives have been met. 6":~ ::"~i~:.-:~.:. ~#"~::.

3~l~i~..General. A design shall meet the objectives specified in $-1.7" Maintenance of Design Features. The design features .:..., Sec~'~:~z,.6:...if, for each design fire scenario, assumption and design required for the building to continue to meet the performance '~.-~. : :~ s p e c i t ~ f ~ n , the performance criterion in 3-2.2 is met.

. . . . . . ,q. "~-?~.f...::.':~x.. ::::~ oals and objectaves of th~s Code shall be mmntmned for the life of ~... ",:-:i.~::.'_.-.'..':..-.: ~-" t~e building. This shall include complying with all documented '% ,~-:.-"~:~.~" Performance Criterion. No occupant not intimate wim assumptions and design specifications. Any variations ., ~'..:!i:.<*" igfiltion shall be exposed to instantaneous or cumulative untenable the approval of the authority having jurisdiction prior ~., . conditions. change. (See a l s o 1-11.10.2.)

~i}J":'" SECTION 3-3 RETAINED PRESCRIPTIVE REQUIREMENTS 3-1.8 Special Definitions. ~-'~"

3-3.1" Systems and Features. All fire protection systems and

s ~ , q u i r e .~thd~tual

x~.-'., i~!::

..:~-'. ".<-~:'-'~.%x., x'~$... ... 4- Alte~ative C~dculation Procedure. Proc~.~'re g'~t fr~e

one originally employed by the design teat~'.but whic~"i~ovi_~'~s predictions for the same variables of i n t ~ " ~ . ~ .-.-':~.-.- "

Data Conversion. Process of developing the i ~ ' ~ set for the assessment method of choice.

Design Fire Scenario. A fire scenario selected for evaluation of a proposed design.

Desi[pa Specifications. * Building characteristics and other conditaons that are under the control of the design team.

Design Team. Group of stakeholders including, but no t limited to, representatives of the architect, client, and any and all pertinent engineers and other designers.

Exposure Fire. Fire that starts remote from the area being protected but grows to expose that which is being protected.

Fire Model.* Structured approach to predicting one or more effects of a fire.

Fire Scenario.* A set of conditions that defines the development of fire, the spread of combustion products throughout a building or part of a building, the reactions of people to fire, and the effects of combustion products.

Fuel Load.* The total quantity of combustible contents of a building, space, or fire area.

Incapacitation. Condition where humans do not function adequately and become unable to escape the untenable conditions.

features of the building shall comply with applicable NFPA standards for those systems and features.

3-3.2 Means of Egress. The design shall comply with the following requirements in addition to the performance criteria of Section 5-2 and the methods of Sections 3-4 through $-8:

Changes in Level in Means of Egress - 5-1.6 Guards - 5-1.7 Doors - 5-2.1 Stairs - 5-2.2

Exception: The pwvisions of 5-2.2.5.1, 5-2.2.5.2, 5-2.2.6.3, 5-2.2.6.4 and 5-2.2.6.5 shall be exempted. Ramps - 5-2.5

Exception: The provision* of S-Z5.3.1, 5-2.5.5 and 5-2.5.6.2 shdll be exempted. Fire Escape Ladders - 5-2.9 Alternating Tread Devices - 5-2.11 Capacity of Means of Egress - 5-$

Excepaon: The provisions of 5-3.3 and 5-3.4 shall be exempted. Impediments to Egress - 5.-]5.2 Illumination of Means of Egress - 5-8 Emergency Lighting - 5-9 Marking of Means of Egress - 5-10

3-3.3 Equivalency. Equivalent designs for the features covered in the retained prescriptive requirements mandated by 3-3.1.1 shall be addressed in accordance with the equivalency provisions of Section 1-9.

SECTION 3-4 DESIGN SPECIFICATIONS AND OTHER CONDITIONS

3-4.1" General.

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5-4.1.1 Clear Statement . Design specifications and o ther condi t ions u sed in the pe r fo rmance-based des ign shall be clearly s tated and shown to be realistic a n d sustainable.

3-4.2 A s s u m p t i o n s a n d Des ign Spec i f i ca t ions Data.

3-4.2.1 Each a s sumpt ion a n d design specification used in the design shall be accurately t rans la ted into i npu t da ta specifications, as appropr ia te for the calculat ion m e t h o d or model .

3-4.2.2 Any as sumpt ion and design specifications tha t the design analyses do no t explicitly address or incorporate , and which are therefore omi t ted f rom i npu t data specifications, shall be identified, a n d a sensitivity analysis of the consequences of tha t omiss ion shall be per formed•

3-4.2.3 Any assumptior i and des ign specifications modif ied in i n p u t da ta specifications, because o f l imitat ions in test me thods or o ther da ta gene ra t ion procedures , shall be identified, a n d a sensitivity analysis of the consequences of the modif icat ion shall be per formed.

5-4.3 Building Characteristics. Characteristics of the bui ld ing or its contents, equ ipment , or operat ions no t i n h e r e n t in the design specifications, b u t tha t affect occupan t behavior or the rate of hazard deve lopmen t shall be explicitly identified.

s tated goals a n d objectives shall be specified, est imated, or character ized sufficiently to evaluate the design.

$-4.9* Consis tency o f Assumpt ions . The des ign shall no t inc lude mutua l ly incons is ten t assumpt ions , specifications or s t a tements o f condit ions•

8-4.10" Special Provisions. Addit ional provisions no t covered by the above des ign specifications, condi t ions , es t imat ions a n d assumpt ions bu t tha t are requ i red for the design to comply with the pe r fo rmance objectives shall be d o c u m e n t e d .

SECTION 3-5" DESIGN FIRE SCENARIOS

8-5.1 Design Fire Scenarios. The author i ty having jur isdic t ion shall approve the pa ramete r s involved with des ign fire scenarios. The p roposed des ign shall mee t the goals and objectives if it achieves the pe r fo rmance criteria for each requi red des ign fire scenario. (See 3.5.3.)

3-5.2* Evaluation. Design fire scenarios shall be evaluated for each requi red scenario us ing a m e t h o d acceptable to the author i ty having jur i sd ic t ion a n d appropr ia te for t he condit ions. Each scenario shall be chal lenging, bu t realistic, with respect to a t least one of the following scenario specifications: initial fire location, early rate of growth in fire severity or smoke genera t ion . Th e scenario specifications shall be as cha l lenging as could realistically

3-4.4* O p e r a t i o n a l Status a n d Ef f ec t i venes s o f Bui ld ing Features occur in the building. and Systems. The pe r fo rmance of fire protec t ion systems and ~/::x bui ld ing features shall reflect the d o c u m e n t e d pe r fo rmance of the 3-5.3* R ~ e s i g n Fire Scenarios. Scenarios selected as c o m p o n e n t s of those systems or features unless des ign des ign f~.~x~enariros shall include, bu t no t be l imited to, those specifications are incorpora ted to modify the expected s p e c l ' ~ iri":i-~.~$.l t h rough 3-5.$.8. pe r fo rmance . . . . ".~.. ' ~ . .

'':~ ~ :"'~" i~i • $-4.5 O c c u p a n t Characterist ics . ~'=iisfact'l~on of the ~ o r i 0 having jurisdiction as inappropriate for the

~}~..~Ild2~ use and ~'ndltwns. * e <" ::.:$.:$ .'~:.~ 3-4.5.1 Gen ral. The selection of occupan t characteristics to be ~ : "~ , . .~ . ~

used in the des ign calculations shall be approved by the author i ty ~ * "Design Fire Scenario 1 An occuoancv-snecific desi~,n fire having jur isdic t ion a n d shall provide an accurate reflection o f t h % . sce r~ . . . r#p re ' s en ta t ive of a typic.a1 fire fo r ' t he occupancy. T°his expec ted popu la t ion of bui ld ing users O c c u p a n t charactenst ics .~ desl .-y~'~ • " " " " " ~ s ~ i ~ : "g "~ :g scenario shall exl~licifly accoun t for:. occupan t activities, shall r ep resen t the no rma l occupan t profile, unless design % * ' ~ . : - ' ~ ' ~ - ~ r ~ a n d lacatinn- rcmm ~izp. f,,rnigh;no.g a n d eantpnt*, fi,*l specifications are used to modify the expected occupan t features. "?o .~-~t - t ies - - ' andi~:n i f i 'onsou"rc-esT 'an '~ l 'ven" t i l ' a t ]on 'co~ ' ]~ '~ ', " : l~e • • • ~::'~ .4:-" t'~.-.t~ g , • O c c u p a n t characteristics shall n o t vary across fire scenarl.~.i:~xeept ~.'.~- t i n t i tem io'nited and its locat ion shall be exnlicid~ def ined as or . . . . . . . ~ s . ".~s. o-- r ~ • au th lzed by the au thor i ty h a w n g j u n s d t c t i o n . #" "-.+.:::.-: ":'4 .~.,~ ~...'-:~.~ :~........~.*

~i'~%'. ":¢-"..x ~ ';q~" B-5 $ 2" Desi Fire Scenario 2 An ultrafast-develo in fire in 3-4.5.2* Response Characterist ics. Each o f the f o t f i S ~ . ~ b ~ % . . %*" " " • gn -" • • P g ' . . . . .x.-:-: ",~:.--':::-.-x::: the pr imary m e a n s of egress, w~th inter ior doors o en at the start of pe r fo rmance characterlsUcs shall be considered: sen s i b I ~ '*:~:~:~:~.* ~ ~..~ Tu: . a ^ . : ~ ~ . . . . . . . :^ .u^, , ^ an . . . . . t. p . . . . . . .

• • ~ - 1 . , . - - . 1 . ~ • . . . . - ~ . ~ - ~ , 1 "*" • t h g L i l t . l l l l O ~.lkCbl~ll J L I / g ~ L g L | ~ . J [ I O ~ l l d . l l ~ J . ~ L I g I ~ I ~ U l g L O I L I L g I | J . O I L r eac tmty monluty, a n n susceptit)luty. Jnese ~ o n s ~ ~ . . . . . . . . . . m - ' . . . . . . . - -.~--~-x...:~:. :..:.:-:~ .~ r educ ing m e n u m n e r oI available means o t egress. r enec t m e expectect a l s t n n u u o n ox charactV.tt~tics ~.~@opurg!Ra'n - appropr ia te to the use of the building. ~ " ource d~:ik~ta f cU . . , ° . . . . . . . . . . . . . . . the ch te . . . . . . . . tc4:Y~i~ :"~:~ ~-~.~.~ u e s t g n r~re ~ c e n a n o ~. ~ nre , s t a rung m a n o r m m q se arac n sucs snail De n o c u m e n t o a , x~}~, ~ . . ? . . . . . ,

~ ~,>." u n o c c u p l e a room, tha t can potenual ly e n d a n g e r a large n u m b e r . . . . . . . . . . . . . . . . "~.~i::, .:!~-"--. of occupants in a large r o o m or o ther area. This des ign fire ~-,L~.2~ Locauon , it snail De assumect m a t in e " , n o . ~ a n y , . .

. . . . . . ~ , ~ . n ~ . . . . . scenario shall address the concern of a fire s t a rung m a normal ly occu leu r o o m or a rea at least one pe r son snail o,~,$.-.t~cateo at m e . . . . . . . . P . . . . . . . - ~ u n o c c u p l e a r o o m a n n migra t ing into m e space tha t can, mos t r emote po in t n-om m e exits. .:. . ._ , . . . . . . __ , . , , .. ,.

" potennany, no la m e greatest n u m o e r Ot occupants in m e nUllOang.

8-4.5.4* Number . T h e des ign shall be based on the m a x i m u m n u m b e r o f peop le tha t every occup ied room or a rea is expected to contain. Where success or failure of the design is con t ingen t on the n u m b e r of occupants no t exceed ing a certain n u m b e r , operat ional controls shall be used to ensu re a greater n u m b e r of occupants could no t be present .

8-4.5.5* Staff Assistance. T he ability of t ra ined employees to be inc luded a s p a r t of the fire safety system shall be identif ied and d o c u m e n t e d •

3-4.6 Emergency Response Personnel . Design characteristics or o ther condi t ions related to the availability, speed of response, effectiveness, roles, and o the r characterist ics of emergency response personne l shall be specified, est imated, or character ized sufficiently to evaluate the design.

3-4.7* Post-construct ion Condit ions. Design characteristics or o ther condi t ions related to activities du r i ng the life o f bui ld ing that affect the ability of the bui ld ing to mee t the stated goals and objectives shall be specified, est imated, or character ized sufficiently to evaluate the design.

3-4.8 Off-si te Condit ions. Design characteristics or o ther condi t ions re la ted to resources or condi t ions outs ide the proper ty be ing des igned that affect the ability of the bui ld ing to mee t the

3-5.3.4* Design Fire Scenario 4. A fire or iginat ing in a concealed wall- or ceiling-space adjacent to a large occup ied room• This des ign fire scenario shall address the conce rn of a fire or iginat ing in a concealed space tha t does no t have ei ther a de tec t ion system or suppress ion system, a n d the fire spread ing into the r o o m within the bui ld ing tha t can, potentially, ho ld the greatest n u m b e r of occupants .

3-5.3.5* Design Fire Scenario 5. A slowly developing fire, shie lded f rom fire protect ion systems, in close proximity to a h igh occupancy area. This des ign fire scenario shall address the concern of a relatively small igni t ion source causing a significant fire.

8-5.$.6* Design Fire Scenario 6. The mos t severe fire resul t ing f rom the largest possible fuel load characteristic of the normal operat ion of the building. This des ign fire scenario shall address the concern of a rapidly developing fire with occupants present .

8-5.3.7* Design Fire Scenario 7. Outside exposure fire. This des ign fire scenario shall address the concern o f a fire start ing remotely f rom the area of concern a n d ei ther spreading into the area, blocking escape f rom the area, or developing un tenab le condit ions within the area.

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$-5.3.8* Design Fire Scenario 8. A fire originating in ordinary combustibles m a room or area with each passive or active fire protection system rendered - one by one - unavailable. This set of design fire scenarios shall address the concern of each fire protection system or fire protection feature, considered

dividually, being unreliable or unavailable.

Exception:* Fire protection systems for which both the levd of reliability and the design performance in the absence of the system are acceptable to the authority having jurisdiction.

$-5.4 Design F'me Scenarios Data.

3-5.4.1 Each design fire scenario used in the performance-based design proposal shall be translated into input data specifications, as appropriate for the calculation method or model.

$-5.4.2 Any design fire scenario specifications that the design analyses do not explicitly address or incorporate, and which are therefore omitted from input data specifications, shall be identified, and a sensitivity analysis of the consequences of that omission shall be performed.

$-5.4.8 Any design fire scenario specifications modified in input data spedfications, because of limitations in test methods or other data generation procedures, shall be identified, and a sensitivity analysis of the consequences of the modification shall be performed.

SECTION $-6* EVALUATION OF PROPOSED DESIGN

3-6.1 General. A proposed design's performance shall be assessed relative to each performance objective in Section 1-6 and each applicable scenario in Section 3.5, with the assessment conducted through the use of appropriate calculation methods. The authority having jurisdiction shall approve the choice of assessment methods.

3-6.2 Use. The design professional shall use the assessment .. methods to demonstrate that the proposed design will achieve t h ~

in goals and objectives, as measured by the performance criteria ~ . analysis, for each light of the safety margins and uncertainty

scenario, given the assumptions.

Inpnt

$-6.3.1 Data. Input data for computer fire models sh~ " obtained in accordance with ASTM E 1 5 9 1 , ~ S ~.Guic for Fire Models. Data for use in analytical m ~ I e computer-based fire models shall be o b ~ d using:: .op~g~lte measurement, recording, and storage t e ~ . e s to e e the applicability of the data to the analytical m e l ~ e i n g ; ~ e d .

3-6.3.2 Data Requirements. A complete listing~'~an~ ~ut'4r data requirements for all models, engineering method~, d other calculation or verification methods required or proposed as part of the performance-based design shall be provided.

3-6.$.$* Uncertainty and Conservatism of Data. Uncertainty in input data shall be analyzed and, as determined appropriate by the authority having jurisdiction, addressed through the use of conservative values.

5-6.4* Output Data. The assessment methods used shall accurately and appropriately produce the required output data from input data based on the design specifications, assumptions, and scenarios.

3-6.5 Validity. Evidence shall be provided confirming that the assessment methods are valid and appropriate for the proposed building, use and conditions.

SECTION $-7 SAFETY FACTORS

3-7.1" General. Approved safety factors shall be included in the design methods and calculations to reflect uncertainty in the assumptions, data, and other factors associated with the performance-based design.

SECTION $-8 DOCUMENTATION REQUIREMENTS

3.8.1" General. All aspects of the design, including those described in 3-8.2 through 3-8.14, shall be documented. The format and content of the documentation shall be acceptable to the authority having jurisdiction.

3-8.2* Technical References and Resources. The authority having jurisdiction shall be provided with sufficient documentation to support the validity, accuracy, relevance, and precision of the proposed methods. The engineering standards, calculation methods and other forms of scientific information provided shall be appropriate for the particular application and methodologies used.

~8.$ Building Design Specifications. All details of the proposed building design that affect the ability of the building to meet the stated goals and objectives shall be documented.

$-8.4 Performance Crimrla. Performance criteria, with sources, shall be documented.

$-8.5 Occupant Characteristics. Assumptions about occupant characterisucs shall be documented.

$-8.6 Design Fire Scenarios. Descriptions of design fire scenarios shall be documented.

3-8.7 Input Data. Input data to models and assessment methods, including sensitivity analysis, shall be documented.

3-8.8 Out Output data from models and assessment sensitivity analysis, shall be documented.

Safety factors utilized shall be documented.

uirements. Retained prescriptive

~ Modeling 3~ ' i .L:~ ~. Features.

3-8.1 i~ .~ssumpt ions made by the model user, and description of gCand methods used, including known limitations, shall be ~ iented.

$-8.11.2 Documentation shall be provided that the assessment methods have been used validly and appropriately to address the design specifications, assumptions, and scenarios.

$-8.12 Evidence of Modeler Capability. The design team's relevant experience with the models, test methods, data bases, and other assessment methods used in the performance-based design proposal shall be documented.

$-8.15 Performance Evaluation. The performance evaluation summary shall be documented.

3-8.14 Use of Performance-based Design Option. Design proposals shall include documentation that provides anyone involved in ownership or management of the building with notification that:

(a) the building was approved as a performance-based design with certain specified design criteria and assumptions, and

(b) any remodeling, modification, renovation, change in use, or change in the established assumptions will require a re-evaluation and re-approval.

APPENDIX A

A-3 Chapter 3 of this Code provides requirements for the evaluation of a performance-based life safety design. The evaluation process is summarized in Figure A-3.

Code Criteria. On the left hand side of Figure A-3 is input from the Code. The life safety goals have been stated in Section 1-5. The objectives necessary to achieve these goals are stated in Section 145. Section 3-2 of this Chapter, Performance Criteria, specifies the measures that are to be used to determine whether the objectives have been m e t

Input At the top of Figure A-3 is the input necessary to evaluate a life safety design.

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The design specifications must indude certain retained prescriptive requirements as specified in Section 5-3. All assumptions about the life safety design and the response of the building and its occupants to a fire must be clearly stated as indicated in Section 5-4. Scenarios are used to assess the adequacy of the design. Eight sets of initiating events are specified for which the ensuing outcomes must be satisfactory.

Performance Assessment. Appropriate methods for assessing performance are to be used per Section $-6. Safety factors must be applied to account for uncertainties in the assessment as stated in Section 5-7. If the resulting predicted outcome of the scenarios is hounded by the performance criteria, then the ob)ectives have been met and the life safety design is considered to be m compliance with this Code. Although not part of this Code, a design that fails to comply may be changed and reassessed as indicated on the right h a n d side of Figure A-3.

Documentation. The approval and acceptance of a life safety design are dependent on the quality of the documentation of the process. Secuon 5-8 specifies a minimum set of documentation that must accompany a submission.

Retained ' ' e Design ( Prescriptive ~ (Design FIt ~ ~Svecifications and~ | Requirements I l ;Cec~n n~_s 5 J [ -6~er Conditions-[ L Secti°n 3-3 ~ ~K~- i n J / Secti;n3-4 J

/~ - - - N [ Evaluation of [ f ^ ~.oals _ ~ I Proposed Design ]

~ Change Design

Section 1-6 . Section 3-7 ~' I

I I I . . . . .

Performance Criteria Section 3-2

No

Requirements Section 3-8

Figure A-3 Performance-based Life Safety Code Compliance Process.

The performance option of this Code establishes acceptable levels of risk to occupants of buildings and structures as addressed in Section 1-2. While the performance option of this Code does contain goals, objectives andper formance criteria necessary to provide an acceptable level of risk to occupants, it does not describe how to meet the goals, objectives and performance criteria. Design and engineering are needed to develop solutions that meet the provisions of this chapter. The SFPE Engineering Guide to Performance-based Fire Protection Analysis and Design provides a framework for these assessments. Other references that may be useful include the Australian Fire Engineering Guidelines, and the British Standard Firesafet 3 Engineering in Buildings.

A-5-1.3 Qualifications should include experience, education, and credentials that demonstrate knowledgeable and responsible use of applicable models and methods.

A-5-1.4 A third-party reviewer is a person or group of persons chosen by the authority having jurisdiction to revaew proposed performance-based designs.

A-5-1.7 Continued compliance with the goals and objectives of the Code involves many things. The building construction - including openings, interior finish, fire and smoke resistive construction - and the building and fire protection systems need to retain at least the same level of performance as provided for the original design parameters. The use and occupancy should not change to the degree that assumptions made about the occupant characteristics, combustibility of furnishings, and existence of trained personnel are no longer valid. In addition, actions provided by other personnel, such as emergency responders, should not be diminished below the documented assumed levels. Also, actions needed to maintain reliability of systems at the anticipated level need to meet the initial design criteria.

A-5-1.8 Design Specifications. Design spedfications include both hardware and human factors, such as the conditions produced by maintenance and training. For purposes of performance-based design, the design specifications of interest-are those that affect the ability of the building to meet the stated goals and objectives.

A-5-1.8 Exposure Fire. This usually refers to a fire that starts outside a building (for example, wiidlands fwe or vehicle fire) and that consequently exposes the building to a fire.

A-5-1.8 Fire Model. Due to the complex nature of the principles involved, models are often packaged as computer software. Attached to the fire models will be any relevant input data, assumptions and limitations needed to properly implement the model. ,~::, ~ A-3-1,8 ~ c e n a n o , A fire scenario defines the conditions under~'%~""[~2.roposed design is expected to meet the fire safety g o ~ : ~ . . c t o ~ ' ~ f c a l l y include fuel characteristics, ignition

s ~ au.t~ons~anc~la~ I~ilding characteristics, and occupant .~,~ ~ t ~ o n s an ~e_ristics. "Fire scenario" includes more than

Ore ~ o n s and excludes any characteristics that do not vary

fi 9he fire to another; the later are called assumptions. The ter ~e. .~cenario" is used here to mean only those specifications r e q u i i ~ ( o calculate the fire's development and effects, but in

~ n t e x t s , term may ~ e r the be used to mean both the initial ~ :vcations and the subsequent development and effects (i.e., a p.l.ete description of fire fi'om conditions prior to ignition to mmns following extinguishment).

A-5-1.8 Fuel Load. Fuel load includes interior finish and trim.

A-5-1.8 Performance Criteria. Performance criteria are stated in engineering terms. Engineering terms include temperatures, radiant heat flux, and levels of exposure to fire products. Performance criteria provide threshold values used to evaluate a proposed design.

A-5-1.8 Proposed Design. The design team may develop a number of trial designs that will be evaluated to determine if they meet the performance criteria. One of the trial designs will be selected from those that meet the performance criteria for submission to the authority having jurisdiction as the proposed design.

The proposed design is not necessarily limited to fire protection and building features, but also includes any component of

proposed design that is installed, established, or maintained for the purpose of life safety, without which the proposed design could fail to achieve specified performance criteria. As such, the proposed design often includes emergency procedures and organizational structures that are needed to meet the performance criteria specified for the proposed design.

A-5-2.2 One of the following methods can be used to avoid exposing occupants to untenable conditions:

1. The design team could set detailed performance criteria that would ensure that occupants are not incapacitated by fire effects. The SFPE Engineering Guide to Performance-Based Analysis and Design describes a process of establishing tenability limits.

The guide references D. A. Purser, "Toxicity Assessment of Combustion Products," Chapter 2-8, The SFPE Handbook of Fire Protection Engineering, National Fire Protection Association, Quincy, MA, 1995, which describes a Fractional Effective Dose (FED) calculation approach also contained in the 1996 edition of NFPA 269, Standard Test Method for Developing Toxic Potency Data for

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Use in Fire Hazard Modeling. FED addresses carbon monoxide, hydrogen cyanide, carbon dioxide, hydrogen chloride, hydrogen bromide, and anoxia effects. It is possible to use the test data, combined with laboratory experience, to estimate what FED would lead to the survival of virtually all people. This value is about 0.8.

There is a relationship between exposures leading to death and those leading to incapacitation. Kaplan [Kaplan et aL, Journal of Fire Science, 2 286-805 (1984)] found that rodent susceptibility is similar to human and that for the narcotic gases (CO and HCN), incapacitation occurs at one-third to one-half of the lethal exposure. Gann [ G a n n e t al , Fire and Materials, 18 193 (1994)] found that carbon monoxide dominates the lethality of fire smoke, since most fire deaths occur remote from the fire room from fires that have proceeded past flashover. Thus, were an FED value of 0.8 used for a non-lethal exposure, an FED of 0.3 would be reasonable for a non-incapacitating exposure.

If the authority having jurisdiction or the design professional is concerned with potential toxic fire effects other than those addressed by the FED procedure as documented, then the calculation procedure can b e expanded by adding additional terms to the Fractional Effective Dose (FED) equation, each term having the form of a ratio. The numerator of the ratio is the cumulative exposure to that fire effect, measured as an integral of the product of instantaneous exposure (concentration for toxic products) and time. The denominator of the ratio is the quantity of cumulative exposure for which FED equals the chosen threshold value (e.g., 0.8 or 0.3) based on that fire effect alone.

ASTM is actively considering standards that would extend the list of toxic fire effects with standard values.

If the authority having jurisdiction or the design professional is concerned with potential fire effects other than toxicity, then the calculation procedure can be modified to include other fire effects, such as thermal effects.

For buildin~gs where an unusually large fraction of the occupants will be espeoally vulnerable, the calculation procedure should be... modified to use FED values lower than those cited above. ~:'"~ "~

2. For each design fire scenario and the design specifications, conditions and assumptions, the design team could demmmw.ate that each room or area will be fully evacuated before f l ~ and toxic gas ~ayer in that room descends to a level l ~ r t h ~ f t (1.8 m) above the floor. This will require that no 6"~'~:~i~,~-.," ~:~'.':i:':'~:'~.,': exposed to fire effects. It requires calculation of the h)/~/~:ns, "'~":i movement, and behavior ~ i of occupants, beca~z~ . .~ . . p s f ~.~..ff.eSts and occupants separate by moving the o c c u # ~ t s . " ~ e l o~i~::" (1.5 m) is often used in " calculauons, but .~ .~ , that l e ' ~ l a ~ fraction of the population would not be:"2g~'~.'~..~.~ stand, "~lk, or run normally and still avoid inhalation of toxic : ~ ' ~ They.i~ould have to bend over or otherwise move their heads cl ~ ( ~ o . ~ floor level. ":~":~-'-"" !~:?.~.~-

3. For each design fire scenario and the design specifications and assumptions, the design team could demonstrate that the smoke and toxic gas layer will not descend to a level lower than 6 ft (1.8 m) above the floor in any occupied room. The advantage of this procedure is that it conservatively requires that no occupant need be exposed to fire effects, regardless of where occupants are or where they move. This removes the need to make any calculations regarding occupants, including their behavior, movement locations, pre-fire characteristics, and reactions to fire effects. This is even more conservative and simpler than the procedure in number 2 above, because it does not allow fire effects in occupied rooms to develop to a point where people could be affected even after there are no people present to be affected.

4. For each design fire scenario and the design specifications and assumptions, the design team could demonstrate that no fire effects will reach any occupied room. The advantage of this procedure is that it removes the need to make any calculations regarding occupants, including their behavior, movement, locations, pre-fire characteristics, and reactions to fire effects. A further advantage is that it also removes the need for some of the modeling of fire effects, because it is not necessary to model the filling of rooms, only the spread of fire effects to those rooms. This is even more conservative and simpler than the procedures in number 2 and number $ above, because it does not allow any fire effects in occupied rooms.

A-3-3.1 This requirement applies both to systems and features required by the C_od,; that reference applicable standards, and t o any additional systems or features included in the design at the discretion of the design team. The referenced standards are hereby expected to state maintenance, testing, and other requirements needed to provide positive assurance of an acceptable level of reliability. The referenced standards themselves may be prescriptive- or performance-based.

A-$-4.1 The design specifications and other conditions will form the input to evaluation of proposed designs (see Section $-6). Where a specification or condition is not known a reasonable estimation may be made. However, the design team will need to take steps to ensure that the estimation is valid during the life of the building. Any estimations need to be documented. (See Section ~8.)

A-$-4.4 Systems addressed by this requirement include automatic fire suppression systems and fire alarm systems. Performance issues that need to be documented might include response time indexes, discharge densities and distribution patterns. Calculations should not include an unlimited suppl~" of extinguishing agent if only a limited supply will be provided in the actual structure or building.

A-3-4.5.1 Examples of design features that might be incorporated to modify expected occupant characteristics include training, use of staff to assist with notification and movement, or type of notification ~..~[~.~iance used.

.¢..-~ ..g. A - $ - 4 , 5 . ~ four basic characteristics - sensibility, reactivity, mobilii~.~ a ~ ] ~ c e p t i b i l i t y - comprise a minimum, exhaustive set of o~jlly d ~ i v e , performance characteristics of people in b ~ .~a t a fire safety system's ability to meet life c ~ d t

etg. ectives. ,~ey are briefly described as follows:

i ~ - ~ i b i l i t y - to physical cues. Ability to sense the sounding of ar - : :~m. May also include discernment and discrimination of v i su~ . .d ,o l fac tory cues in addition to auditory emanations from

'-'~-~g.$:--~'Reactivity - ability to interpret correctly cues and take al~'ropriate . . . . action. May be function, of cognitive capacity,, speed of msuncuve reacuon, or group dynamics. May need to consider reliability or likelihood of a wrong decision as in the influence of familiarity with the premises on wayflnding.

(c) Mobility - speed of movement. Determined by individual capabilities as well as crowding phenomena such as arching at doorways.

(d) Susceptibility - to products of combustion. Metabolism, lung capacity, pulmonary disease, allergies, or other physical limitations that may affect survivability in a fire environment.

In application, as with the use of computer evacuation models, assumptions may address a larger number of factors that are components of these basic performance characteristics, for example:

Alertness Awake/asleep, may depend on time of day

Responsiveness Ability to sense cues and react

Commitment Degree to which occupant is committed to an activity underway before the alarm

Focal point

Physical and mental capabilities

Point at which an occupant's attention may be focused (e.g., to front of classroom, stage or server in business environment)

May affect ability to sense, respond and react to cues. May be related to age or disability

Role May determine whether occupant will lead or follow others

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Familiarity Can d e p e n d on t ime spent in building or participation in emergency training

Social affiliation Extent to which an occupant will ac t / reac t as an individual or as a member of a group

Condit ion Over the course of the fire, the effects - both physiological and psychological - of the fire and its combustion products on each occupant.

A-5-4.5.4 The number of people expected to be contained in a room or area should be b a s e d o n the occupant load factor specified in Table 5-3.1.2 or o ther approved sources.

A-5-4.5.5 For example, in hospitals, staff characteristic such as number , location, quality and frequency of t raining should be considered.

A-5-4.7 Design proposals need to state explicidy any design specifications or esumations regarding building fire safety plans, inspect ion programs, or o ther ongoing programs whose per formance is necessary for the building, when occupied and operational, to mee t the stated goals and objectives.

Programs of interest include any maintenance, training, labeling, or certification programs required to assure operational status or reliability in building systems or features.

A-5.4.9 This includes assumptions about the interrelat ions between the per formance of building elements and systems, occupant behavior, or emergency response actions that conflict with each other. For each fire scenario care needs to be taken to assure that conflicts in actions do no t occur. Typical conflicts could include (1) assuming a fire door will remain d o s e d dur ing the fire event to contain smoke, while this same door is used by occupants dur ing egress f rom the area, (2) assuming fire apparat.Os will arrive immediately f rom a distant location to charge fire ~ depa r tmen t connect ions to provide water, and similar situations. "~

x $

For example, an assumption that compar tmenta t ion bl .O~i~g the passage of fire and smoke will be mainta ined at the d o 9 t ~ . . ¢ . stairwell cannot be paired with an assumption that e~[lzuatio~i! .~ through that door will extend over many minutes. * * " ~ ~ ~

A-5-4.10 This includes provisions that are i n ~ . : . . 9 . f b~ ~- requirements covered by re ferenced codes affd sta/ti~.gls ~ design requirements , and operat ing p r o c ~ . It ir~.('~ Igi'ings such as more f requent periodic testing a/'qi~F-~.~ntenan~-to increase the reliability of fire protect ion syst d ig~ . redun~in t s),stems

on site • guard service t, to increase reliability, o e ~ c . ~ ' ~ e t e c u o n of procedures, staff tr fires and aid in fire response ~ , availability

and per formance of emergency response personm.~ and other factors.

A-5-5 Design fire scenarios define the challenge a building is expected to withstand. Design fire scenarios capture and limit value judgments on the type and severity of the fire challenge to which a proposed fire safety system needs to respond. The system includes any and all aspects of the p roposed design that are in tended to mitigate the effects of a fire: egress system, automatic detect ion and suppression, barriers, staff training, p lacement of manual extinguishers, etc.

Design fire scenarios come from two sources: those that are specified in paragraphs 5.5.3.1 th rough 5-5.3.8, and those that are developed by the design team based on the unique characteristics o f the building as required by 5.5.2. In most, if no t all cases, more than one design fire scenario will be developed to mee t the - requirements of 5-5.2.

Once the set of design fire scenarios is established, both those specified by 5-5.3.1 through 5-5.3.8 and those that are developed as required by 5-5.2, they must be quantified into a format that can be used for the evaluation of p roposed designs. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design outlines a process and identifies tools and references that can be used at each step of this process.

A-5-5.2 The protect ion systems and features used to meet the challenge of the design fire scenario should be typical of, and consistent with, those used for o ther similar areas o f the building• They should no t be des igned to be more effective in the building area addressed than in similar areas n o t included and which are, therefore, no t explicitly evaluated.

A-5-5.3 It is desirable to run a wide variety of different fire scenarios to evaluate the complete life safety capabilities of the building or structure. Fire scenarios should not be limited to a single or a couple of "worst case" fire scenarios.

The descriptive terms used to indicate the rate of fire growth for the scenarios are in tended to be generic. Use of t-squared fires is not required for any scenario.

A-5-5.3.1 Scenario 1 An example of such a scenario for a health care occupancy would involve a pat ient room with two occupied beds; fire initially involving one bed; room door is open. This is a cursory example in that much of the explicitly requi red information indicated in 5-5.3.1 can be de te rmined from the information provided in the example. Note that it will usually be necessary to consider more than one scenario to capture the features and condit ions typical o f an occupancy.

A-5-5.3.2 Scenario 2 Examples of such scenarios are a fire involving ignition of gasoline as an accelerant in a means of egress, clothing racks in corridors, renovation materials or o ther fuel configuratio.r~.'!:.gh~at can cause an ultrafast fire. The means of egress chosen is ~ i ~ y with the largest egress capadty among d o o r w a y ~ a l l y used in the ordinary operat ion of the building. The b ~ c u p a n t characteristics for the proper ty are assq~_ .fi~.-s_ A t " ~ O o n , doors are assumed to be open th roughout

~- . .5-5~ Scenari#"3 An example of such a scenario is a fire in a ~ 9 o m adjacent to the largest occupiable room in the b ~ g . The contents of the room of fire origin are specified to p r 0 ~ . x ~ , largest fuel load and the most rapid growth in fire severi L ~ n s i s t e n t with the normal use of the room. The adjacent • u )~lble room is assumed to be filled to capacity with ~ t ) ' ~ a n t s . Occupants are assumed to be somewhat impaired in wl~tever form is most consistent with the in tended use of the building. At ignition doors f rom both rooms are assumed to be open. Depend ing u p o n the design, doorways may connect the two rooms or they may connect via a common hallway or corridor.

For purposes of this scenario, an occupiable room is one that may contain people (i.e., a location within a building where people are typically found) .

A-5-5.3.4 Scenario 4 An example of such a scenario is a fire originating in a concealed wall- or ceiling-space adjacent to a large occupied funct ion room. Ignition involves concealed combustibles, inc luding wire or cable insulation and thermal or acoustical insulation. The adjacent funct ion room is assumed to be occupied to capacity. The baseline occupant characteristics for the property are assumed. At ignition, doors are assumed to be open throughout the building.

A-5-5.3.5 Scenario 5 An example of such a scenario is a cigarette fire in a trash can. The trash can is close enough to room contents to ignite more substantial fuel sources but is no t close enough to any occupant to create an intimate-with-ignition situation. If the in tended use of the property involves the potential for some occupants to be incapable of movement at any time, then the room of origin is chosen as the type of room likely to have such occupants, filled to capacity with occupants in that condition. If the in tended use of the property does no t involve the potential for some occupants to he incapable of movement , then the room of origin is chosen to be an assembly or funct ion area characteristic of the use of the property, and the trash can is placed so that it is shielded by furni ture f rom suppression systems. At ignition, doors are assumed to be open th roughout the building.

A-5-5.3.6 Scenario 6 An example of such a scenario is a fire originating in the largest fuel load of combustibles possible in normal operat ion in a funct ion or assembly room, or a process /manufac tur ing area, characteristic of the normal operation of the property. The configuration, type, and geometry o f the combustibles are chosen so as to produce the most rapid and severe fire growth or smoke generat ion consistent with the

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normal operation of the property. The baseline occupant characteristics for the property are assumed. At ignition, doors are assumed to be closed throughout the building.

This category includes everything from a big couch fire in a small dwelling to a rack fire in combustible liquids stock in a big box retail store.

A-3-5.$.7 Scenario 7 An example of such a scenario is an exposure fire. The initiating fire is the closest and most severe fire possible consistent with the placement and type of adjacent properdes and the placement of plants and combustible adornments on the property. The baseline occupant characteristics for the property are assumed.

This category includes wildlands/urban interface fires and exterior wood shingle problems, where applicable.

A-~-[i.$.8 Scenario 8 This scenario addresses a set of conditions with a typical fire originating in the building with any one passive or active fire protection system or feature being ineffective• Examples of this include unprotected openings between floors or between fire walls or fire barrier walls, rated fire doors fall to close automatically or are blocked open, sprinkler system water supply shut-off, fire alarm system is non-operative, smoke management system not operational, or automatic smoke dampers blocked open• This scenario should represent a reasonable challenge to the other building features provided by the design and presumed to be available.

The concept of a fire originating in 'ordinary combustibles' is intentionally selected for this event. This fire, although presenting a realistic challenge to the building and the associated building systems, does not represent the worst case scenario or the most challenging fire event for the building.

Examples include:

(a) A fire originating in ordinary combustibles in the corridor of a patient wing of a hospital. Staff is assumed not to close any

• $(~.::-~. patient room doors upon detection of fire. The basehne o c c u p ~ characteristics for the property are assumed, and the patient room"~., off the corridor are assumed to be filled to capacity. At ignition, ~ doors to patient rooms are not equipped with self-cinsin~.~.,~...:~ces and are assumed to be open throughout the smoke c o ~ n t .

. . . . . . ~ N ,.~i~:: . . . . . . (b) A fire ~e.~ ongmaung in ordinary combustibles ia"~ " e~..%..:~

assembly room or area in the interior of the building. automatic suppression systems are assumed t ~ . . . o f , ~ t } ~ n . The baseline occupant characteristics for ~ ~ . ~ r . ~ ~'-'6.'~..':-~ assumed, and the room of origin is a s s u ~ to be fi i}~$o capacity. At ignition, doors are assumeff~v/~::.closed ~ o u g h o u t the building. "::~:.'~::. f f

• ::.~.~.:~. s:.~.,-

(c) A fire originating in ordinary c o m b u s t i b l e ~ : n unoccupied small function room adjacent to a lag,~e assembly room or area in the interior of the building• The automatic detection systems are assumed to be out of operation. The baseline occupant characteristics for the property are assumed, the room of origin is assumed to be unoccupied, and the assembly room is assumed to be filled to capacity. At ignition, doors are assumed to be closed throughout the building•

A-~-5.8 Exception The Exception is applied to each active or passive fire protection system individually and requires two different types of information to be developed by analysis and approved by the authority having jurisdiction. System reliability is to be analyzed and accepted• Design performance in the absence of the system is also to be analyzed and accepted, but acceptable performance need not mean fully meeting the stated goals and objectives• It may not be possible to meet fully the goals and objectives with a key system unavailable, and yet no system is totally reliable• The authority having jurisdiction will determine what level of performance, possibly short of the stated goals and objectives, is acceptable, given the very low probability (i.e., the system's unreliability probability) that this situation will occur•

A-3-6 The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design outlines a process for evaluating whether trial desi .gns meet the performance criteria during the design fire scenarios.

Procedures described in Sections 3-2 and 3-4 identify required design fire scenarios within which a proposed fire safety design must perform and the associated untenable conditions which must be avoided in order to maintain life safety. This section discusses methods that form the link from the scenarios and criteria to the goals and objectives.

Assessment methods are used to demonstrate that the proposed design will achieve the stated goals/objectives, by providing information indicating that the performance criteria of Section 3-2 cart be adequately met. Assessment methods may be either tests or modeling•

Tests. Test results may be directly used to assess a fire safety design when they accurately represent the scenarios developed by using Section 3-4 and provide output data matching the performance criteria in Section 3-2. Since the performance criteria for this Code are stated in terms of human exposure to lethal fire effects, no test will suffice. However, tests will be needed to produce data for use in models and other calculation methods.

Standardized Tests. Standardized tests are conducted on various systems and components to determine whether or not they meet some predetermined, typically prescriptive, criteria- Results are given on a pass/fail basis: either the test specimen does or does not meet the pre-established criteria. The actual performance of the test specimen is not usually recorded.

Sca/e. Tests can be either small, intermediate, or full scale. Small scale t~: . .are used to test activation of detection and suppressiq.g..!~:~s, and the flammability and toxicity of materials. Usually,..e.tJ~:~tem to be tested may be placed within the testing device-~:~g)__af~ns.~ Intermediate scale tests may be used to d e t ~ . 4 ~ :quacy of system components (e.g., doors and

~ .~2~,~ entire systems). The difference between and in al~.: i~(:~ite scale is usually one of definition provided ~ tla"~. conducting the test. Full scale tests are typically used to l~c~nbg and structural components or entire systems. The

d .~tween intermediate and large scale is also subject to the ~ / ~ ~on of those performing the test. Full scale tests are intend"[i~:to most closely depict performance of the test subject as

~ .~ . . . t&l .~ l in the field (i.e., most closely represent real world

Full-scale building evacuations can provide information on how the evacuation of a structure is likely to occur, for an existing building with a given population but without subjecting occupants to the real physical or psychological effects of a fire.

Data Uses. The data obtained from standardized tests have three uses for verification purposes. The test results can be used instead of a model. (This will typically be the role of full scale test results.) The test results can be used as a basis for validating the model. (The model predictions match well with the test results, therefore, the model can be used in situations similar to the test scenario.) The test results can be used as input to models. (This is typically the use of small scale test; speciflcally, flammability tests.)

Start-up Tes~ Start-up test results can be used to demonstrate the fire safety system performs as designed• The system design may be based upon modeling• If the start-up test indicates a deficiency, then the system must be adjusted and retested until it can be demonstrated the design can meet the performance criteria. Typically, start-up tests apply only to the installation to which they are designed•

Experimental Data• Experimental data from non-standardized tests may be used when the specified scenario and the experimental setup are similar. Typically, experimental data are applicable to a greater variety of scenarios than are standardized test results.

Human and Organizational Perfortnance Tests. Certain tests determine whether inputs used to determine human performance criteria remain valid during the occupancy of a building. Tests of human and organizational performance might include any of the following: Evacuation times measured during fire drills; querying emergency response team members to determine whether they know required procedures; and, field tests to ensure that emergency response team members can execute tasks within predetermined times and accuracy limits. Design proposals should include descriptions of any tests that are needed to determine

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whether stated goals, objectives and performance criteria are being m e t . ,

Modeling. Models may be used to predict the performance criteria for a given scenario. Because of the limitations on use of tests alone for this purpose, models are expected to be used in most, if not all, performance-based design assessments.

Fire models do not model fires; they model the effects of a (user) specified fire (i.e., a heat release rate curve is input). For ease of use, the term "fire model" will be used instead of the more accurate fire effects model.

The effect of fire and its toxic products on the occupants can be modeled, as can the movement and behavior of occupants during the fire incident. The term "evacuation model" will be used to describe models that predict the location and movements of occupants, and the term "tenability model" will be used to describe models that predict the effects on occupants of specified levels of exposure to fire effects.

Types of Fire Models. Fire models will be used to predict fire- related performance criteria. Fire models may be either probabilistic or deterministic. Several types of deterministic models are available: computational fluid dynamics (CFD or field) models, zone models, purpose built models, and hand calculations. Probabilistic fire models are also available, but are less likely to be used for this purpose.

Probabilistic fire models use the probabilities as well as the severity of various events as the basis of evaluation. Some probabUistic models incorporate deterministic models, but this is not a requirement. Probabilistic models attempt to predict the likelihood or probability that events or severity assooated with an unwanted fire will occur or the "expected" loss, which may be thought of as the probability-weighted average severity across all possible scenarios. Probabilistic models may be manifested as fault or event trees, or other system models that use frequency or probability data as input. These models tend to be manifested a~..~,j~ computer software, but this is not a requirement. Furthermore the discussion below under "Sources of Models" may also be ' ~'~ applied to probabilistic models, although it concentrates on deterministic models. ~ ..~-:~...'.-~:.

~.q~" q~::~

CFD models provide the most accurate predJction~.4i~all ~ deterministic models because they divide a given s ~ g ~ ~ .

since these "~-:~ thousands of smaller volumes. However, - : ~ 1 models, they are not absolute in ~ . . their depicti.~.s~.~.~,dity ~......+ addition, they are much more expensive toA~ b e ~ f l ~ * ' computationally intensive. Because of t ~ . ~ I~: ~xpense , ..~apl, ~ t y and intensive computational needs, C F I ~ $ ~ . l s requ ' /~much greater scrutiny then do zone models. It is I ~ . . . m t r e ~ i f f i c u l t to

check ' to a provide multiple runs of CFD models to , ~ i f i ~ resolutio ntilation. variety of factors such as design fire cell ~

Zone models are more widely used than CFD models because they provide reasonably accurate predictions in much less time. It is much easier to assess sensitivity of different parameters with zone models because they generally run much faster and the output is much easier to interpret. Prediction of fire growth and spread has a large number of variables associated with it, consequently the zone models with their crudeness and speed have advantages over the more complex CFD models.

Purpose-built models (also known as stand-alone models) are similar to zone models in their ease of use. However, purpose built models do not provide a comprehensive model; instead, they predict the value of one variable of interest. For example, such a model can predict the conditions of a ceiling je t at a specified location under a ceiling but a zone model would "transport" those conditions throughout the enclosure.

Purpose-built models may or may not be manifested as computer software. Those that are not are referred to as hand calculations. These purpose-built models are therefore simple enough that the data management capabilities of a computer are not necessary. Many of these calculations are found in The SFPE Handbook of Fire Protection Engineering.

Types of Evacuation Models. There are three categories of evacuataon models that can be considered: single-parameter

estimation methods, movement models, and behavioral simulation models.

Single-parameter estimations are generally used for simple estimates of movement time. They are usually based on equations derived from observations of movement in non-emergency situations. They may be hand-calculations or simple computer models. Examples include calculation methods for flow umes based on widths of exit paths and travel times based on travel distances. Sources for these methods include The Sb'PE Handbook of Fire Protection Engineering and the NFPA Fire Protection Handbook.

Movement models generally handle large numbers of people in a network flow similar to water in pipes or ball bearings in chutes. They tend to optimize occupant behavior, resulting in predicted evacuation times that can be unrealistic and far from conservative. However, they can be useful in an overall assessment of a design especially in early evaluation stages where an unacceptable result with this sort of model will indicate that the design has failed to achieve the life safety objectives.

Behavioral simulation models take into consideration more of the variables related to occupant movement and behavior. Occupants are treated as individuals and can have characteristics assigned to them uniquely, allowin~ a more realistic simulation of the design under consideration. However, given the limited availability of data for the development of these models, for their verification by their authors or for input when using them, their predictive reliability is 9A~.stionable.

T e n . a ~ Models. In general, models will be needed here only to a n t ~ f ~ . c u l a t i o n s over time of exposure effect equations

~'~ Otlier Models."'~Iodeis may' be used to describe combustion (as . te ~..most "fire 4~odels" only characterize fire effects), automatic

. t ~ y r f o r m a n c e , and other elements of the calculation. There ~w models in common use for these purposes, so they are not

d~' ~ a r t h e r here. .:.::~.

~ ~ Compendia of computer fire models are found dman ' s Survey of Computer Models for Fire and Smoke and the Computer Software Director~. Within these references are

models that were developed by the Building Fire Research i~bo-ratory of National Institute of Standards and Technology which can be downloaded from the Intemet at http://www.bfrl.nist.gov/864/fmabs.html. Evacuation models in all three categories are discussed in The SFPE Handbook of Fire Protection Engineering and the NFPA Fire Protection Handbook.

Validation. Models undergo limited validation. Most can be considered demonstrated only for the experimental results they were based upon and /o r the limited set of scenarios to which the model developers compared the model's output.

The Society of Fire Protection Engineers has a task group to independently evaluate computer models. As of January 1998, they are preparing to finish their first evaluation and have chosen a second model to evaluate. Until more models can be independently evaluated the model user must rely on the available documentation and previous experience for guidance regarding the appropriate use of a given model.

The design professional should present and the authority having jurisdiction, when deciding whether to approve a proposal, should consider the strength of the evidence presented for the validity, accuracy, relevance, and precision of the proposed methods. An element in establishing the strength of scientific evidence is the extent of external review and acceptance of the evidence by peers of the authors of that evidence.

Models have limitations. Most are not user-friendly. For that reason, experienced users will be able to construct more reasonable models and better interpret output than novices. It is for these reasons that the third party review and equivalency sections are provided. This is not meant to discourage the use of models; only to indicate that they must be used with caution by those well-versed in their nuances.

Inout Data. The first step in using a model is to develop the input data.

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The heat release rate curve specified by the user is the driving force of a fire effects model . If this is incorrectly defined, the subsequent results are not usable. In addit ion to the smolder ing and growth phases that will be specified as part o f the scenario definition, two additional phases are needed to complete the input heat release rate curve - steady burn ing and burnout.

Steady burn ing is characterized by its duration, which is a function of the total amount of fuel available to be burned. In determining the durat ion of th i sphase , the designer must consider how much fuel has been a s s u m e d t o be consumed in the smolder ing and growth phases, and how much is assumed to be consumed in the bu rnou t phase which follows. A common assumption is that the burnou t phase is the mirror image of the preceding phases, with a reversed heat release rate curve and the same amoun t of fuel consumed in the burnout phase as in the growth phase. Depending on the assumptions made regarding the amount of fuel consumed during burnout , the t ime at which this phase starts should be easy to determine.

Bear in mind that the above discussion assumes that the burning objects are solid (i.e., table, chairs, etc.). If l iquid or gaseous fuels are involved, then the shape of the curve will be different. For example, smolder ing is no t relevant for burn ing liquids or gases and the growth per iod is very short, typically measured in seconds. Peak hea t release rate may d e p e n d primarily on the rate of release, or leak rate (gases and liquid sprays) or on the extent of spill

• (pooled liquids). The steady burn ing phase is once again d e p e n d e n t upon the amoun t of fuel available to burn. Like the growth phase, the burnout phase is typically shor t (e.g., closing a valve), a l though it is conceivable that longer times may be appropriate , depend ing on the ext inguishment scenario.

Material propert ies are needed (usually) for all fuel i tems (initial and secondary) and the enclosure surfaces of involved rooms or spaces.

For all fires of consequence it is reasonable to assume that the fire receives adequate ventilation. If there is insufficient oxygen, e::.:,~ the fire will no t be sustained and thus will go out. An ::~j!!i overabundance of oxygen is only a concern in special cases (e.g., ~ hermetically sealed spaces) when a fire may no t occur due to dilution of the fuel (i.e., a f lammable mixture is no t prq,d~,..~...d). Therefore , given that the scenarios of interest will occttg.~t 'fl"~ - hermetically sealed enclosures, it is reasonable to as s . ~ e th@." adequate ventilation is available and that if a fire s~.....wi.~:i~;.'.'~i'~ cont inue to burn until it ei ther runs out of fuel or is ext~ishei~-~!-~ by o ther means. The only variable that may ~ N ~ e ~ ~ .edjs the total vent width. ~:"" ..... :':" ..::,-:-~ . . . . . . ~i::, ~?"

.~: : , :g~..'~ ..-V Maximum fire extent is affected by t w o ~ ' ~ e t r i c asp'~.'.~ts:

burn ing object proximity to walls and ove i 'F~c . iosurd d im e nsi o ns. ":'~'":' :~'-:~%:.:ff.

Conservatively, when a fire is "against a wall" or a corner" the effective hea t release of the fire can be doubled and quadrupled, respectively. In order for the burn ing object to be considered against the wall or in the corner, it must be either touching the enclosure surface or within two inches (about five cent imeters) . The reasoning beh ind this convent ion is that a wall effectively cuts the f i r e p l u m e in half, while a corner results in one quarter of the p lume if the burning object were closer to the center o f the room. Conceptually, the same amount of combustible vapors are produced, regardless of the burn ing object 's position, but the presence of wal ls /corners results in a smaller volume in which to burn them. In o ther words, wails and corners effectively concentrate the f lammable vapors result ing f rom pyrolysis o f the fuel.

The room dimensions affect the time required for a room to flashover. Simply, for a given amoun t and type of fuel, under the same ventilation conditions, a small room val"l flashover before a large room. In a large room with a small amoun t of fuel, a fire will behave as if it is outside: adequate oxygen to burn, no concentra t ion of heat- If the fuel package is unchanged but the dimensions of the room are decreased, then the room will begin to have an affect on the fire (assuming adequate ventilation). The presence of the (relatively smaller) enclosure results in the build up of a ho t layer of smoke and o ther products of combustion under the ceiling. This in turn feeds more heat back to the seat of the fire, which results in an increase in the pyrolysis rate of the fuel and thus increase the amoun t of hea t energy released by the fire.

The room enclosure surfaces themselves also contribute to this radiation feedback effect..

Probabilistic data is expressed as either a f requency (units of inverse time) or a probability (unitless bu t applicable to a stated per iod of time). An example of the former is expected number of failures per year and the range of the latter is between zero and one, inclusive. Probabilities can be either objective or subjective. Subjective probabilities express a degree of belief that an event will occur. Objective probabilities are based on historical data and may be expressed as a reliability (of a component , system, etc.).

A-3-6.3.$ Procedures used to develop required input data need to preserve the in tended conservatism of all scenarios and assumptions. Conservatism is only one means to address the uncertainty inhe ren t in calculations and does no t remove the need to consider safety factors, sensitivity analysis, and o ther methods of dealing with uncertainty. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design outlines a process for identifying and treating uncertainty.

A-3-6.4 An assessment me thod translates input data, which may be test specifications, parameters or variables for model ing, or other data, into output data, which are measured against the per formance criteria. Computer fire models should be evaluated for their predictive capability in accordance with ASTM E 1555, Standard Guide for Evaluating the Predictive Capability of Fire Models.

A-$-7.1 S e r ~ 4 " t y and Uncertainty Analysis and Safety Factors. The a s s e s s m e n ~ t r ' ~ ' ~ i s i o n required in 3-8.2 will require sensitivity and unce r t a l~ . , . . a lys i s , which may be translated into safety factors.

.:~.~'~': " ~ ' ~ ' f ~ ~ t i v i ~ !ysis. The first run a model user makes should b ~ j ~ i ~ l as t h ' ~ . ~ a s e , using the n6minal values of the various

)~rameters. ~ u t . I !~[~f'bwever, the model user should no t rely on a

~ n g i ~ n to use ~ the basis for any performance-based fire safety ~ .~ i$~gs ign . Ideally, each variable or parameter that the model

u s ~ a d e to develop the nominal input data should have multiple r u n ' i n . . . . w~ ted with it, as should combinat ions of key variables and p a r a n J ' ~ s . Thus, a sensitivity analysis should be conducted that ~.O..:~...d~ the model user with data that indicates how the effects of ~ - ' ~ " f i r e may vary and how the response of the proposed fire satiety design may also vary.

The interpretat ion of a model 's predict ions may be a difficult exercise if the model user does no t have knowledge of fire dynamics or h u m a n behavior.

Reasonableness Check. The first th ing the model user should try to de te rmine is whether or no t the predict ions actually make sense (i.e., don ' t upset intuition or preconceived expectations). Most likely if the results don ' t pass this test an input error has been commit ted .

Sometimes the predict ions appear to be reasonable but are in fact incorrect. For example, a mode l may predic t higher temperatures farther f rom the fire than close to it. The values themselves may be reasonable (e.g., no t hot ter than the fire) but they don ' t "flow" down the energy as expected.

A margin of safety can be developed using the results o f the sensitivity analysis (to provide the possible range of when a condi t ion is estimated to occur) in conjunct ion with the per formance criteria.

Safety factors and margin of safety are two concepts used to Uantify the amoun t of uncertainty in engineer ing analyses. Safety

tors are used to provide a margin o f safety a n d r e p r e s e n t , or address, the gap in knowledge between the theoretically perfect model (i.e., reality) and the engineer ing models that can only partially represen t reality.

Safety factors can be appl ied to ei ther t h e p r e d i c t e d level of a physical condi t ion or the t ime that the condi t ion is predic ted to occur. Thus, a physical a n d / o r a temporal safety factor may be appl ied to any predic ted condit ion. A predic ted condit ion (i.e., a paxameter 's value) and the t ime it occurs are best represen ted as distributions. Ideally, a computer fire model predicts the expected or nominal value of the distribution. Safety factors are in tended to represent the spread of these distributions.

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Given the uncertainty assodated with data acquisition and reduction, and the limitations of computer modeling, any condition predicted by a computer model may be thought of as an expected or nominal value within a broader range. For example, an upper layer temperature of 600C is predicted, at a given time. If the modeled scenario is then tested (i.e., full scale experiment based on the computer model 's input data), the actual temperature at that given time could be 640C or 585C. Therefore, the temperature should be reported as: 600C; +40, -15 or a range of 585C - 6 4 0 C .

A-3-8.2 The sources, methodologies and data used in performance-based designs should be based on technical references that are widely accepted and utilized by the appropriate professions and professional groups. This acceptance is often based on documents, which are developed, reviewed and validated under one of the following processes:

(a) Standards developed under an open consensus process conducted by recognized professional societies, codes or standards organizations, or governmental bodies.

Ideally, predictions are reported as a nominal value, some percentage or absolute value. As an example, an upper layer temcoerature prediction could be reported as "600C, $0C" or "600C, 5% . In this case, the physical safety factor is 0.05 (i.e., the amount by which the nominal value should be degraded and enhanced). Given the state-of-the-art of computer fire modeling, this is a very low safety factor. Physical safety factors tend to be on the order of tens of percent; 50% is not unheard of.

Part of the problem with this approach is that it is difficult to state what percentage or range is appropriate. These values may be obtained when the computer model predictions are compared to te.st data However, using computer fire models in a design mode does not facilitate this since (1) the room being analyzed has not been built yet, and (2) test scenarios do not necessarily depict the intended design.

(b) Technical references that are subject to a peer review [process, and are published in widely recognized peer-reviewed journals, conference reports or other publications.

(c) Resource publications such as The Sb"PE Handbook of Fire Protection Engineering which are widely recognized technical sources of information.

The following factors are helpful in determining the acceptability of the individual method or source:

(a) Extent of general acceptance in the relevant professional community. Indications of this acceptance include peer-reviewed publication, widespread citation in the technical literature, and adoption by or within a consensus document.

(b) Extent of documentation of the method, including the Perform a sensitivity analysis on the assumptions that affect the analytical me...t~.d itself, assumptions, scope, limitations, data

condition of interest. Develop a base case which uses all nominal sources a n ~ - ~ l ' . . e d u c t i o n methods. values for input parameters• Vary the input parameters over ,4~&. .~.~•-::.~i.-:'~. regsonable ranges and note the variation in predicted output. This . . . . ~.-'.~ . . . . . . Thi (c) ~ t e i l ~ . ~ vahdauon and analysts of uncer tamues s.

• ~ ¢ : , :1.:-::f¢3;,.

output variation may then become the basis for physical safety mcl' [ ' ~ . ~ c o m ~ 0 n of the overall method with experimental data factors, tq~$ ~ errd'~i{C.t:g.edF'as well as analysis of the uncertainties of

. / . ~ d:~ta, u n c e ~ e s arid limitations in the analytical method, The temporal safety factor addresses the issue of when a ~ c ~ e r t a i n t i e s ~ the associated performance criteria•

condition is predicted and is a function of the rate at which ..... ~%~'i ~ ' ~ :~ Extent to which the method is based on sound scientific processes are expected to occur. If a condition is predicted to

occur two minutes after the start of the fire, then this can be use~,~: print .~s,:. as a nominal value. A similar process of that described above foff~-...~. :~-~;~:"f"~"':'~ physical safety facto.rs can also be employed to develop temporal : ~ : i ' : ' : ~ . ) .::Extent to which the proposed .app!ication ".m with. in the stated safety factors. In thts case, however, the rates (e.g., of heat release, .:.;~ .:!::. ~ and hmatauons of the supportang lnformauon, including the toxic product generation) will be varied instead of absolg~..-....~lues :~ff" ragige of applicability for which there is documented validation•

• . ~ : ~ . - ~ - - . . . . (e.g., matertal properues). .#:" :'--::~*~: "~:~:. Factors such as spataal dimenstons, occupant character~stacs

$ii~ ~$: . ::i~i!:.'::" ambtent condttaons etc., may hmtt vahd apphcataons. • . -.. !$?&. .:~., ..... ~ ~:;.~ ,

The margin of safety can be thought of as a refletff]:6~.~ # ~ . ~ : : : - " values and may be imposed by the AHJ to that p u r p o s e ' ~ c e ~ i ~ In many cases, a method will be built from, and include time a condition is predicted will most likely,~.;~ocu£~!.....~LI~ 's numerous component analyses. These component analyses should (e.g., the model predicts occupants will hav#~]five ~ . e s td:~:"~]y be evaluated using the same factors as are applied to the overall evacuate), margin of safety will be c h a r a c ~ e d ~ t e m # ~ r a l method as outlined above. aspects (and tacitly applied to physical r f i ~ o f safet~.~

~.x. ~'~ A method to address a specific fire safety issue, within Since escaping the harmful effects of fire (or ~ . ~ g them) is, documented limitations or validation regimes, may not exisL In

effectively, a race, the metric of choice when a s s ~ fire safety such a case, sources and calculation methods can be used outside system designs based on computer model predict~ns is time. of their limitations provided the design team recognizes the When an AHJ is faced with the predicted tame of untenability, a limitations and addresses the resulting implications. decision must be made regarding whether or not sufficient tame is available to ensure the safety of building occupants. The AHJ is assessing the margin of safety: "Is there sufficient time to get everyone out safely?" If the AHJ feels that the predicted egress time is too close to the time of untenability then the AHJ can impose an additional time that the designer must incorporate into the system design. This is to say that the AHJ may impose a greater margin of safety than that originally proposed by the designer.

A-$-8.1 The SHE Engineering Guide to Performance-Based Fire Protection Ana~sis and Design describes the documentation that should be provided for a performance-based design.

Proper documentation of a performance design is critical to the design acceptance and construction. Proper documentation will also assure that all parties involved understand what is necessary for the design implementation, maintenance, and continuity of the fire protection design. If attention to details is maintained in the documentation, then there should be little dispute during approval, construction, startup and use.

Poor documentation could result in rejection of an otherwise good design, poor implementation of the design, inadequate system maintenance and reliability, and would provide an incomplete record for future changes or if the design were forensically tested.

The technical references and methodologies to be used in a performance-based design should be closely evaluated by the design team and the authority having jurisdiction, and possibly by a third party reviewer. The strength of the technical justification should be judged using criteria listed above. This justification may be strengthened by the presence of data obtained from fire testing.

A-~8.11 Documentation for modeling should conform to ASTM 1472, Standard Guide for Documenting Computer Software, although most, if not all, models were originally developed before this standard was promulgated.

To the non-mandatory references appendix (to become an annex) add the following:

SFPE Engineering Guide to Performance-based Fire Protection Ana~sis and Design, Society of Fire Protection Engineers, Bethesda, MD, 1998. ,

Fire Engineering Guidelines, Fire Code Perform Centre, Limited, Sydney, Australia, 1996.

Fire Safety Engineering in Buildings, DD240: Part 1, British Standards Insfftution, l , ondon, England, 1997•

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(Log #370) Committee: SAF-EU N

101- 162 - (3-2 Basement): Accept SUBMITTER: Lawrence G. Perry, Building Owners and Managers Assn. Int'l (BOMA) COMMENT ON PROPOSAL NO: 101-20 RECOMMENDATION: Delete the proposed new definition for "basement":

u~:~.=e..'nenL .~n)" :to." 3" "..hzt .h.~ ..'n~re ".~hz.n 50 Fc:ce:zt of the total r~-ca o f "~, ~c.::..."'.c=z= v.~.]~. 5~1o:'." - . ' ~ c . SUBSTANTIATION: Current ~4~A standards contain three different definitions of the term "basement", and this proposed definition does not match any of them. NFPA 1 defines basement as "a story with more than 50 percent of its perimeter below grade.": NFPA 30, NFPA 30A, NFPA 30B, and NFPA 434 define basement as "a story with 1 /2 or more of its height below ground level and to which access for fire-fighting purposes is unduly restricted." NFPA 1141 defines basement as "a story with more than 50 percent of this cubic volume below the average adjacent ground level." In addition, the proposed definition does not match the definition of basement generally found in the model building codes.

The term is used in very few locations in NFPA 101; it should not be defined unless the definition is coordinated with other NFPA standards, and with the model codes. COMMITTEE ACTION: Accept. NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12

(Log #312) Committee: SAF-DET

101- 163- (4-1.5.1): Accept SUBMITrER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-83 RECOMMENDATION: Reject the proposal which adds "Holding Cells" and "Lockups" to A-4-1.5.1. SUBSTANTIATION: Contrary to the proposal the addition of Holding Cells, and Lockups does not assist with the proper classification. In my experience these do not have sleeping accommodations and would be part of the main occupancy such as holding cells in a court house. COMMITTEE ACTION: Accept. NUMBER OF COMMrlq'EE MEMBERS ELIGIBLE TO VOTE: 20 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 19 NOT RETURNED: I Barbaro

(Log#7) Committee: SAF-END

101- 164 - (4-1.12 Exception): Accept in Principle SUBM1TrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-84 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-END, SAF-IND and SAF-MER consider the effect of proposed subpart (a) of the Exception to 4-1.12 with regard to incidental day-care, mercantile, business, industrial and storage uses; and submit any needed revisions to the language during ROC-preparation. " SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

In the new exception being added to 4-1.12 by Proposal 101-84, revise subpart (a) so as to remove the words "day-care,'. COMMITTEE STATEMENT: The SAF-END Committee thanks the TCC on Safety to Life for noting the proposed change to the exception 4-1.12. The committee believes that any day-care use needs to meet the day-care requirements. For example, it would be inappropriate for even the smallest of day-care occupancies to be located on the upper floors of an existing high-rise office building that meets only the requirements applicable to existing business occupancies. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


(Log #7a) Committee: SAF-IND

101- 165 - (4-1.12 Exception): Accept in Principle SUBMITrERa Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-84 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-END, SAF-IND and SAF-MER consider the effect of proposed subpart (a) of the Exception to 4-1.12 with regard to inddental day-care, mercantile, business, industrial and stora~ge uses; and submit any needed revisions to the language during ROC-preparation. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

No luther action needed. COMMITTEE STATEMENT: The Committee reviewed the effect of Proposal 101-84 and determined that no further action is needed. NUMBER OF C O M M r r r E E MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:


(Log #Tb) Committee: SAF-MER

101- 166 - (4-1.12 Exception): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-84 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-END, SAF-IND and SAF-MER consider the effect of proposed subpart (a) of the Exception to 4-1.12 with regard to incidental day-care, mercantile, business, industrial and stora~ge uses; and submit any needed revisions to the language during ROC-preparation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Prindple.

No further action is needed. COMMITTEE STATEMENT: The Technical Committee concurs with the action taken on Proposal 101-84. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


(Log #CC54) Committee: SAF-MEA

101- 167 - (5-1.3.2.1(a)): Accept SUBMITrER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-97

[ RECOMMENDATION: Reject Proposal 101-97. SUBSTANTIATION: The at tempt to integrate performance-based language into Chapter 5 was premature. It might adversely affect the work done for the new performance-based chapter. COMMITTEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101-168- (5-1.$.2.1 (a) Exception and (b) Exception No. 4 (New)): Accept in Principle SUBMrrTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-97 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUN, which has primary responsibility for the development of the materials on performance-based design, review the changes proposed for Chapter 5 via Proposal 101-97 for compatibility with those being

~ roposed as a new Chapter $ on performance-based design. UBSTANTIATION: See the above recommendation.

COMMITTEE ACTION: Accept in Principle. Reject Proposal 101-97.

COMMITrEE STATEMENT: The action taken by the Means of Egress Committee in its proposed revision to Chapter 5 can be misunderstood. Thus, it has the potential to affect adversely the

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use of proposed Chapter 3 on performance-based design. As such, the material should not be added to Chapter 5. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GALLAGHER: I agree with Mr. Lathrop. LATHROP: I strongly believe that to be called an "exit", even

under performance design a minimum enclosure should be provided.


101- 169- (5-1.$.2.1(d)): Accept SUBMITTER= Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-99

I RECOMMENDATION: Add a second Exception to 5-1.3.2.1 (d) to read:

Exception No. 2 to (d): In buildings of Type I or II construction, existing fire protect ion rated doors shall be permitted to interstitial spaces provided that such space:

(a) Is used solely for distribution of pipes, ducts, and conduits, and

(b) Contains no storage, and (c) Is separated from the exit enclosure in accordance with 6-2.$.

SUBSTANTIATION: Interstitial spaces are constructed of noncombustible construction, and separated from the stair enclosure in accordance with 6-2.3. The interstitial level is separated from the floor below by at least one-hour fire resistive construction and at least a 2-hour floor slab above. Interstitial spaces contain noncombustible duct work, plumbing, electrical conduit, sprinkler piping and open cable trays.

The NFPA 15, Standard for the Installation of Sprinkler Systems, Technical Committee recognizes that these spaces constitute an extremely low degree of hazard. NFPA 13 recognizes that these spaces do not pose a threat to the life safety of the building inhabitants even though they are not sprinklered. The committee has formally stated that in order for a building to be considered completely protected by automatic sprinklers, the interstitial space as defined, does not need to be sprinklered. [FI 13-80-29(A)]

Maintaining the integrity of exit stair enclosures is paramount and is not lessened by providing access to interstitial spaces, as defined above. COMMITTEE ACTION: Accept. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


CLog #9) Committee: SAF-MEA

101- 170 - (5-1.5.2.2 Exception (New)): Accept in Principle SUBMITYER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-102 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Koffel's explanation of negative. It reads:

KOFFEL: By adding the proposed exception, it appears as if the exit discharge through the level of exit discharge is still considered part of the exit That is not the intent of the current provisions of the Code. The proponent states that the exception is needed to address "locadons not meeting the strict definition as an exit discharge." It is not apparent why the provisions of 5-7.1 do not meet the definition of exit discharge. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See the Committee Action on Comment 101-172 (Log #314) and Comment 101-171 (Log #252). COMMITTEE STATEMENT: The Committee Action on the referenced comments should satisfy the submitter's i n t en t NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 171 - (5-1.3.2.2 Exception (New)): Accept SUBMITFER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-102

[ RECOMMENDATION: Delete the new Exception. SUBSTANTIATION: I agree totally wi thbo th Mr. Berry and Mr. Koffel. 5-7.1 deals with "exit discharge" not the "exit" enclosure. They are two distinctly different parts of a means of egress. The exception, as proposed, is no t applicable. COMMITFEE ACTION: Accept. NUMBER OF COMMrrFEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFHRMATIVE: 26 NOT RETURNED: 1 Paolucci


101- 172 - (5-1.3.2.2 Exception (New)): Accept SUBMITTER: James ~ Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-102 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: The exit is still protected to the exit discharge. 5-7.2 allows the exit discharge to be inside the building but this does not affect the fact that the exit must be protected to the exit discharge. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 175 - (5-1.5, A-5-1.5): Reject SUBMITFER: Peter A. Larrimer, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-108 RECOMMENDATION: Delete the proposed new wording. SUBSTANTIATION: The new language is more confusing than helpful, especially compared to BOCA's language. Even after reading the committee s substantiation, I don ' t understand the problem that necessitates this change. It effectively allows a 6 ft -8 m. ceiling height with no technical justification. Clearly the authority having jurisdiction can accept variations to the minimum for sloped or curved ceilings such that this confusing language does not have to be added. The appendix note is marginally helpful, but the terminology "...but are not limited to" should be added to ensure that other projections are included. COMMITTEE ACTION: Reject COMMITTEE STATEMENT: The proposed new sentence liberalizes 5-1.5 to allow things such as soflits which extend to a degree to exceed the concept of a "projection". The new wording also helps address situations where there are sloped ceilings or peaked roofs. Because the new wording liberalizes the requirement, there is no need for an exception for existing buildings. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMr['FEE ACTION:

AFFIRMATIVE: 25 NEGATIVE: 1 NOT RETURNED: 1 Paolucci

EXPLANATION OF NEGATIVE: FRABLE: In the Report on Proposals, the Technical Committee

only accepted this proposal to solicit input via public comments on the adequacy of the "two-thirds" criterion. Two public comments were received [101-175 (Log #144) and 101-174 (Log #371)] and both proposed deleting this new text. In addition, this proposal has not been adequately justified to substantiate this "liberalized" revision.

Based on the above concern, the appropriate action on this comment should have been "Accept."

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101- 174 - (5.1.5, A-5-1.5): Reject $UBMYITER: Lawrence G. Perry, Building Owners and Managers Assn. Int'l (BOMA) COMMENT ON PROPOSAL NO: 101-108 RECOMMENDATION: Delete the added second sentence to 5-1.5:

"T~..e :r..:'nL~..um ce'L:ng hc 'ght =h~! ~ m~n*~..~2:ned fc= at !e~t ~:'c

substantiation to introduce the two-thirds requirement for ceiling height. If ceiling height provisions are intended to specifically allow a certain accumulation of smoke, the permitted intrusions into the required area would need to he based on the total volume of the space served, the occupant load, and the time necessary for evacuation.

If the Committee does not delete this requirement, an exception needs to be added for existing buildings, so that this requirement does not apply retroactively. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The proposed new sentence liberalizes 5-1.5 to allow things such as sofiits which extend to a degree to exceed the concept o fa ~ projection". The new wording also helps address situations where there are sloped ceilings or peaked roofs. Because the new wording liberalizes the requirement, there is no need for an exception for existing

c o M M i E .IB, E TO VOTE: 27 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: FRABLE: In the Report on Proposals, the Technical Committee

only accepted this proposal to solicit input via public comments on the adequacy of the "two-thirds" criterion. Two public comments were received [101-173 (Log #144) and 101-174 (Log #371)] and both proposed deleting this new text. In addition, this proposal has not been adequately justified to substantiate this ~liberalized" revision.

Based on the above concern, the appropriate action on this comment should have been "Accept."


101- 175 - (5-1.6 (New), 5-2.2.8.2 and 5-2.2.8.3): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-109 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Paul's comment on affirmative so as to make any needed changes to the appendix material. It reads:

PAULS: The deletion of ~uniformly slip resistanC from 5-2.2.3.3 will require that the portion of the appendix note (dealing with slip resistance of stair treads) be moved to the new 5.1.6. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Remove the following wording from A-5-2.2.3.3. and relocate it so as to become a new A-5-1.6.4:

Regarding the slip resistance of treads, it should be recognized that when walking up or down stair a person's foot exerts a smaller horizontal force against treads than achieved when walking on level floors. Therefore, materials used for floors that are acceptable as slip resistant (as described by ASTM F1637-95, "Standard Practice for Safe Walking Surfaces") provide adequate slip resistance where used for stair treads, including the important leading edges of treads, the part of the tread that the foot first contacts during decent, the most critical direction of travel. If stair treads are wet, there may be an increased danger of slipping, just as there may be an increased danger of slipping on wet floors of similar materials. A small wash or drainage slope on exterior stair treads is therefore recommended to shed water (see Templer, J. A., The Staircase: Studies of Hazards, Falls, and Safer Design, Cambridge, MA: MIT Press, 1992). COMMITTEE STATEMENT: The appendix material moved should satisfy the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 26 NOT RETURNED: 1 Paolucci


101- 176 - (5-1.6.2): Hold SUBMI2WER= L.J. DeFrancisci, DEMACO COMMENT ON PROPOSAL NO: 101-110 RECOMMENDATION: Add wording to 5-1.6.2 (new paragraph 5-1.7.2) to more dearly differentiate the intent of this paragraph in relation to 5-1.6.1:

"...with the requirements of 5-2.2 with the following additions: the

g resence and location of ramped portions...". UBSTANTIATION: Ipresume the meaning is that: If the change in level of egress is more than 21 in. then the

requirements of 5-2.2 apply. If the change in level is not more than 21 in. then the requirements of 5-2.2 apply with the additions stated in the paragraph 5-1.6.2. To me, this is not clear the way it is written. COMMITTEE ACTION: Hold. COMMITrEE STATEMENT: The recommendation introduces material that has not had public review. As such, it must be held ~pk, irocessing during the next revision o/de.

BER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:



101- 177- (5-1.6.2 Exception): Accept in Principle S U B ~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-110 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA, which has primary responsibility Chapter 5 egress provisions, review the change proposed for Chapter 5 via Proposal 101-110 for technical content and compatibility with Chapter 5. SAF-AAC notes that SAF-IND developed this proposal on Chapter 5 after SAF-MEA held its final ROP-preparation meeting. SUBSTANTIATION: See the above recommendation. COMMITFEE ACTION: Accept in Principle.

Retain the Committee Action of accept on Proposal 10L110. COMMITTEE STATEMENT: The Committee Action should meet the suhmitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 178 - (5-2.1.2)= Accept in Principle SUBMITIER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-115,101-121 RECOMMENDATION: Revise 5-2.1.2 to read:

5-2.1.2 F~,v-e~ Width. Revise 5-2.1.2.1 as follows: 5-2.1.2.1" E~ress Canacitv Width. In determining the egress width

for swinging doors for purposes of calculating capacity, only the clear width of the doorway when the door is open 90 degrees shall be measured. In determining the egress width for other types of doors for purposes of calculating capacity, only the clear width of the doorway when the door is in the full open position shall be measured. Clear width of doorways shall be measured between the face of the door and the stop in accordance with 5-3.2.

Add an Exception to read: Exceotion: In determinin~ the width of any exisdng dogf

installation for ourooses of calculatin~ canacitv, only the clear width of the doorway when the door is in-the full onen position shall be measured. Clear width shall be determineti in accordance with 5-3.2.

Add the following title to 5-2.1.2.2: "5-2.1.2.2 Minimum Width. Door..."

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N F P A 101 - - F99 R O C

Revise 5-2.1.2.3 to read: 5-2.1.2.3 Minimum Width Measurement. For ourooses of

determininu minimum door width, the door leaf width shall be v

used unless dear width is spfcified. Where clear width is snecified._ ~-here shall be no projections into the required clear door opening width lower than 34 in. (86 cm) above the floor or ground. Projections into the required clear door opening width which are at least 34 in. (86 cm) but not more than 80 in. (205 cm) above the floor or ground shall not exceed 4 in. (10.1 cm). SUBSTANTIATION: This clearly separates the sizes and measurement based on capacity and the need for wheel chair movement. It incorporates exceptions for existing buildings based on current code andallows the committee to work in the code based on each separate and distinct need. Confusing egress capacity needs with minimum width due to main streaming is not user friendly. COMMITTEE ACTION: Accept in Principle.

Revise 5-2.1.2 to read: 5-2.1.2 ~ r ~ s s Width. Revise 5-2.1.2.1 as follows: 5-2.1.2.1" E~ress Caoacitv Width. In determining the egress width

for swinging doors for purposes of calculating capacity, only the clear width of the doorway when the door is open 90 degrees shall be measured. In determining the egress width for other types of doors for purposes of calculating capacity, only the clear width of the doorway when the door is in the full open position shall be measured. Clear width of doorways shall be measured between the face of the door and the stop in a~cordance with 5-3.2.

Add an Exception to read: Excention: In determining the width 9f any existing door

installation for nurnoses of calculadn~ canacitv, only the clear width of the dogla~y when the door is in the full o0en nosition shall be measured. Clear width shall be determinecl in accordance

Renumber 5-2.1.2.3 as 5-2.1.2.2 and revise it to read: 5-2.1.2.2 Minimum Width Measurement. For nurnoses of

determinin~ minimum door width, the door leaf width shall be used unless clear width is soecified. Where clear width is specified. ~-T-here shall be no projections into the required clear door opening width,measured in accordance with 5-2.1.2.1. lower than

[ 34 in. (86 cm) above the floor or ground. Projections into the required clear door opening width which are at least 34 in. (86 cm) but not more than 80 in. (203 cm) above the floor or ground

I shall be limited to the hinged side of each door opening and shall not exceed 4 in. (10.1 cm).

Projections more than 80 in. (203 cm) above the floor or ~ o u n d shall not be limited.

Renumber 5-2.1.2.2 to become 5-2.1;2.3 and add a title to read: "5-2.1.2.3 Minimum Width. Door . . . .

COMMITTEE STATEMENT: The Committe Action should meet the submitter's intent. The additional changes respond to other

ublic comments. UMBER OF COMMITCEE MEMBERS ELIGIBLE TO VOTE: 27

VOTE ON COMMITCEE ACTION: AFFIRMATIVE: 26 NOT RETURNED: 1 Paolucci


101- 179 - (5-2.1.2): Accept TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed to implement Mr. Gilda's comment so as to revise Figure A-5-2.1.2.2(b) to add the door frame to the top and left side of the figure; and to remove the cross-hatching from the top and left of the figure, (both) as done in Figure A-5-2.1.2.1(b).

Further, the SAF-AAC directs that the action be changed to implement Mr. Koffel's comment so as to revise Figure A-5-2.1.2.1(a) to change the label that appears across the door opening from ~Minimum clear width" to =Egress capacity width.- - SUBM1TTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-115, 101-121 RECOMMENDATION: Add an appendix to read:

A-5-2.1.2.1. Figures A-5-2.1.2.1 (a) and A-5-2.1.2.1 (b) illustrate the method of measuring door width for purposes of calculating egress capacity.

I Wall I 4--- Egress capacity width -~

i

T' \ I o/

Figure A-5-2.1.2.1(a) Door width - egress capacity.

• Framo

Door In. [ I I

P'AI I ~in. 5 cm)

~-.--eDoor width for . - - -~ gress capac i ty - -

F'tgure A-5-2.l.2(b) Door width - egress capacity with allowed obstructions.

Renumber existing appendix A-5-2.1.2.1 to become A-5-2.1.2.2 and change the first paragraph to read:

A-5-2.1.2.2 Figures A-5-2.1.2.2(a) and A-5-2.1.2.2(b) illustrate the method of measuring minimum clear width for doors.

¢ Wall ~ --- Minimum clear width

I

T ' \

Figure A-5-2.1.2.2(a) Minimum clear width.

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N F P A 101 - - F 9 9 R O C

,a,,,,,--Hinged side

~-- Frame

Door

80 in. (203 cm)

(->86 era)

Minimum clear width

KOFFEL: It should be noted that proposals Proposal 101-115 (Log #GP101) and Proposal 101-121 (Log 0CP103) are related and must be considered together. During the discussions on these two

~ roposals, a concept was introduced that was not included in the nai committee action. The concept involved different methods of

determining clear width based upon the purpose of the measurement (capacity or minimum width). A means to resolve some of the negative comments would be to use different methods of measurement. Therefore, the purpose of including this affirmative comment is to include this concept in the ROP to enable the public to comment on this concept as well.

2. Any need for an exception to the 90 degree rule for existing, previously approved arrangements.

3. Exactly how to modify Figure A-5-2.1.2.1. 4. Whether any addironal appendix figures are needed to

support the new sentence being added to A-5-2.1.2.1. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Comments 101-178 (Log #315) and 101-179 (Log #CC250). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


Figure A-5-2.1.2.2(b) Minimum clear width with allowed obstructions.

Delete current Figure A-5-2.1.2.1. SUBSTANTIATION: The revision to the appendix, including the new figures, further explains intent and supplements actions on other comments. COMMITTEE ACTION: Accept. NUMBER OF COMMrrTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


COMMENT ON AFFIRMATIVE: GILl)A: From the drawing shown in A-5-2.1.2.2(b), the format

should be replicated from A-5-2.1.2.1(b). A-5-2.1.2.1(b) shows the frame around the periphery of the opening. The frame should also be shown around the periphery of the opening in A-5-2.1.2.2(b) as well. The cross-hatching across the top of the opening and the left side of the opening should be eliminated in A-5-2.1.2.2(b).

KOFFEL: I agree that the proposed diagrams are consistent with the action taken during the technical committee meeting. However, after further consideration the dimension shown and identified as "Min. Clear Width" in proposed Figure A-5-2.1.2.1 (a) should be revised to "Egress Capacity Width." This would be more consistent with the dtle of the figure and the text of 5-2.1.2.1 as revised in Comment 101-178 (Log #MS).


101- 180 - (5-2.1.2.1, A-5.2.1.2.1 and Figure A-5-2.1.2.1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-115 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA reconsider it action so as to address:

1. Needed coordination between this proposal and Proposal 101- 121 as mentioned in Mr. Woodward's explanation of negative and Mr. Koffel's comment on affirmative. They read:

WOODWARD: The width should be measured from the stop to the closest obstruction p including hardware. It should not just be done to the face of the door. This proposal should be tied to Committee Proposal 101-121 (Log #CP103)so that they only go together and not separately. While Committee Proposal 101-121 (Log #CP103) will assure that "clear width" is maintained for accessibility, permitting a 4 inch reduction in the width between the 34 and 80 inch heights runs counter to 5-3.2 and seems unjustified. "Clear width" should be clear width. Given that a 32 inch width would then be reduced to 28 inches, does not seem to account for the body sway which is shown as "to 30 inches" in the appendix.

(Lo~ #1s) Committee: ~AF-MEA

101- 181 - (5-2.1.2.2 Exception No. 6 (New)): Accept in Principle SUBMITTF~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 1 0 1 - 1 1 9 ,

RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA reconsider it action so as to address the concerns contained in Mr. Versteeg's explanation of negative. There is precedence in the Code for allowing exemptions for spaces not within the accessible route (e.g., assembly occupancy ramp provisions). It reads: VERSTEEG: I vote against the committee's action in this matter.

The submitter seeks to add a new exception that would allow exit access doors in new construction to be 98 inches in clear width when the area served is not required to be accessible to persons in wheelchairs, regardless of room size. Currently, the minimum clear width of an egress door in new construction is 32 inches and is onlypermitted to be reduced to 24 inches if serving a room not larger than 70 square feet and that room is not required to be accessible to persons in wheelchairs. This new exception would allow the use of 28 inch clear width doors versus the current minimum clear width of 32 inches in many new structures where rooms or spaces within are not required to be accessible to persons in wheelchairs, e.g. pilot briefing rooms on military installations. Not including this exception places an authority having jurisdiction in the less desirable position of having to waive a Code requirement rather than simply determine the proper application of this new exception in a given situation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Insert a new Exception No. 2 to read: Exception No. 2: Doors serving a building or portion thereof not

required to be accessible to persons with severe mobility impairments shall be permitted to be 28 in. (71 cm) in door width.

Revise Exception No. 1 to read: "...accessible to persons with severe mobility impairments shall be

at least 24 in...." Renumber existing Exceptions No. 2 through 5 to become

Exceptions No. 3 through 6. COMMITTEE STATEMENT: The committe action should meet the submitter's intent. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON CO MITI'EE ACTION:


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N F P A 101 m F 9 9 R O C


101- 182 - (5-2.1.2.$ and A-5-2.1.2.$ (New)): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-121 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA reconsider it action so as to address:

1. Needed coordination between this proposal and Proposal 101- 115 as mentioned in Mr. Koffel's comment on affirmative.

2. Mr. Woodward's concerns of conflict with the principles of 5-3.2 as presented in his explanation of negative. They read: KOFFEL: It should be noted that proposals Committee Proposal

101-115 (Log #CP101) and Committee Proposal 101-121 (Log #CP103) are related and must be considered together. During the discussions on these two proposals, a concept was introducedthat was not included in the final committee action. The concept involved different methods of determining clear width based upon the purpose of the measurement (capacity or minimum width). A means to resolve some of the negative comments would be to use different methods of measurement. Therefore, the purpose of including this affirmative comment is to include this concept in the ROP to enable the public to comment on this concept as well.

WOODWARD: While the proposal will assure that "clear width" is maintained for accessibility, permitting a 4 inch reduction in the width between the $4 and 80 inch heights runs counter to 5-3.2 and seems unjustified. "Clear width" should be dear width. Given that a 32 inch width would then be reduced to 28 inches, does not seem to account for the body sway which is shown as "to 30 inches" in the appendix. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Comments 101-178 (Log #$15) and 101-179 (Log #CCA0). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 183 - (5-2.1.4.1 Exception No. 1): Accept SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-123

I RECOMMENDATION: Revise Exception No. 1 to read as follows: "Sliding doors as provided in Chapters 14 and 15, and doors as

provided in Chapters 21.22. and 23 ." SUBSTANTIATION: Recent changes to 22-$.2.2.2(b) and 25- 3.2.2.2(b) have permitted doors within individual rooms and suites of rooms in Large Residential Board and Care Occupancies to be swinging or sliding. This proposal seeks to coordinate the provisions of the occupancy chapters with the requirements of Chapter 5 for the permitted operation of doors. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


Further, SAF-AAC directs that the public comment request that SAF-MEA reconsider Exception No. 2 to 5-2.1.4.4 in light of the directive that the technical committees examine the provisions applicable to existing buildings. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Do not change the body of 5-2.1.4.4 and do not add Exception No. 1.

Revise Exception No. 2 to read: "Exception No. 2: In existing buildings, a door providing access

to a stmr shall not be required to maintain any minimum unobstructed width during its swing and, when open...". COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMrrrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #$16) Committee: SAF-MEA

101- 185 - (5-2.1.5.1): Accept SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-128

I RECOMMENDATION: In the last line of 5-2.1.5.1 delete "of the building". SUBSTANTIATION: Not needed. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITFEE ACTION:



101- 186- (5-2.1.5.$): Reject SUBMITTER= Joshua W. Elvove, U.S. Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-132 RECOMMENDATION: Revise 5-2.1.5.3 as follows:

5-2.1.5.3" Where installed, a A-latch or other fastening device on a door shall be provided with a releasing device .ha:'z,g :.= o~-'ou~ mc'&od, of opcr:'.2~:, that is readily ooergted under all lighting conditions. The releasing mechanism for any latch shall be located at least $4 in. (86 cm] and not more than 48 in. (122 cm) above the finished floor. Doors shall be operable with not more than one releasing operation.

Both exceptions (one existing and one new) to remain. SUBSTANTIATION: This paragraph does not require latches to be installed. This is to clarify that this requirement applies to all latches where installed (for whatever reason) and not merely to latches that are required to be installed (for Code reasons). COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The language already does what is requested because it does not require latches. Rather, the requirement applies only when latches are installed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:



101- 184- (5-2.1.4.4): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-126 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Woodward's comment on affirmative that appears with Proposal 101-127. Although Mr. Woodward's comment was shown on his letter ballot as applying to Log #CP507 (which subsequently was sequenced as Proposal 101-127), it appears to be applicable to Proposal 101-126. It reads:

WOODWARD: The 22 inch minimum is not required in the Uniform Building Code. The one-half rule is included but could be used to accept 18 inches in a $6 inch corridor. Sections 1005.4 and 1006.2 of the International Building Code first draft also do not contain the 22 inch limitation.


101- 187- (5-2.1.5.$): Reject SUBMI'ITER= Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-129 RECOMMENDATION: Accept the submitter's original language. SUBSTANTIATION: I agree with both of the committee members who voted negatively. When a person is on the roof of a building, regardless of how they got there, they are "in the building" unless there is a safe code- complying means of egress from the roof. I know of maintenance personnel who have inadvertently been locked onto roofs when a door closed behind them. Keep it simple and do what the submitter proposed. His language does not prohibit you from locking the roof door in the stair to roof direction. COMMITTEE ACTION: Reject.

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N F P A 101 ~ F 9 9 R O C

COMMITTEE STATEMENT: The Committee Action sets up a condition that has fewer pitfalls than that originally submitted. NUMBER OF COMMrITEE MEMBERS ELIgIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 ABSTENTION: 1 NOT RETURNED: 1 Paolucci

EXPLANATION OF ABSTENTION: ELVOVE: The verbiage submitted by the original proponent and

as revised by the Committee is not necessary nor truly addresses this concern adequately. Furthermore, the text as proposed in the ROP/ROC may cause even more confusion. Hence, I'd prefer to see the newly proposed paragraph 5-2.1.5.$ be deleted in its entirety from the code. Egress from the roof is already covered under the provisions of 5-2.1.5.1 which state, "Doors shall be arranged to be opened readily from the egress side whenever the building is occupied."

As currendy proposed (using the Committee's language) because of the "or" condition, if a door from a stair enclosure to the roof is locked, there are no further requirements for re-entry from the roof. Hence, if an individual somehow gets onto the roof (e.g., the doors is left open) and the stair/roof access door is then closed or locked, that individual could be trapped. There needs to be a provision to allow re-entry from the roof for those individuals who are authorized to be on the roof and are inadvertendy trapped on the roof. Requiring that an access door to a roof be locked, though a good idea for security purposes, should not be part of the scope of this Committee; and one should not assume an individual who accesses the roof will necessarily have the means or ability to egress the roof (e.g., no locking hardware from the roof side).This assumption is not made for health care occupancies; if it were, then the pro~sions in 12/15-2.2.2.5 (e.g., all staff must carry keys, etc.) wouldn t be necessary.

If a special exception for locking doors from the roof to the stair is deemed necessary, and I feel it is, then I would suggest the following code change:

Add a third Exception to 5-2.1.5.1 and a corresponding appendix note as follows:

5-2.1.5.1 Exception No. $: A door serving a stair enclosure and a roof shall be permitted to be locked from the egress side, provided the roof is not normally occupied and adequate means for the rapid removal of authorized occupants are available.

A-5-2.1.5.1 Exception No. 3 Adequate means could be remote- control of locks, keying all roof door locks to keys carried by authorized staff or keys carried by authorized staff at all times.

Substantiation: This exception is needed topermi t egress doors from a roof into a stair enclosure to be Iockedwhen the roof is not normally occupied and certain safeguards to prevent entrapment are provided. This proposal borrows language from the health care occupancy chapter (12/15-2.2.2.5) which permits certain doors to be locked if sufficient safeguards (like those suggested in the proposed appendix) are provided. This also ensures that the provisions only apply for those individuals who are authorized to be on the roof to ensure building security.


101- 188 - (5-2.1.5.5): Accept SUBMrI'rER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-152 RECOMMENDATION: Revise 5-2.1.5.$ as follows:

5-2.1.5.$* A latch or other fastening device on a door shall be provided with a releasing device having an obvious method of operation and that is readily operated under all lighting conditions. The releasing mechanism for any latch shall be located at least $4 in. (86 cm) and not more than 48 in. (122 cm) above the finished floor. Doors shall be operable with not more than one releasing operation.

]Both exceptions (one existing and one new) to remain. SUBSTANTIATION: It is important to retain the concept of obvious method of operation. Thus, the words originally stricken in the ROP have been reinserted. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE:

DIPII.2.A: The wording regarding %.having an obvious method of operation and that is..." had been removed and has now been reinserted. At the prior G5 meeting, we had discussed this subject at length, and there was a consensus that words such as ~obvious" are too vague and subjective to be of any value. In addition, the provision that is "readily operated under all lighting conditions" covers this concept. Recommend this wording be removed as was originally discussed.


101- 189 - (5-2.1.5.3 Exception (New)): Hold SUBMITTER: Margaret R. Engwer, Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-152 RECOMMENDATION: Add an Exception to read:

"In existin~ buildings, office soaces of uD to 400 so ft routinely occuoied by not more than four Dersons.-shall be oermitted to have not more than one addition~ releasin~ ooeration, provided such device is operable from inside without-the use of a key or tool." SUBSTANTIATION: Door hardware that employs separate locking and latching devices is commonly found in existing buildings. An example is a F21 mortise lock set described in ANSI Standard A-156.13 as a room lock. This hardware set consists of a deadbolt lock that is key operated on the outside with a thumb turn release on the inside. The dead lock is used in combination with a separate latch knob. Two operations are required to open a door equipped with this hardware set, when the deadbolt is locked. ANSI's description of he hardware set as a room lock could account for the wide use of this type of hardware arrangement in existing buildings.

5-2.1.5.$ requires that doors be openable with not more than one releasing operation. The intent is to assure that doors are easily openable by persons who may not be familiar with the are3. This intent is evidenced by the fact that the existing exception allows use of a second release device in residential living units or guest rooms where the occupant(s) would reasonably be expected to be familiar with the locking arrangement and methods of release.

The proposed exception would allow hardware that requires two releasing operations to continue in use in existing buildings under restricted circumstances. The business occupancy chapters of NFPA 101 set the occupant load at a minimum of 100 sq ft per person. Based on that requirement, it is clear that NFPA already allows an office space of 400 sq ft toe routinely used for four persons. In a room of that size with four occupants, it is reasonable to expect that all occupants would be familiar with the lockin~ arrangement and would be able to easily open the door in case o r emergency. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The recommended text introduces new material that has not had public review. As such, it needs to be held for the next revision.cycle. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 190 - (5-2.1.5.3 Exception (New)): Hold SUBMITTER: Margaret R. Engwer, Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-132 RECOMMENDATION: Add an Exception to read:

"In existin~ buildings storage rooms and mechanical s~aces shall be permitted to have-not more than one additional r¢le~imr onemtion, nrovided such device is operable from inside without the use of a key or tool." SUBSTANTIATION: Door hardware that employs separate locking and latching devices is commonly found don storage and mechanical spaces in existing buildings. In fact, the hardware set described in ANSI Standard A-156.15 as a store room lock consists of a deadbolt that is key operated both inside and out, combined with a separate latch knob. This type of locking arrangement would not be permitted, even with the new exception w but the point is made to illustrate that when a recognized standard such as ANSI lists a hardware set as a store room lock, it is easy for

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N F P A 101 ~ F 9 9 R O C

building owners to believe the locking arrangement is acceptable and meets code.

Storage and mechanical rooms are occupiable spaces, they are not designed or intended for continuous occupancy. In addition, when deadbolts or similar locks are used to secure these rooms, access is restricted to authorized persons, i.e., those who have a key. It is highly likely that individuals who have a key and are authorized to enter the space would be familiar with and able to operate the door release mechanisms.

The code already permits two releasing operations to be used in residential settings where there is high expectation that occupants will be familiar with the releasing operation. This exception deals with a similar circumstance ~ access is restricted to authorized persons who would be familiar with the space and locking arrangement. The exception should therefore be permitted. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The recommended text introduces new material that has not had public review. As such, it needs to be held for the next revision cycle. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 191 - (5-2.1.6.1(c), A-5-2.1.6.1(c)): Reject SUBMITrER: James IL Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-137 RECOMMENDATION: Accept the original proposal 101-137. SUBSTANTIATION: See the original substantiation along with the negatives of Bush and Versteeg on Proposal 101-135 and Versteeg for Proposal 101-137. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: There is no need for the feature requested. The delayed e.~,ress device does not present a permanent locked-in condition. Rather, it is temporary for 15 or 30 seconds. Thus, it can be equated to a travel distance allowance where the presence of sprinklers permits a longer travel path which results in a longer egress route to the exit. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:



101- 192 - (5-2.1.6.1(c), A-5-2.1.6.1(c) (New)): Reject SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-135 RECOMMENDATION: Add a new 5-2.1.6.1 (c) as follows:

~The doors unlock unon condition¢s) that would urevent the oneration of the automatic fire detection system or snrinkler s~terq in the fire zone serving the snace immediately adiacent to the door.

Excevtion to ¢c): Existing delayed egress lock installations. ~ Renu-mber remaining subparagraphsof this section as necessary. Add a new A-5-2.1.6.1 (c) as follows: ~The intent of this subnaragraoh is to provide for unimveded

e~ess from snaces where thelevels of fire urotection installed immediately adjacent to any eeress door orovided with delayed egress locks have been reduced. The unlocking operation of these doors does not reouire automatic oneration, and may be by manual means. Where the building is not subdivided into fire protection zones, this reouirement should anply to the entire building. It is not intencled that the temoorarv "disablemenC of a system comnonents for testify, maintenance, or reoair uumoses which woulc1 not comnromisethe oneration of remaining clevices on that system would necessitate the release of these loc~." SUBSTANTIATION: The wording of this subparagraph has been revised to address some of the concerns of the original submitter. A new exception has been added to permit existing designs to be continued in use. The term ~disablemenC has been replaced with wording to more dearly address the levels of service interruption necessary to require the unlocking of these doors, Trouble conditions or removal of specific system devices would be permitted to continue provided their presence does not prevent the

remaining components of the system to function in the event of a fire emergency. The unlocking of these doors does not involve major design or construction changes, nor does it prevent normal levels of building occupancy, as may be required for the installation of additional means of egress or fire rated enclosures as permitted by other trade-offs in fully protected buildings. While adequate levels of security are important to maintain, jeopardizing the life safety of the building occupants should be of paramount importance. The current wording in the Code without this subparagraph introduces a "major hazard by permitting locks with no arrangement for immediate release except upon loss of power, even while the fire protection system features of the building have been diminished. This arrangementmay not be acceptable when fire and /o r smoke conditions at the locked door pose an immediate threat to persons awaiting the delay release mechanism to release in accordance with code-complying design delays. The lack of these requirements poses a serious threat that should not be permitted. COMMITlrEE ACTION: Reject. COMMITrEE STATEMENT: See Committee Statement for rejection of Comment 101-191 (Log #317). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:


EXPLANATION OF NEGATIVE: BUSH: Even for a limited period of time, where any impediment

restricts the free and clear use of means of egress, additional precautions must be in place to compensate for the delay in evacuation or protection of building occupants from any threatening condition. The proposed exception addresses the original Committee concerns regarding existing conditions. In addition, a new appendix note serves as clarification that the doors should be automaucally or manually unlocked whenever there is a major impairment to the levels of fire protection in areas immediately adjacent to the locked door. These revisions should clearly specify the intentions of this required level of protection and address the reasons for the original rejection of the proposal.

While adequate levels of security are important to maintain, jeopardizing the life safety of the building occupants should be of paramount importance. T h e current wording in the Code without this subparagraph introduces a major hazard by permitting locks with no arrangement for immediate release except upon loss of power, even while the fire protection features of the building have been diminished. This arrangement may not be acceptable when fire and /o r smoke conditions at the locked door pose an immediate threat to persons awaiting the delay release mechanism to unlock in accordance with code-complying design delays.


101- 193 - (5-2.1.8): Accept in Principle in Part SUBMITTER: Peter A. Larrimer, Dept. of Veterans Affmrs COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Revise as follows:

5-2.1.8 Self-Closing Devices. 5-2.1.8.1 A door designed to normally be kept closed "a :. m c z :

ogcgr-e~ shall not be secured in the open position at any time and be ~ self-closing or automatic dosing in accordance with 5-2.1.8.2.

5-2.1.8.2 (a) and (b) no change, replace (c) with the following: (c~ The automatic releasing mechanism or medium is activated

v

Ip¥ the oneration of approved smoke detectors installed in ~¢cordance with the reuuirements for doors release service in ]qFPA 72. National Fire-Alarm Code. or smoke detection installed to protect the door ovening within the linear styacing reouirements of ~ ' P A 72 and connected to a nrotected vren:fises fire ~arm system control unit.

Delete (d) and (e), leave (I) unchanged. SUBSTANTIATION: This requirement for self-closing/automatic closing applies to all doors, not just those in a means of egress. Other chapters in the code reference this paragraph for doors which are not in the means of egress.

NFPA 72 provides the requirements for the installation of detectors for door closing (whether or not they are connected to a control unit). It is a fire safety control function by definition and the requirements for failsafe operation [deleted item (e)] and supeva'sion (d) is also covered in NFPA 72.

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The complete building fire detection system should be deleted as this is rarely, if ever, used. I agree with the submitters substantiation in ROP 101-150 with the exception that you do not need detection throughout the corridor for cross corridor doors. COMMITTEE A c r I O N : Accept in Principle in Part.

Revise as follows: 5-2.1.8 Self-Closing Devices. 5-2.1.8.1 A door required to normally be kept closed shall not be

secured in the open position at any time and shall be self-closing or automatic closing in accordance with'5-2.1.8.2.

5-2.1.8.2 (a) and (b) no change, replace (c) with the following: (c) The automatic releasing mechanism or medium is activated

by the operation of approved smoke detectors installed in accordance with the requirements for smoke detectors for door release service in NFPA 72, National Fire Alarm Code.

Delete (d) and leave (e) and (f) unchanged. Delete Exception to (c) as done by Proposal 101-150.

COMMrI'rEESTATEMENT: The Committee Action modifies the submitter's text to reflect changes made to NFPA 72. This should meet the submitter's intent. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 194 - (5-2.1.8 and Exception): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) recjuests that SAF-MEA reconsider it action so as to coordinate with the action on Proposal 101-150, reduce potential conflicts with the provisions of NFPA 72, and present the material in a format that is usable and representative of the committee's in t en t SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-193 (Log #145). COMMITTEE STATEMENT: This Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #17) Committee: SAF-M EA

101- 195 - (5-2.1.8(c)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: I01-150 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA reconsider it action so as to coordinate with the action on Proposal 101-149, reduce potential conflicts with the provisions of NFPA 72, and present the material in a format that is usable and representative of the committee's intent. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-195 (Log #145). COMMITrEE STATEMENT: This Committee Action should meet the submitter's intent. NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON c o M M r r r E E ACTION:



101- 196 - (5-2.1.8.2): Accept SUBMITrER: James ~ Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Revise 5-2.1.8.2(b) as follows:

5-2.1.8" Self-Closing Devices. 5-2.1.8.1 A door designed to normally be kept closed in a means

of egress shall not be secured in the open position at any time and be a serf-closing or automatic closing in accordance with 5-2.1.8.2.

5-2.1.8.2 In any building of low or ordinary hazard contents, as defined in 4-2.2.2 and 4-2.2.3, or where approved by the authority having jurisdiction, doors shall be permitted to be automatic- closing, provided that

(a) U p o n release of the hold-open mechanism, the door becomes self-closing; and

(b) The release device is designed so that the door instantly releases manually and upon release becomes self-dosing, or the door c a n b e readily doseds; and... SUBSTANTIATION: ff the door readily closes it is self-closing, I believe the original intent was that the door can be readily closed manually. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #CG52) Committee: SAF-MEA

101- 197 - (5-2.1.9): Accept SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-152 RECOMMENDATION: Add an asterisk to 5-2.1.9 and add the following appendix:

A-5-2.1.9. Power doors are divided into two categories - power assisted and power operated. Power assisted doors that conform to ANSI/BHMA A156.19, American National Standard for Power Assist & Low Energy Power Operated Doors, use limited power to operate the door. They require fewer safeguards as compared to full power operated doors. These door operators are for swinging doors only. Power operated doors that conform to ANSI/BHMA A156.10, American National Standard for Power Operated Pedestrian Doors, require more power to operate the door and require additional safeguards to provide protection against

ersonal injury. Power operated doors can be swinging, sliding or lding doors.

SUBSTANTIATION: The appendix material provides needed information. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 198 - (5-2.1.9.2): Accept in Principle SUBM]TTEI~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-153 RECOMMENDATION: The Technical Gorrelating Committee on Safety to Life (SAF-AAG) requests that SAF-MEA evaluate the merits of the recommendation prepared by SAF-HEA in Proposal 101-153 and revise its action on Proposal 101-152 as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-200 (Log #$19). CO MITrEE STATEMENT: This Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


130



101- 199- (5-2.1.9.2): Accept in Principle SUBMI]TER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT O N PROPOSAL NO: 101-152 RECOMMENDATION: Add "or sliding" after the word "swinging". SUBSTANTIATION: So that sliding doors that are required to be self-dosing are also addressed. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-200 (Log #319) which deletes the word "swinging" so 5-2.1.9.2 applies to any door type. COMMITTEE STATEMENT: This Committee Action should meet the submitter's intent. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 200 - (5-2.1.9.2): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be revised in 5-2.1.9.1 to replace the word ~reqldred" with the words "means of egress" so as to read: "5-2.1.9.1" General. Where means o f ~ doors are operated .. ."

This change is clone for correlation wlth the action in the RO P on Proposal 101-151. SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT O N PROPOSAL NO: 101-152 RECOMMENDATION: Revise the proposed 5-2.1.9 as follows:

5-2.1.9 Powered Doors. 5-2.1.9.1" Power-Operated Doors. Where required doors are

operated by power upon the approach of a person or doors with OWer-assisted manual operation, the design shall be such that ... ontinue without change and retain the five exceptions] 5-2.1.9.2 Power-Assisted Doors Required to Be Self-Closing.

Where ~ doors are required to be self-closing and (1) are operated by power upon the approach of a person, or (2) are provided with power-asslsted manual operation, they shall be permitted in the means of egress under the following conditions:

(a) Door can be opened manually in accordance with 5-2.1.9.1 to permit egress travel in the event of power failure;

(b) Door remains in the closed postti" "on unless actuated or opened manually;

. . . . . . . . . . ~ . . . . . . . . . . . . ~"'~' . . . . . . .-3.~ ~ ' K 77 ".'k :7..,';Z,: . . . . . . ~ ; . . . . . . . . . . . . . ; . . . . . . . , . . . . . . . . . ~ . . . . at r ~ IN

. . . . ~ \ ; in h=:.ght on a con~-a~fing ~..z.ckgroun~ .(..~. xcO - When actuated, the door remains open for not more than

30 seconds; .(O.)_ xcg+ ff door is held open for any period of time, it will c lose -

and the power assist mechanism will not function - upon operation of approved smoke detectors installed in such a way as to detect smoke on either side of the door opening in accordance with the provisions, of NFPA 72, National Fire Alarm Code;

(e) Doors reouired to be self-latchin~ are either self-latching or become self-latchine unon ooeration ~ annroved smoke detectors ~m/mz

.(]~.~4~,~- Power-assisted doors comply with BHMA/ANSI A156.19, American National Standard for Power Assist and Low Energy Power Operated Doors.

To 33-1.2 add: BHMA/ANSI A-156.19-1997, American National Standard for

Power Assist and Low Energy Power Operated Doors, Builders Hardware Manufacturers Association, 355 Lexington Avenue - 17th Floor, New York, NY 1001%6603 (5-2.1.9.2) SUBSTANTIATION: There does not appear to be any reason to restrict this to swinging doors, 5-2.1.9.1 covers both power-operated swinging and sliding doors, this should be able to do the same.

A simple reference to 5-2.1.9.1 ran handle all the egress considerations allowing the deletion of (c), (d), and (e). Most doors required to be self-dosing also have to be self-latching (fire rated doors) and the new (e) addresses that concern. COMMITTEE ACTION: Accept in Principle.

Revise the proposed 5-2.1.9 as follows: 5-2ol.9 Powered Doors. 5-2.1.9.1" General. Where required doors are operated by power

upon the approach of a person or doors with power-assisted manual operation, the design shall be such that ... [continue without change and retain the five exceptions]

5-2.1.9.2 Doors Required to Be Self-Closing. Where doors are required to be self-closing and (I) are operated by power upon the approach of a person, or (2) are provided with power-assisted manual operation, they shall be permitted in the means of egress under the following conditions:

(a) Doors can be opened manually in accordance with 5-2.1.9.1 to permit egress travel in the event of power failure;

(b) New doors remain in the closedposition unless actuated or opened manually;

(c) When actuated, new doors remain open for not more than 30 seconds;

(d) Doors held open for any period of time shall close - and the power assist mechanism will not function - upon operation of approved smoke detectors installed in such a way as to detect smoke on either side of the door opening in accordance with the provisions of NFPA 72, Nadonal Fire Alarm Code;

(e) Doors required to be self-latching are either self-latching or become self-latching upon operation of approved smoke detectors

p e r (d); . . . I (f) New power-assisted swinging doors comply with BHMA/ANSI A156.19, AmericanNational Standard for Power Assist and Low Energy Power Operated Doors.

To 33`1.2 add: BHMA/ANSI A-156.19-1997, American National Standard for

Power Assist and Low Energy Power Operated Doors, Builders Hardware Manufacturers Association, 355 Lexington Avenue - 17th Floor, NewYork, NY 10017-6603 (5-2.1.9.2) COMMITIT~ STATEMENT: The revisions made by the committee to the material submitted reflect enhancements that should be acceptable to the submitter. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 201 - (5-2.1.14): Accept in Part SUBMITTER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT O N P ROP O SAL NO: 101-159 RECOMMENDATION: Do not delete the Exception to (d). SUBSTANTIATION: The committee substantiation is incorrect There is justifirafion for maintaining this exception. There is no reason to require this criteria when a sliding door serves less than 50 persons because it is not likely that severalpeople will be pushing on the door while trying to open it. If the committee does not wish to retain the exception for all such doors serving fewer than 50, I request that you at least keep the exception for existing doors. It is very difficult to run such a test on doors that are already in place. COMMITTEE ACTION: Accept in Part.

See Comment 101-202( Log #320). COMMITTEE STATEMENT: The action on the referenced comment accomplishes part of what the submitter requested. The exemption is not warranted for new installations. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 26 NOT RETURNED: 1 Paolucci.


101- 202 - (5-2.1.14): Accept SUBMITrER: James K. Lathrop, Koffel Assoc., Inc. COMMENT O N P ROP O SAL NO: 101-159

I RECOMMENDATION: Instead of deleting 5-2.1.14(d) Exception, revise it to read:

Exception to (d): ~ horizontal sliding exit access doors servingan area having an occupant load of fewer than 50. SUBSTANTIATION: Insuffidentjustification was provided to delete this for existing installations. COMMITTEE ACTION: Accept.

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N F P A 101 ~ F99 R O C




101- 203 - (5-2.2.2.4): Accept in Principle SUBMITIT_~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-165 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Koffei's comment on affirmative. It reads:

KOFFEL: Additional editorial modifications should be made to clarify that the two exceptions do not apply to the "where specifically permitted...--provisions in 5-2.2.2.4. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise 5.2.2.2.4 to read: 5-2.2.2.4 Spiral Stairs. 5-2.2.2.4.1 Where specifically permitted for individual occupancies

by Chapters 8 through 31, spiral stairs shall be permitted as a component in a means of egress in accordance with 5.2.2.2.4.2 through 5-2.2.2.4.4.

5-2.2.2.4.2 Spiral stairs shall be permitted provided: (continue with (a) through (f) as in the ROP).

5-2.2.2.4.5 Where the occupant load served does not exceed 3, spiral stairs shall be permitted provided: (continue with (a) through 40 of Exception No. 1 in the ROP).

5-2.2.2.4.4 Within dwelling units, guest rooms and guest suites, and existing buildings, where the occupant load served does not exceed 5, spiral stairs shall be permitted provided: (continue with (a) through (e) of Exception No. 2 in the ROP). COMMITTEE STATEMENT: The Committee Action should satisfy the submitter's intent. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 204- (5-2,2.3.3): Accept SUBMrrTER: Joshua W. Elvove, U.S, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-109 RECOMMENDATION: Revise 5-2.2.$.3 as follows:

5.2.2.$.3" Tread and Landing Surfaces. Stair treads and landings shall be solid, without perforations, u~'~f~.rm! 7 :Ep .-~-:w~., and free of projections or lips that could trip stair users. If not vertical, risers shall be permitted to slope under the tread at an angle of not more than $0 degrees from vertical, however, the permitted projection of the nosing shall not be more than 1 1/2 in. (3.8 cm).

Exception to remain. SUBSTANTIATION: Adding the term "without perforations" is consistent with language that currently exists for Floors in 5-2.6.3. Note: If this is deemed superfluous, then an alternative recommendation is to delete 5-2.6.3 in its entirety as i t would be superfluous as well given the new text proposed by 5-1.6 (new). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 23 NEGATIVE: $ NOT RETURNED: 1 Paolucci

EXPLANATION OF NEGATIVE: DIPILLA: The addition of %vithout perforations ~ is redundant,

considering the preceding wording which indicates that treads and landings are to be ~solid ". If it is solid, it is by definition without perforations. Recommend removal of this wording.

PAUL.S: I am voting negatively on this item (as I voted negatively with several other committee members durin~ the ROC meeting) because I do not see justification for prohibi t ing perforations on stair treads and landings. There might be quite valid reasons, such as drainage of moisture, for having perforations in the surfaces. Moreover, even ICC/ANSI A117.1 permits openings in walking surfaces so long as the openings do not allow passage of a 1 /2 inch diameter sphere. Generally, there does not appear to be a reason for the prohibition based on circulation safety. If there is some fire

protection reason for not having perforations this can be dealt with elsewhere in the Code.

WOODWARD: My records indicate that this was accept in principle: my copy shows the word "surface ~ being added after the word "solid. ~

I believe the requirement for the floor surface to be ~solid ~ is too restrictive when combined with the wording "without l~erforations." The ICC/ANSI Al17.1-1998 which regulates accessibihty will accept openings which do not permit the passage of a 1 /2 in. sphere. It does not seem logical to be more restrictive than what is acceptable for accessibility. Metal grates are a common type of stair tread in occupancies other than those covered by the exception. Additionally, the proposed language will create confusion when dealing with stairs constructed using ~2 by" dimensional lumber. Is the small gap between adjacent boards acceptable under the wording "solid, with perforations"? COMMENT ON AFFIRMATIVE:

ELVOVE: The reason for my proposing the additional text was to

[~ rovide consistency within the Code. Section 5.2.6.3 (Exit assageway) ~Floor" currently states: "The floor shall be solid and

without perforations." Therefore, these requirements should be the same for (Stair/Stair Details) "Treads and Landing Surfaces." If adding "without perorat ions" is either redundant or too restrictive for treads and landing surfaces, it must also be redundant and too restrictive for floors. If this is the case, then I have no problem changing my vote to negative but with the provision that deleting the "without perforations" (i.e., returning the language to what was originally proposed) is done in conjunction with deleting the complete text for 5-2.6.3 to avoid the conflict.

C (Log #CC53)

ommittee: SAF-MEA 101- 205 - (5-2.2.4.5(c)): Accept SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-175 RECOMMENDATION: Split current 5-2.2.4.5(c) as follows:

(c) Handrails shall have a circular cross section with an outside diameter of at least 1-1/4 in. 43.2 cm) and not more than 2 in. (5 cm).

Exception to (c): [current Exception No. 1 to (cl (d) New handrails shall be conunuously graspable along the

entire length. Exception to (d): [current Exception No. 2 to (c] Reletter existing subparts (d) and 4e) to become (e) and (f).

SUBSTANTIATION: The changes are editorial for ease in use. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #342) Committee: SAF-M EA

101- 206 - (5-2.2.4.5(c) Exception No. 2): Accept in Part SUBMITTER: Belk Null, Nat'l Miscellaneous & Ornamental Metals Assn. COMMENT ON PROPOSAL NO: 101-175 RECOMMENDATION: Revise 5-2.2.4.4(c) Exception No. 2 subparts (1) through (3) to read as follows:

(1) mzd ;;~ich ~agT. do not project horizontally beyond the sides of the handrail within ~-1.5 inches (L~ ~.75 cm) of the bottom of the handrail and

(2) ~a4c-4v they have ~ ; ; " _ ~ ! / " n . (0.~ c:'.. ::-.-:--..-n.ur::..

and ($) No change.

SUBSTANTIATION: Revise the clearance between handrail and handrail bracket to 1 1 /2 in. rather than 2 1 /2 in. 1 1 /2 in. has been in widespread use for the past 20 years satisfactorily. COMMITTEEAL'TION: Accept in Part.

Revise 5-2.2,4.4(c) Exception No. 2 subpart (1) only as follows: "41) ----':~ ;~..:.:u ~ do not project horizontally beyond the sides

of the handrail with t-1.5 i n c h ~ ( ~ $.75 cm) of the bottom of the handrail and ~

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COMMITTEE STATEMENT: Subpart 1 has been revised as requested. For subpart 2, the words ~no sharp edges" are too subjective for enforcement. NUMBER OF COMMITTF~ MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON CObiNIITI'EE ACTION:


EXPLANATION OF NEGATIVE: PAUL& I am voting negatively on both Comment 101-206 (Log

#$42) and 101-207 (Log #254) (on which the committee action was similar) because there was much good technical justification for the original proposal to increase to 2-1/2 in. (within reductions

~ ermitted depending on handrail size) the 1-1/2 in. clearance elow the bottom of the handrail and beyond the side of the

handrail. The submitters of comments on this proposal both confused this vertical clearance with the horizontal clearance between the handrail and wall to the side which has traditionally been 1-1/2 in. but which research also suggests should be increased to approximately 2-1/4 in. (This matter of horizontal clearance is discussed by Templer in The Staircase, MIT Press, 1992, p. 129 referring to the work of Chaffin et al., 1978. The whole matter of handrail brackets and other fixing details is discussed by Maki in ~Influence of Handrail Shape, Size and Surface Texture on the Ability of Young and Elderly Users to Generate Stabilizing Forces and Moments," 1985). The matter of a 2-1/2 in. verucal clearance is also dealt with in ICC/ANSI Al17.1-1998 (as well as being recommended in the ADAAG Review Committee Report) in clarifying that its requirement that handrail gripping surfaces shall be without interruption by construction elements or obstructions and that "horizontal projections beyond the sides of the handrail occur 2-1/2 in. (64 ram) minimum below the bottom of the handrail." Neither the prior NFPA 101 requirement for a 1-in. clearance nor the 1-1/2 in. suggested in the two partially accepted comments (Logs #342 and #254) prevent the obstructions referred to in ICC/ANSI Al17.1-1998 Secuon 505.6 or in NFPA 101 Section 5-2.2.4.5(c). When one is sliding one's hand down the handrail, as is common in descent, the obstructions are most pronounced when one is also using the handrail for vertical support as is more common with older persons and others experiencing difficulty with stair use. Biomechanically this is best accomplished by keeping one palm in line with the forearm; that is, the wrist is not bent or flexed. This means that the fingers hang down below the side of the handrail adjacent to the wall or other fixing surface and will hit the brackets unless they comply with the 2-1/2 in. rule as set out in Proposal 101-175. Otherwise the sliding fingers hit the wall or the connection of the bracket or picket below the rail. The submitters of comments accepted in part by the committee did not address these biomechanical considerations; their concerns were the extent of their industry's redesign needed for traditional handrail brackets, most of which clearly fail to meet the old 1-in. rule or even the 1- 1/2 in. rule brought in by the comments. The submitter of Log #$42 gives only this limited argument about having built inadequate brackets for a long time "satisfactorily." As well as misrepresenting the detail possible in national injury statistics, the submitter of Log #254 presented many other flawed arguments both in the written submission and in his remarks at the committee meeting (in relation both to the clearance issue and the 1/8 in. criterion for edges). Especially questionable are the justification comments that =humans develop a sense and inclination to avoid injury" in essence by avoiding using the handrail in a boimechanically preferred way-with the wrist unbent and the fingers hanging behind the handrail to facilitate sliding while getting some vertical support from the handrail. The comment submitter plays down the importance of functional handrails for the reported 40 percent who use them. He ignores the fact that the 40 percent figure applies to relatively able-bodied adults, in public settings and not of advanced age. Handrail use by older persons, especially in homes (where stairs are typically far more challenging and dangerous than in public settings) is not the same. His argument that ICC/ANSI Al17.1 and ADAAG will revert to the poorer standard for handrail obstructions thus is badly flawed; the populations most served by ICC/ANSI Al17.1 and ADAAG are exactly the ones whose needs are downplayed by the commenter. Thus, for reasons of ample justification for the 2-1/2 in. requirement and because of flawed,

~ estionable reasoning for the comment, I must vote negatively on e committee's action to a accept in part these two comments.

WOODWARD: This revision eliminates the reduction in the original proposal that was available when a larger handrail section is used. Additionally, the ~quirements will no longer coordinate with those of the ANSI Al17.1-1998 for handrails. If the 1.5 in.

dimension from this revision is accepted, it probably is appropriate to eliminate the reduction for larger handrail sections.


101- 207 - (5-2.2.4.5(c) Exception No. 2 (1) and (2)): Accept in Part SUBMITI'ER: Daniel M. McGee, Julius Blum & Co., Inc. COMMENT O N PROPOSAL NO: 101-175 RECOMMENDATION: Revise Section 5-2.2.4.4(c) Exception No. 2 (1) and (2) to read as follows:

"(1) ^,,a~ -xh'¢h ~ do not project horizontally beyond the sides of the handrail within ~--~5-1.5 inches (Lxg-ro~.75 cm) of the b o t t o m o f t he h a n d r a i l r . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . . . . .

. . . . . . . . . . . . . . . I t " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . x . . . . . . i

. . . . . . . . '-'" I /~ : - " (0.3 :.'..) and (2) ~': . . . . . . . . 1 . . . . . They have no sharp edges ~'A'~ ! /S :::. (9.3

(3) No change." SUBSTANTIATION: Revise the clearance between handrail and handrail bracket to 1 1/2 in. rather than 2 1/2 in. 1 1/2 in. has been in widespread use for the past 20 years satisfactorily.

Introduction. The intent of this comment is to establish the required clearance between the bottom of a handrail and the handrail support bracket at 1 1/2 in. rather than the 2 1/2 in. presently proposed and to delete the requirement that they have edges with a minimum 1/2 in. radius, as proposed in the 1999 Report on Proposals.

Section 5-2.2.4.5(c) Exception No. 2 Subsection (1). Background. NFPA 101, Life Safety Code has contained the

requirement that handrail brackets or balusters that do not project horizontally beyond the side of the handrail within I in. vertically of the bottom of the handrail, would not be considered obstructions.

The above I in. clearance requirement was reasonable and appropriate. The GABO/ANSI Al17.1-92 Agt;essible and Usable Buildings and Facilities which is referenced in the NFPA 101 contains no specified clearance to handrail brackets.

The specific requirement for clearance from the underside of the handrail is shown pictorially in the United States Access Board Accessibilitv Guidelines for Btlildings and FaCilities. Sentember 1994 as 1 1/2 in. This requirement is clearly a reasonal~le extension of the almost universal traditional clearance, from handrail to wall, of 1-1/2 in.

Substantiation of the 2 1/9 in. Clearance. The handrail clearance in NFPA 101 was changed from 1 in. to 2 1/2 in. on the basis of information that 2 1/2 in. was required to allow for the extended finger length when sliding ones hand down a handrail, as shown below:

1" Preterit requirement (101.97)

2W Propote¢ r~luir~t~ (ROO)

1½" Reque=to¢ requiret~¢tlt"

133

N F P A 101 - - F 9 9 R O C

First, one must truly ask, do persons actually place their hands on a handrail in such an extended manner? Do you use such an extended finger position on a handrail when you slide your hand down a handrail?

I maintain just the opposite is true. Humans develop a sense and inclination to avoid injury, even the slightest injury if possible. This instills in people a tendency to maintain a semi-defensive position - knees slightly bent, elbows slightly bent and fingers slightly curled. Such positions enable one to be more flexible and able to recoil from minor obstructions that may cause injury. As a result few if any persons would grasp a handrailwith an extended finger grip.

Secondly, we must recognize the considerable variation in the range of users of handrails from children to adul~ and hence the range in finger length. The percentage of people with large hands that would grasp a handrail in the pictured manner is believed to be minuscule and hence in no way would justify a 150 percent (from 1 in. to 2 1/2 in.) increase m the clearance to the handrail bracket. We should also recognize that about 60percent of stair users do not use the handrail at all (Templet, 1974).

The supporting reason for urging adoptmn of clearance to the handrail bracket of 2 1/2 in. in lieu of the 1 in. requirement contained in NFPA 101, is that such a requirement is contained in he recently published CABO/ANSI A117.1-98.

The A117.1 standard is written under the ANSI Consensus procedures for an approved committee. The committee process works fine for the development of single focus standards for tests or equipment such as fire hose and fire detectors but is not suitable for multi-faceted codes. Although the All7.1 committee has almost fifty members most have a narrow focus and unfortunately no organization related to handrail manufacturers, fabricators or installers is on the committee.

Granted handrail interests should be involved in regulatory matters. However, unfortunately the handrail industry, if it can be called that, is made up of many small companies thereby representing a fragmented group not able to participate in all standards writing activities.

The handrail industry plans to petition the Al17.1 Committee to reevaluate their requirement for 2 1/2 in. of clearance to a handrail bracket.

Conflicts with Other Codes. Acceptance of the proposed 2-1/2 in. of required clearance from handrail to bracket will create conflicts with building codes that may be in affect in jurisdictions adopting NFPA 101.

At the present time, the 2 1/2 in. requirement would conflict with all three model building codes, the proposed International Residential Code, the American With Disabilities Act of 1994, ADAAG Accessibility Guide of 1994.

In the development of new code requirements, we should not lose sight of the intent and scope of the Code, which is summarized as follows:

"l-2.1...address life safety..." "l-2.2...minimize danger to life..." "l-2.3...identifies the ~ criteria for the design of egress

facilities" "l-2.7...The prevention of personal injuries incurred by an

individual's own negligence, and the preservation of property from loss by. fire have not been considered as the basis for any of the provmons of this Code.

Recognition of the fact that none of the model codes contained any minimum requirement for handrail bracket clearance prior to the adoption of the ADAct of 1992 clearly indicates that this issue was never a significant safety, health or welfare problem. Rather we maintain it was an outgrowth or extension of the required 1-1/2 in. of clearance to the wall. This is particularly evident or necessary where the handrail is recessed in a pocket and the continuous surface below the handrail is given the same clearance as provided to the wall.

Economic Imnact. The proponent stated the cost impact as, "Less than safety/usability benefit."

That was, we believe, a totally undocumented statement. Discussions with handrail manufacturers, fabricators and installers of the need for increased clearance elicited no recollection of serious injuries or lawsuits related to the depth of the handrail brackets.

Review of the U.S. Consumer Product Safety Commission National Injury Clearing House data on injuries reported by hosDital emergency rooms in the United States through the National Electronic Injury Surveillance System did not reveal any injuries specifically related to handrail support brackets.

(One might surmise that if the current criterion does not result in significant injuries, increasing the size of handrail brackets might result in future injuries.)

Since the personal injury data does not indicate a significant personal injury rate, it is reasonable to consider the finandal cost and impact of increasing the handrail bracket clearance. Preliminary studies indicate the increase in bracket clearance will result in a need to increase the strength of brackets about fifty (50) percent. It should be recognized that such an increase will result in the need to redesign current brackets, many of which the strength is determined by load testing as frequently accepted design parameters are not available'for the metals used. There are also ancillary costs in the revising of catalogues, reduction of current inventory and resupply of new inventory. These are not insignificant costs to relatively small handrail component manufacturers.

A~AAC.t2gI2.~Aa~ The Americans With Disabilities Act Accessibility Guidelines for Buildings and Facilities - - Part One established design criteria for handrails and grab bars as well as other necessary features for accessible buildings. The criterion established is mandated by the Americans with Disabilities Act (ADA) of 1990.

The ADAAG criteria led to the virtual uniformity of minimum handrail and handrail bracket design criteria in the United States. Such uniformity of criteria for handrails in itself promotes safety as frequently persons must reach for handrails in the dark or just as they initiate a fail.

The ADAGE handrail criterion is reproduced below.

ffmdr~

T~:~s j ~e I

¢¢J

~g. 35 ~ and 5podng of ~ m~d (~'eb lS~J

n a n d t d

Size and spacing of handrails and grab bars.

Recommendation. In consideration of the above discussion of the proposed change to Exception No. 2(1) of NFPA 101, it is recommended the minimum clearance from the bottom of a handrail to a handrail bracket or surface below be established at a minimum of 1-1/2 in. It is believed that clearance will adequately serve the cast majority of persons using handrails.

Section 5-2.2.4.5(c~ Excention No. 2 Subsection (2L The requirement that handrail-brackets or balusters, "have edges with 1/8 in. (0.3 cm) minimum radius," is unduly restrictive. The 1/8-in. minimum radius establishes an overly exacting criterion that n some decorative shapes may not be attainable.

Whether of wood or metal, handrail brackets are always manufactured with a smooth surface and rounded or champhed edges. It is not necessary to have a minimum 1/8-in. radius to prevent injury. What is important is that there be no sharp edges.

134

N F P A 101 - - F 9 9 R O C

The 1/8-in. requirement also mandates a difficult enforcement problem.

It should also be recognized that recent reductions in openings between balusters have increased the use of attractive screens and grilles, which are regulated as balusters. These are frequently made by casdng or with rectangular bars or tubes and these products have rounded edges but not necessarily of 1/8-in. radius.

Recommendation. In consideration of the above discussion, it is recommended the requirement that all edges have a 1 /8 in. radius be revised to specify they have no sharp edges.

Conclusion. The opportunity to submit this material to the Committee is greatly appreciated. It is hoped it will be helpful to the members in analyzmg all aspects of the handrail bracket clearance. COMMITTEE ACTION: Accept in Part.

See Committee Action on Comment 101-206 (Log #342). COMMITTEE STATEMENT: See Committee Statement on Comment 101-206 (Log #342). NUMBER OF COMMrIq?EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: PAUL& I am voting negatively on both Comment 101-206 (Log

#342) and 101-207 (Log #234) (on which the committee action was similar) because there was much good technical justification for the original proposal to increase to 2-1/2 in. (within reductions permitted depending on handrail size) the 1-1/2 in. clearance below the bottom of the handrail and beyond the side of the handrail. The submitters of comments on this proposal both confused this vertical clearance with the horizontal clearance between the handrail and wall to the side which has traditionally been 1-1/2 in. but which research also suggests should be increased to approximately 2-1/4 in. (This matter of horizontal clearance is discussed by Templer in The Staircase, MIT Press, 1992, p. 129 referring to the work of Chaffin et al., 1978. The whole matter of handrail brackets and other fixing details is discussed by Maki in "Influence of Handrail Shape, Size and Surface Texture on the Ability of Young and Elderly Users to Generate Stabilizing Forces and Moments," 1985). The matter of a 2-1/2 in. vertical clearance is also dealt with in ICC/ANSI Al17.1-1998 (as well as being recommended in the ADAAG Review Committee Report) in clarifying that its requirement that handrail gripping surfaces shall be without interruption by construction elements or obstructions and that "horizontal projections beyond the sides of the handrail occur 2-1/2 in. (64 ram) minimum below the bottom of the handrail." Neither the prior NFPA 101 requirement for a 1-in. clearance nor the 1-1/2 in. suggested in the two partially accepted comments (Logs #542 and #234) prevent the obstructions referred to in ICC/ANSI Al17.1-1998 Section 505.6 or in NFPA 101 Section 5-2.2.4.5(c). When one is sliding one's band down the handrail, as is common in descent, the obstructions are most pronounced when one is also using the handrail for vertical support as is more common with older persons and others experiencing difficulty with stair use. Biomechanically this is best accomplished by keeping one palm in line with the forearm; that is, the wrist is not bent or flexed. This means that the fingers hang down below the side of the handrail adjacent to the wall or other fixing surface and will hit the brackets unless they comply with the 2-1/2 in. rule as set out in Proposal 101-175. Otherwise the sliding fingers hi t the wall or the connection of the bracket or picket below the rail. The submitters of comments accepted in part by the committee did not address these biomechanical considerations; their concerns were the extent of their industry's redesign needed for traditional handrail brackets, most of which clearly fail to meet the old 1-inch rule or even the 1- 1 /2 in. rule brought in by the comments. The submitter of Log #342 gives only this limited argument about having built inadequate brackets for a long time ~satisfactorily." As well as misrepresenting the detail possible in national injury statistics, the submitter of Log #234 presented many other flawed arguments both in the written submission and in his remarks at the committee meeting (in relation both to the dearance issue and the 1 /8 in. criterion for edges). Especially questionable are the justification comments that "humans develop a sense and inclination to avoid injury" in

• essence by avoiding using the handrail in a boimechanlcally preferred way-with the wrist unbent and the fingers hanging behind the handrail to facilitate sliding while getting some vertical support from the handrail. The comment submitter plays down the importance of functional handrails for the reported 40 percent who use them. He ignores the fact that the 40 percent figure applies to relatively able-bodied adults, in public settangs and not of advanced

age. Handrail use by older persons, especially in homes (where stairs are typically far more challenging and dangerous than in public setfi/lgs) is not the same. Hts argument that ICG/ANSI Al17.1 and ADAAG will revert to the poorer standard for handrail obstructions thus is badly flawed; the populations most served by ICC/ANSI All7.1 and ADAAG are exactly the ones whose needs are downplayed by the commenter. Thus, for reasons of ample justification for the 2-1/2 in. requirement and because of flawed, questionable reasoning for the comment, I must vote negatively on the committee's action to a accept in part these two comments.

WOODWARD: This revision eliminates the reduction in the original proposal that was available when a larger handrail section is used. Additionally, the requirements will no longer coordinate with those of the ANSI Al17.1-1998 for handrails. If the 1.5 inch dimension from this revision is accepted, it probably is appropriate to eliminate the reduction for larger handrail sections.


101- 208 - (5-2.2.5.2 Exception No. 3 (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-177 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUN, which has primary responsibility for the development of the materials on performance-based design, review the changes proposed for Chapter 5 via Proposal 101-177 for compatibility with those being proposed as a new Oaapter 3 on performance-based design. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

] Reject Proposal 101-177. COMMITTEE STATEMENT: The action taken by the Means of Egress Committee in its proposed revision to Chapter 5 can be misunderstood. Thus, it has the potential to affect adversely the use of proposed Chapter 3 on performance-based design. As such, the material should not be added to Oaapter 5. NUMBER OF COMMII"rEE MEMBERS'ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 209 - (5-2.2.5.3 Exception No. 3): Accept SUBMITTER= Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-177

[ RECOMMENDATION: Reject Proposal 101-177. SUBSTANTIATION: The attempt to integrate performance-based language into Chapter 5 was premature. It might adversely affect the work done for the new performance-based chapter. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #'21) Committee: SAF-MEA

101- 210 - (5-2.3): Accept in Principle SUBMrlq'ER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-186 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Koffel's explanation of negative. It reads:

KOFFEL: The language proposed for deletion (5-2.3.6 through 5-2.3.13) was deleted from NFPA 101B became it was anticipated that another section of the building code which adopts NFPA 101B would address the requirements. However, unlike lqFPA 101B which anticipates another code adopting the document, NFPA 101 is often usedas a standalone code. Therefore, deleting the material in NFPA 101 is not appropriate. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-211 (Log #321). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITIT~ MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI"EE ACTION:

AFFIRMATIVE: 26 NOT RETURNED: 1 Paolucd

135

N F P A 101 u F 9 9 R O C


101- 211 - (5-2.3.6 through 5-2.3.13): Accept SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-186 RECOMMENDATION: Do not delete 5-2.3.6 through 5-2.3.13. SUBSTANTIATION: Based on the negative of Proposal 101-186 by Koffei. COMMITI'EE ACTION: Accept. NUMBER OF COMMrlq'EE MEMBERS ELIGIBLE TO VOTE- - 27 VOTE ON COMMITTEE ACTION:



101- 212 - (5-2.4.1 Exception No. 2): Accept in Principle SUBMITI'ER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-188 RECOMMENDATION: Delete the new Exception No. 2 related to the performance-based design option. SUBSTANTIATION: This comment is submitted for this section only because it is one of many new exceptions to prescriptive requirements that relate to the performance-based design option. It is my intent that NFPA evaluate this issue and remove all such references in the prescriptive chapters, not only in this one location.

Section 1-8.3 clearly requires the performance-based option to be based on Chapters 1, 2, 3, and 33 only. Exceptions that refer to this option in the prescriptive chapters are therefore moot and unnecessary. COMMITTEE ACTION: Accept in Principle.

See Comment 101-213 (Log #CC56). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 213 - (5-2.4.1 Exception No. 2): Accept SUBMITTER= Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-188

] RECOMMENDATION: Reject Proposal 101-188. SUBSTANTIATION: The attempt to integrate performance-based language into Oaapter 5 was premature. It might adversely affect the work done for the new performance-based chapter. COMMITI'EE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMIq['rEE ACTION:



101- 214 - (5-2.4.1 Exception No. 2 and A-5-2.4.1 Exception No. 2 (New)): Accept in Principle SUBMITFER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-188 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUN, which has primary responsibility for the development of the materials on performance-based design, review the changes proposed for Chapter 5 via Proposal 101-188 for compatibility with those being proposed as a flew Chapter 3 on'performance-based design. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Reject Proposal 101-188. COMMITTEE STATEMENT: The action taken by the Means of Egress Committee in its proposed revision to Chapter 5 can be misunderstood. Thus, it has the potential to affect adversely the use of proposed Chapter $ on performance-based design. AS such, the material should not be added to Chapter 5. NUMBER OF COMMITTEE MEMBEKS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 215 - (5-2.5.3.2(a)): Accept in Principle SUBMIT~R: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-191 RECOMMENDATION: Add an Exception for existing ramps. SUBSTANTIATION: There needs to be an Exception for existing ramps but the committee need to ¢onsider how to properly do this. COMMITTEE ACTION: Accept in Principle.

I eplace Exception to (a) to read: Exception to (a): Existing approved landings.

COMMITrEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO V O T E : 27 VOTE ON COMMITTEE ACTION:



101- 216 - (5-2.6.3): Reject SUBMITTER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-104 RECOMMENDATION: Delete: "and opening protective fire

~ rotection rating". UBSTANTIATION: This phrase is unnecessary and confusing.

The new section 5-2.6.2 already refers to the requirement for the enclosing walls of an exit passageway to meet 5-1.3.2 requirements. 5-1.3.2 clearly sets the requirements for opening protective by referencing 6-2. COMMrFI'EE ACTION: Reject. COMMITTEE STATEMENT." The wording is needed. For example, if an exit passageway is connected to a 1-hr. 3-story stair enclosure, but separted from it by a door, the retained language leads the user to the requirement that doors entering the exit passageway fi'om occupied spaces of the building need to be rated 1-hr., not 45 minutes or 20 minutes. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:



101- 217 - (Table 5-2.8.4(b)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-197 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA reconsider its action which seems to be nonresponsive. Given that Table 5- 2.8.4(a) has an entry similar to that requested for Table 5-2.8.4(b) by the submitter, the inconsistency makes for confusion. As an alternative, the row addressing handrail height in Table 5-2.8.4(a) could be deleted if the subject is adequately covered by 5-2.8.5.1, as explained in Proposal 101-198. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ In Table 5-2.8.4(a) delete the row tided Handrail Height." COMMITTEE STATEMENT: The Committee Action will correct the inconsistency between Tables 5-2.8.4(a) and 5-2.8.4(b). The Committee Action should meet the submitter's intent. NUMBER OF COMMFITEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:



101- 218 - (5-2.12.1(c) (New)): Accept in Principle S U B ~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-200 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Pauls' explanation of negative. It reads:

PAUL& Definitions are not supposed to contain requirements; therefore why require conformance with a definition? We do not do this with other defined terms in the Code. If there is some

136

N F P A 101 - - F 9 9 R O C

reason to conform with certain elements of the definition, those elements should be moved from the definition to a requirement. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Principle.

Reject Proposal 101-200. COMMITTEE STATEMENT: By rejecting the proposal, subpart (c) referencing the definition will not be added. The Committee Action should meet the submitter's intent. NUMBER OF COMMrlWEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 219 - (5-2.12.3.4 Exception No. 3): Accept SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-204

[ RECOMMENDATION: Reject Proposal 101-204. SUBSTANTIATION: The attempt to integrate performance-based language into Chapter 5 was premature. It might adversely affect the work done for the new performance-based chapter. COMMITTEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:



I01- 220 - (5-2.12.$.4 Exception No. $ and A-5-2.12.3.4 Exception No. $ (New)): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-204 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUN, which has primary responsibility for the development of the materials on performance-based design, review the changes proposed for Chapter 5 via Proposal 101-204 for compatibility with those being

g roposed as a new Chapter 3 on performance-based design. UBSTANTIATION: See the above recommendation.

COMMITTEE ACTION: Accept in Principle. [ Reject Proposal 101-204.

COMMITrEE STATEMENT: The action taken by the Means of Egress Committee in its proposed revision to Chapter 5 can be misunderstood. Thus, it has the potential to affect adversely the use of proposed Chapter 3 on performance-based design. As such, the material should not be added to Chapter 5. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 221 - (5-3.1): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be expanded so as to revise 22-3.1.4 and 23-$.1.4 to read:

Occupant Load. The occupant load, in number of persons for whom means of egress and other provisions are required, shall be determined on the basis of the occupant load factors of Table 5- 3.1.2 characteristic of the use of the space or as the maximum probable population of the space under consideration, whichever ts greater.

SAF-AAC makes these changes for correlation with similar wording revisions made by all other occupancy chapters. SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-206 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Koffel's comment on affirmative. It reads:

KOFFEI.z Further editorial revisions to the proposed Table 5- 3.1.2 should be made for information regarding covered mall buildings. _ Instead of the current text ~per factors above +++" the entry in the table should reference a paragraph and the new paragraph should include the necessary text. SUBSTANTIATION: See the above recommendation.

COMMITTEE ACTION: Accept in Principle. Replace "Per factors above +++" with "Per factors applicable to use

of space +++". COMMITFEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #26a) Committee: SAF-MER

101- 222 - (5-$.1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-206 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER evaluate the wording of the Exception that accompanies the triple-dagger note; and reword it to clarity intent. SUBSTANTIATION: See the above recommendation. COMMITI"EE ACTION: Accept in Principle.

Revise the +++ Exception to Table 5-3.1.2 to read as follows: +++ Exception*: The portions of the covered mall, where

considered a pedestrian way and not used as gross leasable area, shall not be assessed an occupant load based on Table 5-$.1.2. However, means of egress from a covered mall pedestrian way shall be provided for an occupant load determined by dividing the gross leasable area of the covered mall building (not including anchor stores) by the appropriate lowest whole number occupant load factor from Figure 5-$.1.2.

Each individual tenant space shall have means of egress to the outside or to the covered mall based on occupant loads figured by using the appropriate occupant load factor from Table 5-$.1.2.

Each individual anchor store shall have means of egress independent of the covered mall.

Revise the title of Figure 5-$.1.2 to read: Figure 5-$.1.2 Covered mall buildings occupant load factors. Also include the current appendix note to 24-1.7 (g) as an

endix note to the +++ exception. T r E E STATEMENT: The exception was revised to

provide greater clarification as to application. It was also noted that there is a revision made by SAF-MEA by Comment 101-221 (Log #26) which the committee supports. Also the appendix note to 24-1.7(g) was inadvertently not carried forward to this table when it was developed by the technical committee. This appendix note is required as it provides the necessary information on determining the occupant load for a covered mall. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:

AFF/RMATIVE: 17 NOT RETURNED: 2 Holmes, Moon


101- 223 - (Table 5-$.1.2): Accept in Principle SUBMI'Iq'ER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-208 RECOMMENDATION: The Techncal Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA review Proposal 101-208 for consistency with proposed Table 5-$.1.2 being created via Proposal 101-206. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

Retain the acceptance of Proposal 101-208 as developed by SAF-

C~I~VlITI'EE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITrER MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


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101- 224 - (Table 5-3.1.2): Accept in Principle SUBMITI'ER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-209 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA review Proposal 101-209 for consistency with proposed Table 5-3.1.2 being created via Proposal 101-206. SUBSTANTIATION: See the above recommendation. COMMrITEE ACTION: Accept in Principle.

I* Retain the acceptance of Proposal 101-209 as developed by SAF- I P / I ~ I % . .



I l ln mercantile occupancies with no street floor, as defined in Chapter 3, but with access direcdy from the street by stairs or escalators, the principal floor at the point of entrance to the mercantile occupancy shall be considered the street floor. COMMITTEE STATEMENT: The original proposal and Mr. Humble's comment intended to clarify the apphcation of the occupant load criteria for sales portions of the mercantile occupancies. The proposed revision accomplishes this intention without the added footnote that they proposed.

The addition of the footnote in this comment was added for clarification and to maintain the current provision found in 24-1.7 (a). The footnote denotes that there is a difference as how street floor is applied for mercantile occupancies as to the definition of street floor as found in 3-2. The definition of street floor has a three step limitation which was not to be applied for this particular aappwplication. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 225 - (Table 5-3.1.2): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-209 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER give consideration to Mr. Humble's and Mr. Perry's comments on affirmative. They read:

HUMBLE: Add a footnote to the proposed Table 5-3.1.2 for entry under Mercantile Use, "~L-eet fleer" "Two or more street floors due ~ " which reads:

"In mercantile occupancies where, due to differences in grade of streets on different sides, there are two or more floors directly accessible from streets (not includin[g alleys of similar back streets), for the purpose of determimng occupant load, each ~uch . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . the use shall be conmdered to be mercantile with two or more street floors. The occupant load factor shall be erie pervert f~.r each a.0 ~q ft (~.7 :q .~?.) ~f based upon the gross floor area of sales space."

A ~ a footnote to the Dronosed Table 5-3.1.2 for entry under Mercantile Use. "Street i'loor" which reads:

"The occuDant load factor shall be based UDOn the gross flQgr area of sales space. :

We, the Committee, have erred in our determination to maintain Exception "(a)" of Section 24-1.7(a) by incorporating the multiple grade level provisions with the single "street level" provision of proposed Table 5-3.1.2. The integration of the two creates a conflict whereby various interpretations can be made for the area per occupant.

By directly relating the intent of Section 24-1.7(a) Exception (a) to the next category, "Two or more street floors due to grade differences", and by modifying the proposal so as not to be redundant with the category tnle, will eliminate this conflict. In addition, since our original intent was to address the area measurement qualifications, namely the "sales area" only, the additional proposal has been included for consistency with the original language of Section 24-1.7(a) and the new proposal to "Two or more steel floors..." above.

I would also direct my fellow committee members attention to 101-738 (Log #GP902) which modified substantially the original language of Section 24-1.7 by simply referring it to the proposed Table 5-3.1.2 Occupant Load Factors.

PERRY: I agree with the comment of Mr. Humble. A footnote indicating that the occupant load factors apply only to the sales area needs to be added in both locations. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise the following sections on Table 5-3.1.2 and add a footnote:

Mercantile Use street floor 1

Sales area on two or more street floors1

Sales area on floors below street floor 1 Sales area on floors above street floor 1 1 " l . . . . g l . . . . . . . ~1 ,C . . . . l ^ ~

Sq Ft Sq M 30 2.8

40 3.7 30 2.8

60 5.6


101- 226 - (Table 5-3.1.2); Accept in Principle SUBM1TTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-210 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA review Proposal 101-210 for consistency with proposed Table 5-3.1.2 being created via Proposal 101-206. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Retain the acceptance of Proposal 101-210 as developed by SAF- IND. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 227 - (5-3.2 Exception, 5-3.2 Exception No. 2 (New), and A-5-3.2 Exception No. 2 (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-211 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Aikman's explanation of negative and Mr. Koffel's comment on affirmative. They read:

AIKMAN: A-5-3.2 is very difficult to understand. The text "Where larger items [greater than 24 in. (61 cm) in length] occur" does not seem to relate to the requirement or the exception. Does it mean that obstructions less than 24 inches in length can occur without restrictions? Is the 48 inch measured in the same direction as the 24 inch dimension or would it be measured across the means of egress as well?

KOFFEL: While the proposed text will work in most instances there are situations where the required width may be less than 36 inches. In those instances, the permission to have projections up to 4 inches on both sides could reduce the effective width to an unacceptable number. It is proposed that a restriction be added to Exception No. 2 to include a minimum required width of 28 inches, or some other number, and no projections within that minimum width. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Retain the action on Proposal 101-211, but delete Exception No. 2 [ to 5-3.2 and its associated appendix note.

COMMITTEE STATEMENT: The new exception would have caused more harm than good. The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


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101- 228- (5-$.$.1): Accept SUBMITTER= James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-215 RECOMMENDATION: Reject proposal 101-213. SUBSTANTIATION: See Koffel's negative ballot on Proposal 101- 213.

Although I strongly support sprinkler alternatives in the Code, this leaves very little in reserve should there be a sprinkler failure. In most cases there are no corridor requirements, travel distances are extended, flame spread is increased, the remoteness is reduced, more unprotected vertical openings are permitted, hazardous areas may not require fire rated separation, areas of refuge are deleted and now egress capacity is reduced. This is especially a concern in assembly and educational occupancies and some mercantile occupancies were egress capacity is often an issue. This may be viable if a restriction is added that this can not be used in conjunction with other sprinkler options. COMMITTEE ACTION: Accept. NUMBER OF COMMIlq'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ENDTHOFF: The reductions in egress width are justified in a

fully sprinklered building. These reductions have been allowed in the BNBC for many years and are included in the latest actions on the International Building Code. There was no technical justification presented for accepting the comments to remove the reductions previously approved. There is no fire history where these reductions have posed any additional safety problems.

FRABLE: In a much debated topic, the Technical Committee voted to accept the recommendation to delete the proposed changes that would have decreased the egress width factors for office buildings when protected by a supervised automatic sprinkler system utilizing quick response sprinklers. The proposed egress width factors that were deleted are consistent with those used by the BOCA National Building Code for the past 15 years in buildings protected by standard response sprinklers. The track record m the "real world" in lieu o f the discussed "scientific evaluations" regarding this issue has been excellent. I believe the technical committee lost a tremendous opportunity to minimize the differences between our codes within the USA and internationally without reducing the safety to building occupants.

Based on the above concern, the appropriate action on this comment should have been "Reject.

ROSENBAUM: It is always hard to argue that more isn't better; however, there are several reasons in addition to the original submitters substantiation why I am voting against the committee action to reject the reduction in egress required widths. The first reason to allow reduced exit widths in buildings is that the installation of sprinklers primarily reduces the number of people who are looking to exit at one time. Sprinklers have a demonstrated capability to reduce the smoke spread and fire hazard assodated with fires and therefore the perceived need to evacuate a structure. Therefore, if sprinklers operate, exits are required in order to evacuate those that are exposed to or perceive to be threatened. Based on the number who perceive a hazard being reduced by sprinkler operation, less egress width is required.

Second, the case that if sprinklers do not work, the exit capadty must be adequate is correct. However, utilizing the current capacities that are based on data from the early part of this century does not appear to be an appropriate approach for justifying status quo. The numbers providedin the current code are based on pre- 1930's data for egress studies. There appears to be no better data on the adequacy of either the proposed numbers in 101-213 or the current edition of the code. Both have been utilized, and neither has resulted in a known hazard or fire life loss. Both are also used throughout large portions of the United States. Theproposed acceptance of the reduction in egress widths by the ICC provides some support that because both numbers are currently being utilized without a strong basis, that an acceptable level of safety is provided by the reduced widths.

Third, the acceptance of the Life Safety Code to allow a reduction in required exit widths along with other fire safety features based on the installation of active systems has a precedent. This precedent occurs in the occupancy type that is most likely affected by the proposed change, assembly occupancies. The current allowable reduction in egress widths allows over three dmes the reduction proposed in 101-213 based on the provision of an active fire safety system. The Code has recognized smoke-protected

seating for many cycles. Smoke-protected seating criteria can be utilized in enclosed spaces such as arenas and convention centers. Egress widths are allowed to decrease significantly, (i.e., a factor of five), based on the capabilities of smoke control and /o r sprinkler systems which the committee must realize can fail to perform as anticipated. In addition, increases in travel distance and reductions to other fire safety features are also allowed in smoke- protected assembly areas. However, no proposed changes have been sbumitted to these criteria based on the justification cited by the submittera.

Reducing required egress widths results in benefits to the usability of a structure. One can always say that more stairs is better. However, the following supports the reduction in required egress widths: 1) there is not a current research based support for either the current or the proposed numbers for calculating egress widths, 2) there is no significant loss data resulting from either approach, $) the International Construction Code isproposing to adopt the reduced required egress widths, and 4) reductions in required egress widths based on active systems that may fail has a precedent in the Code.

(Log #$$5) Committee: SAF-MEA

101- 229 - (5-$.3.1): Accept SUBMITTER: Wayne G. (Chip) Carson, Carson Assoc. Inc.' COMMENT ON PROPOSAL NO: 101-213 RECOMMENDATION: Reject proposed code change. SUBSTANTIATION: The proposed change in exit capacity is a reduction of 1/$ for stairs and 1/4 for doors. There is no technical documentation provided as to why the recommendation to reduce capacities for level travel is different than that reduction for vertical travel, nor is there documentation on the actual use of stairs in emergency situations using these lower capacity factors. Reference to a provision in another code is not technical documentation. The statement that "The resulting experience has been excellent" is not documented by any reference to studies or scientific evaluations.

The reference to the excellent experience of sprinklers is not ~uestioned. Frankly, if the sprinklers work as intended there is httle need for exits. But, if the sprinklers do not work as intended we need the exits to be able to accommodate all occupants in a timely manner. Exits of adequate capacity are needed as the last protection for the occupant in the event that the safety features placed in the building do not work as intended. Lowering the exit capacity is not considered prudent nor justifiable based on the installation of sprinklers when the only time that the building occupants will absolutely need the exit capacity is if the sprinklers fall to operate as intended. COMMITTEE ACTION: Accept. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ENDTHOFF: The reductions in egress width are justified in a

fully sprinklered building. These reductions have been allowed in the BNBC for many }t.ears and are included in the latest actions on the International Building Code. There was no technical justification presented for accepting the comments to remove the reductions previously approved. There is no fire history where these reductions have posed any additional safety problems.

FRABLE: In a much debated topic, the Technical Committee voted to accept the recommendation to delete the proposed changes that would have decreased the egress width factors for office buildings when protected by a supervised automatic sprinkler system utilizing quick response sprinklers. The proposed egress width factors that were deleted are consistent with those used by the BOCA Nadonal Building Code for the past 15 years in buildin~gs protected by standard response sprinklers. The track record m the "real world" in lieu o f the discussed "sdentific evaluations" regarding this issue has been excellent. I believe the technical committee lost a tremendous opportunity to minimize the differences between our codes within the USA and internationally without reducing the safety to building occupants.

Based on the above concern, the appropriate action on this comment should have been "Reject."

ROSENBAUM: It is always hard to argue that more isn't better; however, there are several reasons in addition to the original submitters substantiation why I am voting against the committee action to reject the reduction in egress required widths. The first

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N F P A 101 - - F 9 9 R O C

reason to allow reduced exit widths in buildings is that the installation of sprinklers primarily reduces the number of people who are looking to exit at one time. Sprinklers have a demonstrated capability to reduce the smoke spread and fire hazard associated with fires and therefore the perceived need to evacuate a structure. Therefore, if sprinklers operate, exits are required in order to evacuate those that are exposed to or perceive to be threatened. Based on the number who perceive a hazard being reduced by sprinkler operation, less egress width is required.

Second, the case that if sprinklers do not work, the exit capacity must be adequate is correct. However, utilizing the current capacities that are based on data from the early part of this century does not appear to be an appropriate approach for justifying status quo. The numbers provided in the current code are based on pre- 1930's data for egress studies. There appears to be no better data on the adequacy of either the proposed numbers in 101-213 or the current edition of the code. Both have been utilized, and neither has resulted in a known hazard or fire life loss. Both are also used throughout large portions of the United States. The proposed acceptance of the reduction in egress widths by the ICC provides some support that because both numbers are currently being udlized wtthout a strong basis, that an acceptable level of safety is provided by the reduced widths.

Third, the acceptance of the Life Safety Code to allow a reduction in required exit widths along with other fire safety features based on the installation of active systems has a precedent. This precedent occurs i/a the occupancy type that is most likely affected by the proposed change, assembly occupancies. The current allowable reduction in egress widths allows over three times the reduction proposed in 101-213 based on the provision of an active fire safety system. The Code has recognized smoke-protected seating for many cycles. Smoke-protected seating criteria can be utilized in enclosed spaces such as arenas and convention centers. Egress widths are allowed to decrease significandy, (i.e., a factor of five), based on the capabilities of smoke control a n d / o r sprinkler systems which the committee must realize can fail to perform as anticipated. In addition, increases in travel distance and reductions to other fire safety features are also allowed in smoke- protected assembly areas. However, no proposed changes have been sbumitted to these criteria based on the justification cited by the submitters.

Reducing required egress widths results in benefits to the usability of a structure. One can always say that more stairs is better. However, the following supports the reduction in required egress widths: 1) there is not a current research based support for either the current or the proposed numbers for calculating egress widths, 2) there is no significant loss data resulting flom either approach, 3) the International Construction Code isproposing to adopt the reduced required egress widths, and 4) reductions in required egress widths based on active systems that may fail has a precedent in the Code.


101- 230 - (5-3.3.1): Accept SUBMITEER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-215

] RECOMMENDATION: Reject Proposal 101-215. SUBSTANTIATION: The attempt to integrate performance-based language into Chapter 5 was premature. It might adversely affect the work done for the new performance-based chapter. COMMITIFEE ACTION: Accept. NUMBER OF COMMrlq'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 26 NOT RETURNED: 1 Paolueci


101- 231 - (Table 5-3.3.1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-213 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA reconsider its action so as to clarify that the current column headings [i.e., "in. per person (cm per person) ' ] be retained and appear for all four columns of the table. The table shown in the ROP is missing these labels. SUBSTANTIATION: See the above recommendation.

COMMITTEE ACTION: Accept in Principle. No change needed.

COMMITTEE STATEMENT: The 2 right-hand columns of the table are being deleted by the Committee Action on Comments 101-228 (Log #323) and 101-229 (Log #335). The Committee Action should meet the submitter's intent. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #32) Committee: SAF-HEA

101- 232 - (Table 5-3.3.1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-214 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-HEA address the subject, as needed, during ROG-preparation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Retain the rejection of Proposal 101-214. COMMITTEE STATEMENT: Based on an action taken by the SAF-MEA Committee, Table 5-3.3.1 will not be revised to allow reductions in the capacity factors for sprinklered buildings. Thus, no change is n e e d e d a t this time. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITIT.J~ ACTION:


(Log #32a) Committee: SAF-MEA

101- 235 - (Table 5-3.3.1): Accept in Principle SUBMITYER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-214 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA, which has main responsibility for Chapter 5 provisions, consider the merits of the ~roAposed change given that the proposal was acted on by SAF-

SUBSTANTIATION: See the above recommendation. COMMIT'fEE ACTION: Accept in Principle.

[ Retain the rejection of Proposal 101-214 as made by SAF-AAC. COMMITTEE STATEMENT: The above action is consistent with that on Comments 101-228 (Log #325) and 101-229 (Log #$$5). NUMBER OF COMMIT]FEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 234 - (5-3.3.1 Exception (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-215 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUN, which has primary responsibility for the development of the materials on performance-based design, review the changes proposed for Chapter 5 via Proposal 101-215 for compatibility with those being proposed as a new Chapter 3 on performance-based design. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

] Reject Committee Proposal 101-215. COMMITTEE STATEMENT: The action taken by the Means of Egress Committee in its proposed revision to Chapter 5 can be misunderstood. Thus, it has the potential to affect adversely the use of proposed Chapter 3 on performance-based design. As such, the material should not be added to Chapter 5. NUMBER OF COMMn~I'EE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITYEE ACTION:

AFFIRMATIVE: 12

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101- 235 - (5-3.3.1 Exception (New)): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fii'e Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-213 RECOMMENDATION: Add a new Exception to 5-3.3.1 as follows:

Exception: Buildings sprinklered in accordance with NFPA 13R and supervised in accordance with Section %7 shall be permitted to use the reductions in egress capacity for sprinklered buildings when sprinklers are provided in the means of egress using the reduction. SUBSTANTIATION: In our original submission, we limited the reduction to NFPA 13 systems because there are some elements of a means of egress that are not required to be sprinldered under NFPA 13R. It has been point out to that the reduction in egress capacity would be appropriate with an NFPA ISR system when that means of egress is sprinklered.

The concept of providing a reduction in egress capacity for buildings sprinklered in accordance with NFPA I$R has been accepted by the International Building Code at its most recent hearings. COMMITTEE ACTION: Reject. COMMrlq'EE STATEMENT: The recommended text is not applicable based on the Committee Action on Comments 101-228 (Log #323) and 101-229 (Log #335). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMIq[q'EE ACTION:


EXPLANATION OF NEGATIVE: ENDTHOFF: This egress width reduction isjnstified where

NFPA 13R systems are installed and the area is sprinklered. This reduction would only apply to residential multi-family and would be an incentive to install sprinklers, especially in existing buildings. The comment should be approved a n d the reductions permitted.

VOTE ON COMMITrEE ACTION: AFFIRMATIVE: 26 NOT RETURNED: 1 Paolucci


101- 238 - (5-5.4.1): Reject SUBMITTER= Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-224 RECOMMENDATION: Change "accessible route" to "accessible means of egress". SUBSTANTIATION: The term "accessible route" is not defined. "Accessible means of egress" is defined. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The term "accessible route" has special meaning within the ADA. The submitter's recommended language will confuse the issue. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:


COMMENT ON AFFIRMATIVE: ELVOVE: The Committee made the right decision to reject the

proposal. Using the term ~accessible means of egress ~ as the ~roponent suggested would confuse the issue. However, if accessible route" is the appropriate term, it should be defined as

many code users may not be aware of it. Since there is a definition for accessible route" available from CABO/ANSI All7.1, it should be added to the definitions section of NFPA 101, Chapter 3 a n d / o r 5 as an editorial change to this edition of the Code. (Note: the Committee in its substantiation to reject this comment indicated "accessible route" has a special meaning within the ADA. However, in NFPA I01, all references to the definition of "accessible route" refer to CABO/ANSI Al l7 ) .


101- 236 - (5-5.1.5): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-222 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Koffel's explanation of negative. I reads:

KOFFEL: The language for deletion (mandating noncombustible construction) was deleted from NFPA 101B because it was anticipated that another section of the bui ld ingcode which adopts NFPA 101B would address the requirements. However, unlike NFPA 101B which anticipates another code adopting the document, NFPA 101 is often used as a standalone code. Therefore, deleting the material in NFPA 101 is not appropriate. The requirement for noncombustible construction was specifically included in the existing text to discriminmate between certain construction materials where scissor stairs are used. The requirement for the separation to be noncombustible is consistent with the BCMC Means of Egress Report. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-257 (Log #$24). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 257 - (5-5.1.5): Accept SUBMITI'EP,: James IC Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-222

[ RECOMMENDATION: Reject the proposal. SUBSTANTIATION: This is a far cry from clarification. See A-5-5.1.5. Also see Koffel's negative ballot on Proposal 101-222. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27


101- 239 - (5-7.2 Exception No. 2): Accept SUBMITTER: Thomas W. Jaeger /Thomas W. Gardner, American Health Care Assn. (AHCA) COMMENT ON PROPOSAL NO: 101-226 RECOMMENDATION: Change the proposed new Exception No. 2 to read:

Exception No. 2: In existing buildings, the 50 percent limit on egress capacity shall not apply if the 50 percent bruit on the required number of exits is met. SUBSTANTIATION: Better language per Mr. Aikman's comment. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:


(LOg #35) Committee: SAF-MEA

101- 240 - (5-7.2 Exception No. 2 (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-226 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MFA give consideration to Mr. Aikman's comment on affirmative. It reads:

AIKMAN: To state that the proposed text is in plain English is doubtful. The word "limitation" should be "limit" in the context of use. In an exception, the phrase "shall not be acceptable" would be better written as "does not apply". SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Cqmmittee Action on Comment 101-239 (Log #354). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMIIq'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:


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101- 241 - (Section 5-10): Accept in Principle SUBMrVrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-238 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA give consideration to Mr. Koffel's comment on affirmative and to the last paragraph of Mr. Helton's explanation of negative. They read:

KOFFEL: Many of the changes in the proposal rely on UL924 to adequately address the technical issues. For example, the permission to use photoluminescent signs is basedupon anticipated changes to UL924. Until such time as the changes are made, the provisions of the proposed Section 5-10 may not be adequate. Similarly, many of the provisions for externally illuminated signs do not apply to internally illuminated signs, again relying on UL924 to l~roperly address the issue. A final version of UL924 must be submitted to the technical committee to insure that all technical aspects are properly addressed.

HELTON: There is no photoluminescent product on the market today that is UL listed under UL 924. Also, there are other issues with photoluminescent exit signs - UV degradation, effects of humidity, temperature changes, durability, adhesion, etc~ More research is needed to develop answers to all of these questions, We are being asked to vote on putting a light source in the Life Safety Code that cannot meet the required visibility requirements. Before a product is allowed by the Code, there must be substantial proof that the product will meet all of the necessary requirements. For these reasons, we are voting negative. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

No further action needed. COMMITTEE STATEMENT: The subject of photoluminescent materials has been decided on its merits. See committee statement associated with rejection of Comment 101-242 (Log#276). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 23 NEGATIVE: 2 ABSTENTION: 1 NOT RETURNED: 1 Paolucci

EXPLANATION OF NEGATIVE: HELTON: See my Explanation of Negative on Comment 101-242

(Log #276). WOODWARD: I feel that the committee has acted prematurely

by permitting these signs when they comply with UL 924. While i agree that the acceptance of all signs should be based upon the use of a standard in order to create equal requirements, standards must be used properly.

As pointed out during the committee discussion, the standard does not currently address these types of signs. Therefore, we are making it appear that there are signs currently available which can comply with this standard, ff the standard does not address these signs, there can be no signs available which truly comply with the standard.

Information was presented which claimed that there was a sign which did comply with the standard. However, since this standard does not address these types of signs, this "approval" is nothing more than aa engineering judgment based upon what that one lab felt were the applicable sections of the standard. These types of judgments create a false impression and misapplication. EXPLANATION OF ABSTENTION:

BRYAN: I have abstained on this issue due to professional associations that could be perceived to create a conflict of interest.


101- 2 4 2 - (Section 5-10): Reject TCC NOTE: The Technical Correlating Commit tee on Safety to Life (SAF-AAC) notes that the first sentence o f the Commit tee Statement was not accurate as o f the date that SAF-MEA held its ROP-preparat ion meeting. SAF-MEA did not base its decis ion to retain the R O P action on photo luminescent signs on the existence o f a l isted photo luminescent sign. SUBMITrER: William E. Lynch Jr., Isolite COMMENT ON PROPOSAL NO: 101-238 RECOMMENDATION: New Section 5-10.7.2 and A-5-10.7.2 should be removed. These sections would not only cause substandard signs to be used, but would also place a considerable burden on the local authorities to insure that the charging illumination was adequate.

Photoluminescent material should not be mentioned in any of the proposed changes to the definitions in A-5-10.8. This includes the proposed 5-1.2 and A-5-1.2.

The affirmative comment of Mr. Koffel relies upon proposed changes to the UL 924 standard for the inclusion of photoluminescent signs. There are no proposed changes to this standard.

Further, accordin~ to the data submitted with this proposal, photoluminescent signs do not even come close to meeting the acceptable luminance requirements of UL 924. Mr. Helton explains this is in his explanation of negative vote. UL's Observation Visibility Test and Minimum Luminance Test require that approved signs have a minimum luminance of 206 milUcandelas (0.06 footlamberts) at the end of 90 rain in a dark environment. The photoluminescent data submitted is shown below:

Time Acceotable Period Level EverGlow HI.

10 minutes 206mcd 150 mcd 240 mcd 60 minutes 206mcd 22.5 mcd 40 mcd 90 minutes 206mcd ? ?

No readings were included at 90 rain. However, based on the significant luminance degradation at 60 min, it is clear that the signs would be almost impossible to see at the end of 90 rain.

Photoluminescent material cannot meet the minimum requirements of the UL 924 standard and therefore should not be accepted in the revised NFPA 101, Life Safety Code. SUBSTANTIATION: We appreciate this opportunity to comment on the Proposals for changes to NFPA 101, Life Safety Code. For your information, we are manufacturers of Self-Luminous EXIT signs. These are tritium powered exit signs and are not to be confused with photoluminescent path markers. Unlike photoluminescent path markers, our signs require no external light source for activation and will work as well in a totally dark environment as in a normally lit office building. Our signs meet the new revised UL 924, Standard for SafetyEmergency Lighting and Power Equipment and are listed by UL. Now that you know who we are, we will proceed with our comments.

It is inappropriate to recognize photoluminescent material as an acceptable light source for exit signs at this time. Although significant improvements have been made in photoluminescent technology, even the new metal oxide materials are unable to meet the requirements of UL 924, Standard for Safety Emergency Lighting and Power Equipment. Until such time as a product passes this standard, the inclusion of photoluminescent material as exist signs in NFPA 101, Life Safety Code, will cause these signs to be used incorrectly and thereby potentially put lives at risk.

As evidence of this potential risk, one needs to read the substantiation for the recommended change (Proposal 101-248) to 5-10.3.~ Exception No. 2 submitted by Mr. Manny Muniz of DDC Corporation:

"Photoluminescent exit signs are currently being used throughout the United States. They meet all the requirements of the Code in terms of size and illumination and have evenly illuminated letters with a minimum luminance of 0.06 footlamberts (0 .21 cd/sq m). They are also listed in accordance with UL 924, Standard for Safety Emergency Lighting and Power Equipment, and UL 1994, Standard for Low LevelPath and Lighting Systems."

This is untrue. We have checked with both Underwriters Laboratories and Interteck Testing Services (ETL), who confirm that no photoluminescent sign is listed in accordance with the UL 924 standard. In fact, as far as Underwriters Laboratories is concerned, there is no such thing as a photoluminescent exit sign. There are only photoluminescent path markers. UL has been very deliberate in their attempt to make sure that path markers, approved for use under the UL 1994 standard, are not confused with exit fixtures. For reference we include the following excerpts from UL 1994:

"1.5 These requirements do not cover exit fixtures, exit lights, and self-luminous exit signs (including those intended for floor- proximity installation) intended for use in accordance with NFPA 101, Life Safety Code, or emergency lighting fmtures. Such equipment is investigated under the requirements in UL 924, Standard for Emergency Lighting and Power Equipment.

2.8 PATH MARKER - - A photo-luminescent, self luminous, or externally powered marker mounted at a low level that includes the words "EXIT", ~TO EXIT", "STAIR", "TO STAIRS", "FIRE ESCAPE", "TO FIRE ESCAPE", or the like, and may also include a directional indicator. A path marker is intended only for use with

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and as part of a low level path marking and lighting system. See 1.5 for other limitations.

6.1.8 Installation and operating instructions provided with each externally powered system shall indude:

e) For a path marker, the words: "This path marker is intended for use with and as part of a low level path marking system and is not intended to be used as an exit sign in accordance with NFPA 101, Sections 5-10, or codes that specify listing in accordance with UL 924".

Despite the above, as Mr. Muniz states, photoluminescent path markers are currently being used throughout the United States. This would not be a problem if they were only being used as they were intended. That is, as part of a low level path marking system in accordance with their listing to the UL 1994 standard. However, through clever and misleading advertising and representations, at least one photoluminescent manufacturer has been successful in substituting photoluminescent path markers in applications that require signs to meet the UL 924 standard.

We attach the following exhibits as examples: Exhibit 1: Active Safety's Product Literature for Self-Illuminating

Exit Markings. Nowhere in this literature is it explained that these signs are only approved for use as part of a low level path marking system. The drawings as well as the mounting options certainly imply that they can be used anywhere. Why would you need a ceiling or flag mount for a low level path marking application? The name Self-Illuminating is inaccurate - they must have an external light source to be activated - and confusing. We believe that this name is meant to be confused with Self-Luminous Signs - which do meet the UL 924 standard.

Exhibit 2: Letter from California State Fire Marshal Division Chief, Joe Garcia to Frank Dobronte of Active Safety. This is a response to a request to use Self-Illuminating exit signs in high level applications. The signs have been represented as approved for low level. This is untrue and intentionally misleading. In this instance, the Fire Marshal approved the use of photoluminescent path markers for above door applications in the Napa State Hospital.

Exhibit 3: Application for Variance or Waiver with San Jose Fire Department. Again, Active Safety has been suffidently unclear in their application to cause it to be granted. They requested "UL listed exit sign for low level to be used for high level exit" stating that the "product functions as required for low level use. Requirements for low level exit signs are the same as high level." This is extremely deceptive. While it is true that the requirements for low level exit signs are the same as high level, this does not apply to photoluminescent path markers. This only applies to signs that are axe listed toathe UL 924 standard.

Exhibit 4: Letter to Acuve Safety from Thomas Tralnor, Chief Electrical Inspector for the City of San Diego. Here, Active Safety ran into someone who understood the difference between UL 1994 and UL 924. The letter's final paragraph points to the misleading marketing materials for the photoluminescent path markers as follows:

"I note, in passing, that some of your literature on this product indicates that the exit signs may be used over a door or be hung from a ceiling. This is inaccurate and misleading. In order to reduce the possible confusion this could cause, I am forwarding copies of this letter to distributors in the San Diego area."

Exhibit 5: Special announcement from Active Safety to All representatives and distributors. "Now you can sell Active Safety's exit signage not only for low level but also for high level!!l" Again, false information.

Many more examples are available, but we think, unnecessary. There have been repeated attempts to include photoluminescent material as an acceptable light source for exit signage. These efforts include the Califorma Building Code, the International Code Council Hearings in April 1998, and The Underwriters Laboratory's Industry Advisory Conference in September 1998. All these efforts have failed for one simple reason. To date, no photoluminescent material has successfully passed the agreed standard for Safety Emergency Lighting, UL 924. Despite this fact, photoluminescent path markers are marketed and sold for above door applications. This is in direct conflict with the intent of NFPA 101, Life Safety Code and UL 924.

We respectfully request that the Committee reject the inclusion of any positive reference to photoluminescent material at this time. There is no question that the technology is improving, nevertheless, it still must pass the UL 924 standard before it shouidbe considered for inclusion in the Code. Even then, another important issue must be resolved. How can one insure that every photoluminescent sign in a building receives sufficient light to be activated?

In conclusion, we quote from the 1997 Life Safety Code Handbook A-5-10.3 commentary:.

"Given the problems associated with duration and decay of signs made of photoluminescent materials, if the term were defined m the Code, it would only help to give creditability to photoluminescent signs."

We agree. Adding photoluminescent path markers to the Code at this time would insure that they would be used improperly, making the job of local building inspectors and fire marshals even more diificult. Exhibits 2 and $ included with these comments prove that some local authorities already have difficulty interpreting existing requirements. Do you think that anyone made sure that the photoluminescent path markers approved for high level use in the Napa State Hospital or at 3200 Zanker Road in San Jose, California have sufficient hghting to insure adequate activation of the signs? We doubt it.

In order to protect the integrity of NFPA 101, Life Safety Code, photoluminescent material should not be included at this time.

Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: There is at least one photoluminescent exit sign that is listed to UL 924. If the Code does not have a special section for pbotoluminescent signs under the category of internally illuminated exit signs, then an approved photoluminescent sign could be used without the additional needed safeguards proposed for the Code. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 23 NEGATIVE: 2 ABSTENTION: 1 NOT RETURNED: 1 Paolucd

EXPLANATION OF NEGATIVE: HELTON: The Committee voted to reject the Comment on

Proposal No. 101-238 because there is at least one photoluminescent exit sign that is listed to UL 924. Currently, there are no requirements for photoluminescent exit signs in UL 924. At the present time, UL is processing such requirements, which will significantly change UL 924. We believe the photoluminescent exit sign was listed inappropriately, and this matter is currently under review by the laboratory responsible for the listing. We believe the sign is both an internally and an externally illuminated exit sign and accordingly, must comply with requirements for both. At the time this sign was listed, UL 924 may not have been an ANSI approved standard.

For the above reasons, we vote negatively on the committee action to reject Comment on Proposal No. 101-238.

WOODWARD: I feel that the committee has acted prematurely by permitting these signs when they comply with UL 924. While I agree that the acceptance of all signs should be based upon the use of a standard in order to create equal requirements, standards must be used properly.

As pointed out during the committee discussion, the standard does not currently address these types of signs. Therefore, we are making it appear that there are signs currently available which can comply with this standard. If the standard does not address these signs, there can be no signs available which truly comply with the standard.

Information was presented which claimed that there was a sign which did comply with the standard. However, since this standard does not address these types of signs, this "approval" is nothing more than an engineering judgment based upon what that one lab felt were the applicable sections of the standard. These types of j ~ m e n t s create a false impression and misapplication.

LANATION OF ABSTENTION: BRYAN: I have abstained on this issue due to professional

associations that could be perceived to create a conflict of interest.


101- 243 - (Section 5-10): Reject SUBMITrER= BiUy G. Helton, NEMA/Rep. Lithonia Lighting COMMENT ON PROPOSAL NO: 101-258 RECOMMENDATION: We strongly recommend that the Committee reconsider its recommendation to accept the inclusion of photoluminescent exit signs in the Life Safety Code. SUBSTANTIATION: This is in regards to Proposal 101-238 (Section 5-10), and some preliminary comments are in order. At the last MEA meeting, a presentation on photoluminescent exit signs was made. This presentation included a discussion of

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photoluminescent processes and technology. Statements were made to indicate that photoluminescent exit sign could meet UL 924 requirements and requested that this type of exit sign be included in the Life Safety Code. This Committee does not want to restrict the use of safety products that meet the required needs and applicable codes. Accordingly, it was voted to recommend revision of Section 5-10 to include photoluminescent exit signs and rewrite it for clarification. This was done with the understanding that all of the potential problems with this material would be adequately addressed by making proposals to Underwriters Iabor 'atones and getting UL 924 changed to indude appropriate construction and performance requirements, and getting photoluminescent exit signs Listed prior to the publication of NTPA 101, Life Safety Code, 2000 edition.

The SAF-MEA Committee is ready to take its final actions on proposals for NFPA 101, Life Safety Code, 2000 edition. To date, it does not appear that any substantial progress has been made in addressing the potential problems with allowing the use of photolununescent exit signs for marking of means of egress. There appears to be no readily available published reports proving that a practical photoluminescent exit sign can meet the requirements in UL 924. When proposals are made to Underwriters Laboratories to change UL 924, Underwriters laboratories considers them, and if deemed appropriate for consideration, presents these to the IAC for that standard. To date, no proposals have been made to the IAC. Therefore, it can only be concluded that very little, if any progress has been made in addressing potential problems - compliance with visibility requirements in UL 924, adequate and reliable charging, UV degradation, effects of temperature and humidity, durabdity, adhesion, etc. It is very unlikely that UL 924 will be changed to cover photoluminescent exits prior to the publication of the next Code. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement for rejection of Comment 101-242 (Log #276). NUMBER OF COMMITI?EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



(Log #276). WOODWARD: I feel that the committee has acted prematurely

by permitting these signs when they comply with UL 924. While I agree that the acceptance of all signs should be based upon the use of a standard in order to create equal requirements, standards must be used properly.

As pointed out during the committee discussion, the standard does not currently address these types of signs. Therefore, we are making it appear that there are signs currently available which can comply with this standard, ff the standard does not address these signs, there can be no signs available which truly comply with the standard.

Information was presented which claimed that there was a sign which did comply with the standard. However, since this standard does not address these types of signs, this "approval" is nothing more than an engineering judgment based upon what that one lab felt were the applicable sections of the standard. These types of judgments create a false impression and misapplication. EXPLANATION OF ABSTENTION:



101- 244 - (Section 5-10): Accept in Part $UBMITrER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-258 RECOMMENDATION: Revise as follows:

SECTION 5-10 MARKING OF MEANS OF EGRESS

5-10.1 General. 5-10.1.1 Where Required. Means of egress shall be marked in accordance with this section wbere required in Chapters 8 through

5-10.1.2" Exits. Exits shall be marked by an approved sign readily visible from any direction of exit access.

Exception: Main exterior exit doors that obvious 0 and clearO are identifiable as exits. 5-10.1.3 Exit Stair Door Tactile Signage. At each door into an exit stair enclosure, tactile signage stating "EXIT" and complying with CABO/ANSI A117.1, American National Standard for Accessible and Usable Buildings and Facilities, shall be installed adjacent to the latch side of the door 60 in. (152 cm) above the finished floor to the centerline of the sign. Exception: Existing buildings, provided the occupancy classification does not change. 5-10.1.4" Exit Access. Access to exits shall be marked by approved, readily visible signs in all cases where the exit or way to reach it is not readily apparent to the occupants. Sign placement shall be such that no point in fl~ean exit access corridor is more than 100 ft ($0 m) from the nearest externally illuminated sign and no greater than the marked rating for internally illuminated signs. Exception: Signs in exit access corridors in existing buildings shall not be required to meet the !5~ f i (Y~m) placement distance requirements. 5-10.1.5" Floor Proximity Exit Signs. Where floor proximity exit signs are required in Chapters 8 through 32, ~ signs shall be placed near the floor level in addition to those signs required for doors or corridors. These signs shall be ~ illuminated in accordance with 5-10.5. Externally illuminated signs shall be sized in accordance with 5-10.6.1. The bottom of the sign shall be at least 6 in. (15.2 cm) nor more than 8 in. (20.$ cm) above the floor. For exit doors, the sign shall be mounted on the door or adjacent to the door with the nearest edge of the sign within 4 in. (10.2 cm) of the door frame. 5-10.1.6" -Floor Proximity Egress Path Marking. Where floor

~ roximity egress path marking is required in Chapters 8 through 2, a listed and approved floor proximity egress path marking

system that is internally illuminated shall be installed within 8 in. (20.$ cm) of the floor. The system shall provide a visible delineation of the path of travel along the designated exit access and shall be essentially continuous, except as interrupted by doorways, hallways, corridors, or other such architectural features. The system shall operate continuously or at any time the building fire alarm system is activated. The activation, duration, and continuity of operation of the system shall be in accordance with

5-9.2. 5-10.1.7" Visibility. Every sign required in Section 5-10 shall be located and of such size, disfnctive color, and design as to be readily visible and shall provide contrast with decorations, interior finish, or other signs. No decorations, furhishings, or equipment that impairs visibility of ~ sign shall bepermj t ted , nor shall there be any brightly illuminated sign (for other than exit purposes), display, or object in or near the line of vision of the required exit sign of such a character as to detract attention from the exit sign. 5-10.2" Directional Signs. A sign complying with 5-10.3 with a directional indicator showing the direction of travel shall be placed

! in every location where the direction of travel to reach the nearest exit is not apparent. 5-10.3" Sign Legend. Signs required by 5-10.1 and 5-10.2 shall have the word EXIT" or other appropriate wording in plainly legible letters. 5-10.4" Power Source. Where emergency lighting facilities are required by the applicable provisions of Chapters 8 through $2 for individual occupancies, the ~ signs shall be illuminated by the emergency lighting facilities. The level of illumination of the e,,ft- sign shall be at the levels provided in accordance with 5-10.6.$ or 5-10.7 for the required emergency lighting time duration as specified in 5-9.2.1, but shall be permitted to decline to fi0 percent of the illumination level at the end of the emergency lighting time duration. Exception: Appwved self-luminous signs, e 5-10.5 Illumination of Signs. 5-10.5.1 General. Every sign required by 5-10.1.2 or 5-10.1.4 shall be suitably illuminated by a reliable light source. Externally and internally illuminated signs shall be legible in both the normal and emergency lighting mode. Exception: Where operations or processes require low lighting levels. 5-10.5.2" Continuous Illumination. Every sign required to be illuminated by 5-10.6.$ and 5-10.7 shall be continuously illuminated as required under the provisions of Section 5-8.

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Exception:* Illumination for signs shall be permitted to flash on and off upon activation of the fire alarm system. 5-10.6 Externally Illuminated Signs. 5-10.6.1" Size of Signs. Externally illuminated signs required by 5- 10.1 and 5-10.2 shall have the word "EXIT" or other appropriate wording in plainly legible letters not less than 6 in. (15.2 cm) high with the principal strokes of letters not less than 3/4 in. (1.9 era) wide. The word"EXIT" shall have letters of a width not less than 2 in. (5 cm), except the letter "I," and the minimum spacing between letters shall be not less than $/8 in. (1 cm). Signs larger than the minimum established in this paragraph shall have letter widths, strokes, and spacing in proportion to their height. Exception No. 1: Approved existing signs. Exception No. 2: Existing signs having the required wording in plainly legible letters not less than 4 in. (10.2 era) high. Exception No. 3: Marking required by 5-10.1.3 and 5-10.1.~,~. 5-10.6.2" Size and Location of Directional Indicator. The directional indicator shall be located outside of the EXIT legend, not less than 5/8 in. (1 era) from any letter. The directional indicator shall be of a chevron type as shown in Figure 5-10.6.2. The directional indicator shall be a ~:~: . . . . . r 1 ok :~ (~.2 ~_x t . : ~ l . . ~ ) , 1 r , .~ : _ t o ~ _~x . . . : ' . a_ . . . : ' . ~ . _ a AO :~ ( 1 ~ ~ x . . . . ~ . . . . , : + r .

:n er~er te be identifiable as a directional indicator at a minimum distance of 40 ft (12.2 m). Directional indicators larger than the minimum established in this paragraph shall be proportionately increased in height, width and stroke. The directional indicators shall be located at the end of the sign for the direction indicated. Exception: Approved existing signs.

Figure 5-10.6.2 Chevron-type indicator.

5-10.6.3" Level of Illumination. Externally illuminated signs shall be illuminated by not less than 5 ft-candles (54 lux) at the illuminated surface and shall have a contrast ratio of not less than 0.5. 5-10.7 Internally Illuminated Signs. 5-10.7.1 Listing. Internally illuminated signs shall be listed in accordance with UL 924, Standard for Safe O Emergency Lighting and Power EquipmenL Exception No. 1: Approved existing signs. Exception No. 2: Existing signs having the required wording in legible letters not lezs than 4 in. (10.2 cm) high. Exception No. 3: Marking required by 5-10.1.3 and 5-10.1.~. K 1/ '~ ~ q * D I - . ^ * ~ I . . ~ ; . . . . . . ~ ¢ ; ~ . T I - . ~ g . * . . ^ ~g " * k - -

k . , : l , 4 : ~ - - : . . . . . . . . ' . ~ / q P k ^ . ' 1 1 . . ~ . ' ~ 1 ^ ~ I . . . . I . ^ ~ +k. ~ - ^t +k^

ch-----~r.g "!lumir.a'2c, r. ghcJ! ~c r. rclIa~!, light source ~ ~ctz..-m..:..~c~ K . . +K . . . . + 1 - . ~ . . ~ , K ~ . . : ~ 1 , . 1 . ~ . . . 1 : o + : ^ ~ q " h . ^ ~ K ^ - - . ~ ' - - ~ I : ~ 1 . . + . . . . . . . . I - ^ I I

5-10.8 Special Signs. 5-10.8.1" No Exit. Any door, passage, or stairway that is neither an exit nor a way of exit access and that is located or arranged so that it is likely to be mistaken for an exit shall be identified by a sign reading "NO EXIT." Such sign shall have the word "NO ~ in letters 2 in. (5 cm) high with stroke width of $/8 in. (1 cm) and the word "EXIT" in letters 1 in. (2.5 cm) high, with the word ~EXlT" below the word "NO." Exception: Approved existing signs. 5-10.8.2 Elevator Signs. Elevators that are a part of a means of egress (see 5-2.15.1) shall have the following signs, with minimum letter height of 5/8 in. (1.6 an) , in every elevator lobby:

(a)* Signs that indicate that the elevator can be used for egress including any restrictions on use, and

(b)* Signs that indicate the operational status of elevators. 5-10.9 Tasting and Maintenance. 5-10.9.1 Inspection. Exit signs shall he visually inspected at maximum $O-day intervals for operation of the illumination sources. 5-10.9.2 Testing. Exit signs connected to or provided with a battery-operated emergency illumination source, where required in 5-10.4 g40,g,g, shall be tested and maintained in accordance with 5-9.$.

A-5-10.1.2 Where a main entrance serves also as an exit, it will usually be sufficiently obvious to occupants so that no exit sign is needed.

The character of the occupancy has a practical effect on the need for signs. In any assembly occupancy, hotel, department store, or other building subject to transient occupancy, the need for signs will be greater than in a building subject to permanent or semipermanent occupancy by the same people, such as an apartment house where the residents may be presumed to be familiar with exit facilities by reason of regular use thereof. Even in a permanent residence-type building, however, there is need for signs to identify exit facilities such as outside stairs that are not subject to regular use during the normal occupancy of the building.

There are many types of situations where the actual need for signs may be debatable. In cases of doubt, however, it is desirable to be on the safe side by providing signs, particularly as the placing af signs does not ordinarily involve any material expense or inconvenience,

The requirement for the locations of exit signs visible fro m any direction of exit access is illustrated in Figure A-5.10.1.2. A-5.10.1.4 Based on 6-in. (15.2-cm) high letters, it is recognized that exit signs are legible at a distance of 100 fi (~0 m). However, placing signs every 100 ft (~0 m) in other than exit access corridors

i might create operating difficulties or encourage placement of a sign above the line of sight. To resolve the viewing distance versus

I placement issue, consideration should be given to increasing the size of the exit legend proportionally to the viewing distance if signs are placed at greater distances.

A-5-10.1.5 See A-5.10.3. A-5-10.1.6 See 5-1.2 for definition of internally illuminated.

A-5-10.1.7 In stores, for example, an otherwise adequate exit sign may be made inconspicuous by some high-intensity illuminated advertising sign in the immediate vidnity.

Red is the traditional color for exit signs and is required by law in many places. However, at an early stage in the development of the Code, a provision was made that green be the color for exit signs, following the idea of traltic lights where green indicates safety and red is the signal to stop. During the period when green signs were specified by the Code, many such signs were installed, but the traditional red signs also persisted. In 1949, the Fire Marshals Association of North America voted to request that red be restored as the required exit sign color, as they found that the provision for green involved ditticulties in law enactment out of proportion to the importance of the subject. The 10th edition of the accordingly specified red where not otherwise required by law. The present text avoids any specific requirement for color on the assumption that either red or green will be used in most cases, and that there may be some situations where some color other than red or green may actually provide better visibility.

Figure A-5.10.1.2 Location of exit signs.

A-5-10.2 A sign complying with 5-10.2 indicating the direction of the nearest approved exit should be placed at the point of entrance to any escalator or moving wal l See A-5-10.3. A-5-10.3 Where graphics are used, the symbols of NFPA 170, Standard for Fire ,Safe O S3mbols, should be used. Such signs need to provide equal visibility and illumination and comply with the other requirements of Section 5-10. A-5-10.4 It is not the intent of this paragraph to require emergency lighting but only to have the sign illuminated by emergency lighting if emergency lighting is required and provided.

It is not the intent to require that the entire stroke width and entire stroke height of all letters comprising the word EXIT be visible per the requirements of 5-10.6.$ under normal or emergency lighting operation, provided that the sign is visible and legible at a 100-ft (30-m) distance under all room illumination conditions. See A-5-8.1.3 Exception No. 2.

A-5-10.5.2 It is the intent to prohibit a freely accessible light switch to control the illumination o f either an internally or externally illuminated exit sign. A-5-10.5.2 Exception The flashing repetition rate should be

~p proximately one cycle per second, and the duration of the off- me should not exceed one quarter second per c~,cle. During on-

time, the illumination levels need to be provaded in accordance with 5-10.6.3. Flashin~ signs, when activated with the fire alarm system, may be of assistance.

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A-5-10.6.1 Experience has shown that the word "EXIT" or other appropriate wording is plainly legible at 100 ft (50 m) if the letters are as large as specified in 5-10.6.1.

A-5.10.6.2 Figure A-5-10.6.2 shows examples of acceptable locations of directional indicators with rel~ard to left and right orientation. Directional indicators are permitted to be placed under the horizontal stroke of the letter "1" provided the minimum $/8 in. (1 cm) spacing is maintained from the horizontal and vertical strokes of the 'q'."

Figure A-5-10.6.2 Directional indicators.

A-5-10.6.3 Colors providing a good contrast are red or green letters on matte white background. Glossy background and glossy letter colors should be avoided.

The average luminance of the letters and background is measured in footlamberts or candela per square meter. The contrast ratio is computed from these measurements by the following formula:

Contrast = (Lg - Le) / Lg Where Lg is the greater luminance and Le is the lesser

luminance, either the variable Lg or Le may represent the letters, and the remaining variable will represent the background. The average luminance of the letters and background may be computed by measuring the luminance at the positions indicated in Figure A- 5-10.6.5 by numbered spots.

Figure A-5-10.6.5 Measurement of exit sign luminance.

~. . .~ ' - -~. . -_ . . ; . '~ . ,~ ","~'.-'." 7.'L.\~2;'..~.22 .'2L'T.,~" ~'..7",..~L"'..'L : ~ L ; ~ ~. . . . . . . . . .

A-5-I0.8.1 The likelihood of mistaking passageways or stairways that lead to dead-end spaces where occupants might be trapped for exit doors depends on the same considerations as govern the need for exit signs. Thus, such areas should be marked with a sign reading "NO EXIT." Supplementary identification indicating the character of the area such as "TO BASEMENT," "STOREROOM," "LINEN CLOSET," or the like may be provided. See #_-5-10.2.

A-5-10.8.2(a) These signs are to be used in place of sigus that indicate that elevators should not be used during fires. Examples of these signs include the following:

1. "In the event of fire, this elevator will be used by the fire department for evacuation of people."

2. "Protected Elevator ~ Usable in Emergencies." A-5-10.8.2(b) The wording of these messages should reflect considerations of human behavior in fires and the control specifics of the elevator system. This section addresses signs, but provisions for notification of the seeing impaired need to be considered. For information about human considerations with elevator evacuation see Groner and Levin 'spaper "Human Factors Gonsiderations in the Potential for Using Elevators in Building Emergency Evacuation Plans," Levin and Groner's paper "Human Behavior Aspects of Staging Areas for Fire Safety in GSA Buildings, ~ and Levin and Groner's paper "Human Factors Considerataons for The Potential Use of Elevators of Fire Evacuation of FAA Air Traffic Control Towers." Some examples of messages on signs that could be displayed are shown in Table A-5-10.8.2(b).

Move the A-5-10.5 definitions to 5-1.2 and A-5-1.2, and define "photoluminescenC, as follows: (5-1.2) Electroluminescent. A light-emitting capacitor for which alternating current excites phosphor atoms placed between electrically conductive surfaces and produces light.

(5-1.2) Externally Illuminated. The light source is contained outside of the device or legend that is to be illuminated. (5-1.2) Internally Illuminated. The light source is contained inside the device or legend that is illuminated.

*h . . . . . . I . ^C ^1 - . . . . . d2^~ ^¢ . . : ~ : l - . l ~ ^_ . ' ~ .~ . . * t . l ~ I . ~ l t . . . . . . l t - . : ~ t - . ~ ^~ '~T , J l es

(5-1.2) Self-Luminous. Illuminated by self-contained power sources and operates independently of external power sources. #,-5-1.2 Electroluminescent. This light source is typically contained inside the device.

A-5-1.2 Externally Illuminated. The light source is typically a dedicated incandescent or fluorescent source.

A-5.1.2 Internally Illuminated. The light source is typically incandescent, fluorescent, electrolummescent, photoluminescent, light-emitting diodes, or serf-luminous. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ¢ ) . . . . . . . . . . . . . . . . . . . . . .

. . . =~1 u ~ . 7 . . . . . . . . . . . . . . .

A-5-1.2 Self-Luminous. An example of a serf-contained power source is tritium gas. Batteries do not qualify as a self-contained power source. The light source is typically contained inside the device. SUBSTANTIATION: 5-10.1.4 editorial.

5-10.1.5, 5-10.1.6 and 5-10.4 The reorganization makes the use of the term exit restrictive to "exit" signs only. I believe the intent is for this to apply to both exit and exit access signs.

5-10.6.1 and 5-10.7.1 Exception No. 3. It appears that these should apply to 5-10.1.5 not 5-10.1.6 since it deals with exit signs, 5-10.1.6 is floor proximity egress path marking whereas 5-10.1.5 floor proximity exit signs.

5-10.6.2 Specifications removed in preference of the prior performance language. No justificauon was provided for the change. This was onginallyinstalled by the committee after years of work. Proposal 101-157 in 1990 was submitted by the committee using dimensions. This was modified by Comment 101-92 (NEMA) to go to performance language. • Why go back to specifications? If so, go to the original committee recommendation of 2 1/4 in. high, 1 7/8 in. wide and 5/4 in. stroke. This was the size the committee came up with based on extensive work by a task group over 10 years. Changing without extensive documentation is unjustified.

5-10.7.2, A-5-10.7.2, 5-1.2 and A-5-1.2 All material on photolumlnescent are recommended for deletion. See negative ballots on Proposals 101-258, 101-241, 101-248 and 101-249. COMMITYEE ACTION: Accept in Part.

I Do what the submitter requests for all but the following: Do not delete 5-10.7.2. Do not delete A-5-10-7.2. Do not delete 5-1.2 definition of photoluminescent. Do not delete A-5-1.2 appendix item associated with definition of

photoluminescent. COMMITI'EE STATEMENT: The committee concurs with all of the suggested changes except those identified above. The 4 deletions cannot be done based on the action on Comment 101- 242 (Log #276). This should meet most of the submitter's intent. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



(Log #276). EXPLANATION OF ABSTENTION:



101- 245- (5-10.3, 5-10.1.7): Reject SUBMITTER= William E. Lynch Jr., Isolite COMMENT ON PROPOSAL NO: 101-241 RECOMMENDATION: 5-10.3 No change should be made at this time. The appendix note that explains why photoluminescent material is not considered to be an acceptable light source still applies. Until such time that a photoluminescent product passes the UL 924 standard it should not be listed as an acceptable light S o u r c e .

5-10.1.7 For same reason as above, photoluminescent sign should not be used as a low level exit sign.

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N F P A 101 - - F 9 9 R O C

There is no justifiable reason to add wording to any section of the Code to sanction the use of photoluminescent material, or any other product, as an optional supplement to recjuired egress marking. The Code should only address the minimum acceptable standards. Building owners always have the option to do more than is required. They can choose to put in extra emergency lighting or to use photoluminescent material as a supplement to the Code requirements without any new changes to the Code.

Additionally, it would seem inappropriate to identify or sanction a specific brand name. SUBSTANTIATION: We appreciate this o~portunity to comment on the Proposals for changes to NFPA 101, Life Safety Code. For your information, we are manufacturers of Self-Luminous EXIT signs. These are tritium powered exit signs and are not to be confused with photoluminescent path markers. Unlike photoluminescent path markers, our signs require no external light source for activation and will work as well in a totally dark environment as in a normally lit office building. Our signs meet the new revised UL 924, Standard for Safety Emergency Lighting and Power Equipment and are listed by UL. Now that you know who we are, we will proceed with our comments.

It is inappropriate to recognize photohiminescent material as an acceptable light source for exit signs at this time. Although significant improvements have been made in photoluminescent technology, even the new metal oxide materials are unable to meet the requirements of UL 924, Standard for Safety Emergency Lighting and Power Equipment. Until such time as a product passes this standard, the inclusion of photoluminescent material as exist signs in NFPA 101, Life Safety Code, will cause these signs to be used incorrectly and thereby potentially put lives at risk.

As evidence of this potential risk, one needs to read the substantiation for the recommended change (Proposal 101-248) to 5-10.3.3 Exception No. 2 submitted by Mr. MannyMuniz of DDC Corporation:

"Photoluminescent exit signs are currently being used throughout the United States. They meet all the requirements of the Code in terms of size and illumination and have evenly illuminated letters with a minimum luminance of 0.06 footlamberts (0.21 cd/sq m). They are also listed in accordance with UL 924, Standard for Safety Emergency Lighting and Power Equipment, and UL 1994, Standard for Low Level Path and Lighting Systems."

This is untrue. We have checked with both Underwriters Laboratories and Interteck Testing Services (ETL), who confirm that no photoluminescent sign is listed in accordance with the UL 924 standard. In fact, as far as Underwriters Laboratories is concerned, there is no such thing as a photoluminescent exit sign. There are only photoluminescent path markers. UL has been very deliberate in their attempt to make sure t ha tpa th markers, approved for use under the UL 1994 standard, are not confused with exit fixtures. For reference we include the following excerpts from UL 1994:

"1.5 These requirements do not cover exit fixtures, exit lights, and serf-luminous exit signs (including those intended for floor- proximity installation) intended for use in accordance with NFPA 101, Life Safety Code, or emergency lighting fixtures. Such equipment is investigated under the requirements in UL 924, Standard for Emergency Lighting and Power Equipment.

2.8 PATH M A R K E R - A photo-luminescent, self luminous, or externally powered marker mounted at a low level that includes the words "EXIT", "TO EXIT", "STAIR", "TO STAIRS", "FIRE ESCAPE", "TO FIRE ESCAPE", or the like, and may also include a directional indicator. A path marker is intended only for use with and as part of a low level path marking and lighting system. See 1.5 for other limitations.

6.1.8 Installation and operating instructions provided with each externally powered system shall include:


Despite the above, as Mr. Muniz states, photoluminescent path markers are currently being used throughout the United States. This would not be a problem if they were only being used as they were intended. That is, as part of a low level path marking system in accordance with their listing to the UL 1994 standard. However, through clever and misleading advertising and representations, at least one photoluminescent manufacturer has been successful in substituting photoluminescent path markers in applications that require signs to meet the UL 924 standard.

we attach the following, exhibits as examples: Exhibit 1: Active Safetys Product Literature for Self-Illuminating

Exit Markings. Nowhere in this'literature is it explained that these

signs are only approved for use as part of a low level path marking system. The drawings as well as the mounting options certainly imply that they can he used anywhere. Why would you need a ceiling or flag mount for a low level path marking application? The name Serf-Illuminating is inaccurate - they must have an external light source to be activated - and confusing. We believe that this name is meant to be confused with Self-Luminous Signs - which do meet the UL 924 standard.

Exhibit 2: Letter from California State Fire Marshal Division Chief, Joe Garcia to Frank Dohronte of Active Safety. This is a response to a request to use Serf-Illuminating exit signs in high level applications. The signs have been represented as approved for low level. This is untrue and intentionally misleading. In this instance, the Fire Marshal approved the use of photoluminescent path markers for above door applications in the Naps State Hospital.

Exhibit $: Application for Variance or Waiver with San Jose Fire Department. Again, Active Safety has been sufficiently unclear in their application to cause it to be granted. They requested "UL listed exit sign for low level to be used for high level exit" stating that the "product functions as required for low level use. Requirements for low level exit signs are the same as high level." This is extremely deceptive. While it is true that the requirements for low level exit signs are the same as high level, this does not apply to photoluminescent path markers. This only applies to signs that are are listed to the UL 924 standard.

Exhibit 4: Letter to Active Safety from Thomas Trainor, Chief Electrical Inspector for the City of San Diego. Here, Active Safety ran into someone who understood the difference between UL 1994 and UL 924. The letter's final paragraph points to the misleading marketing materials for the photoluminescent path markers as follows:

01 note, in passing, that some of your literature on this product indicates that the exit signs may be used over a door or be hung from a ceiling. This is inaccurate and misleading. In order to reduce the possible confusion this could cause, I am forwarding copies of this letter to distributors in the San Diego area."

Exhibit 5: Special announcement from Active Safety to All representatives and distributors. "Now you can sell Active Safety's exit signage not only for low level but also for high levelH! ~ Again, false information.

Many more examples are available, but we think, unnecessary. There have been repeated attempts to include photohiminescent material as an acceptable light source for exit signage. These efforts include the California Building Code, the International Code Council Hearings in April 1998, and The Underwriters Laboratory's Industry. Advisory Conference in September 1998. All these efforts have failed for one simple reason. To date, no photoluminescent material has successfully passed the agreed standard for Safety Emergency Lighting, UL 924. Despite this fact, photoluminescent path markers are marketed and sold for above door applications. This is in direct conflict with the intent of NFPA 101, Life Safety Code and UL 924.

We respectfully request that the Committee reject the inclusion of any positive reference to photoluminescent material at this time. There is no question that the technology is improving, nevertheless, it still must pass the UL 924 standard before it should be considered for inclusion in the Code. Even then, another important issue must be resolved. How can one insure that every photoluminescent sign in a building receives sufficient light to be activated?

In conclusion, we quote from the 1997 Life Safety Code Handbook A-5-10.$ commentary:.

"Given the problems associated with duration and decay of signs made of photoluminescent materials, if the term were defined in the Code, it would only help to give creditability to photoluminescent signs."

We agree. Adding photoluminescent path markers to the Code at this time would insure that they would be used improperly, making the job of local building inspectors and fire marshals even more difficult. Exhibits 2 and 3 included with these comments prove that some local authorities already have difficulty interpreting existing requirements. Do you think that anyone made sure that the

hotoluminescent path markers approved for high level use in the apa State Hospital or at 3200 Zanker Road in San Jose, California

have sufficient lighting to insure adequate activation of the signs? We doubt it.


Note: Supporting material is available for review at NFPA Headquarters. COMMITI'EE ACTION: Reject.

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N F P A 101 ~ F9 9 R O C

COMMITTEE STATEMENT: See Committee Statement for rejection of Comment 101-242 (Log #276). NUMBER OF COMMHTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



(Log #'276). EXPLANATION OF ABSTENTION:



101- 246 - (5.10.$.$ Exception No. 2): Reject SUBMrrI 'ER: William E. Lynch Jr., Isohte COMMENT ON PROPOSAL NO: 101-248 and 101-238 RECOMMENDATION: Reject proposal.

The substantiation given for this proposal is inaccurate. No photoluminescent path marker has yet passed the UL 924 standard. If photoluminescent path markers are included in this exception prior to passing this standard, they will be used incorrectly.

Additionally, the word "listed" is ambiguous enough to be abused. Photoluminescent path markers are "listed ~ to UL 1994. Currendy, there is no reference as to what the signs are to be listed "to".

The newest generation of photoluminescent material may meet the minimum luminance of 0.06 footlamberts (0.21 cd/sq m) for a short period of time. Therefore, consideration should be given to including some reference to the fact that this luminance minimum pertains to .the end of 90 rain in the dark. SUBSTANTIATION: We appreciate this opportunity to comment on the Proposals for changes to NFPA 101, Life Safety Code. For your information, we are manufacturers of Self-Luminous EXIT signs. These are tritium powered exit signs and are not to be confused with photoluminescent path markers. Unlike photoluminescent path markers, our signs require no external light source for activation and will work as well in a totally dark environment as in a normally lit office building. Our signs meet the new revised UL 924, Standard for Safety Emergency Lighting and Power Equipment and are listed by UL. Now that you know who we are, we will proceed with our comments.


As evidence of this potential risk, one needs to read the substantiation for the recommended change (Proposal 101-248) to 5-10.~.g Exception No. 2 submitted by Mr. Manny Muniz of DDC Corporation:

"Photoluminescent exit signs are currently being used throughout the United States. They meet all the requirements of the Code in terms of size and illumination and have evenly illuminated letters with a minimum luminance of 0.06 foodamberts (0.21 cd/sq m). They are also listed in accordance with UL 924, Standard for Safety Emergency Lighting and Power Equipment, and UL 1994, Standard for Low LevelPath and Lighting Systems. ~

This is untrue. We have checked with both Underwriters Laboratories and Interteck Testing Services (ETL), who confirm that no photoluminescent sign is listed in accordance with the UL 924 standard. In fact, as far as Underwriters Laboratories is concerned, there is no such thing as a photoluminescent exit sign. There are only photoluminescent path markers. UL has been very deliberate in their attempt to make sure t ha tpa th markers, approved for use under the UL 1994 standard, are not confused with exit fixtures. For reference we include the following excerpts from UL 1994:

~1.5 These requirements do not cover exit fLxtures, exit lights, and self-luminous exit signs (including those intended for floor- proximity installation) intended for use in accordance with NFPA 101, Life Safety Code, or emergency lighting fixtures. Such equipment is investigated under the requirements in" UL 924, Standard for Emergency Lighting and Power Equipment.

2.8 PATH MARKER - - A photoquminescent, self luminous, or externally powered marker mounted at a low level that includes the words ~EXIT', *TO EXIT', ~STAIR', "TO STAIRS ~, "HRE ESCAPE", "TO FIRE ESCAPE', or the like, and may also include a directional indicator. A path marker is intended only for use with and as part of a low level path marking and lighting system. See 1.5 for other limitations.



Despite the above, as Mr. Muniz states, photoluminescent path markers are currendy being used throughout the United States. This would not be a problem if they were only being used as they were intended. That is, as part of a low level path marking system in accordance with their listing to the UL 1994 standard. However, through clever and misleading advertising and representations, at least one photoluminescent manufacturer has been successful in substituting photoluminescent path markers in applications that require signs to meet the UL 924 standard.


Exit Markings. Nowhere in this literature is it explained that these signs are only approved for use as part of a low level path marking system. The drawings as well as the mounting options certainly imply that they can be used anywhere. Whywould you need a ceiling or flag mount for a low level path marking application? The name Self-Illuminating is inaccurate - they must have an external light source to be activated - and confusing. We believe that this name is meant to be confused with Self-Luminous Signs - which do meet the UL 924 standard.

Exhibit 2: Letter from California State Fire Marshal Division Chief, Joe Garcia to Frank Dobronte of Active Safety. This is a response to a request to use Self-Illuminating exit signs in high level applications. The signs have been represented as approved for low level. This is untrue and intentionally misleading. In this instance, the Fire Marshal approved the use of photoluminescent

markers for above door applications in the Naps State ital. ibit 3: Application for Variance or Waiver with San Jose Fire

Department. Again, Active Safety has been sufficiendy unclear in their application to cause it to be granted. They requested "UL listed exit sign for low level to be used for high level exit" stating that the "product functions as required for low level use. Requirements for low level exit signs are the same as high level." This is extremely deceptive. While it is true that the requirements for low level exit silgns are the same as high level, this does not apply to photolummescent path markers. This only applies to signs that are are listed to the UL 924 standard.

Exhibit 4: Letter to Active Safety from Thomas Trainor, Chief Electrical Inspector for the City of San Diego. Here, Active Safety ran into someone who understood the difference between UL 1994 and UL 924. The letter's final paragraph points to the misleading marketing materials for the photoluminescent path markers as follows:

"I note, in passing, that some of your literature on this product indicates that the exit signs may be used over a door or be hung from a ceiling. This is inaccurate and misleading. In order to reduce the possible confusion this could cause, I am forwarding copies of this letter to distributors in the San Diego area- ~

Exhibit 5: Special announcement from Active Safety to All rel?resentatives and distributors. "Now you can sell Active Safety's exit signage not only for low level but also for high level!!!" Again, false information.

Many more examples are available, but we think, unnecessary. There have been repeated attempts to include photoluminescent material as an acceptable light source for exit stgnage. These efforts include the California Building Code, the International Code Council Hearings in April 1998, and The Underwriters Laborator~s Industry Advisory Conference in September 1998. All these efforts have failed for one simple reason. To date, no photoluminescent material has successfullypassed the agreed standard for Safety Emergency Lighting, UL 924. Despite this fact, dPhOtoluminescent path markers are marketed and sold for above

oor applications. This is in direct conflict with the intent of NFPA 101, Life Safety Code and UL 924.

We respectfully request that the Committee reject the inclusion of any positive reference to photoluminescent material at this time. There is no question that the technoJogy is improving, nevertheless, it still must pass the UL 924 standard before it should be

148

N F P A 101 m F 9 9 R O C

considered for inclusion in the Code. Even then, another important issue must be resolved. How can one insure that every photoluminescent sign in a building receives sufficient light to be activated?

In conclusion, we quote from the 1997 Life Safety Code Handbook A-5-10.3 commentary:


We agree. Adding photoluminescent path markers to the Code at this time would insure that they would be used improperly, making the job of local building inspectors and fire marshals even more difficult. Exhibits 2 and 3 included with these comments prove that some local authorities already have difficulty interpreting existing requirements. Do you think that anyone made sure that the

hotoluminescent path markers approved for high level use in the apa State Hospital or at 3200 Zanker Road in San Jose, California

have sufficient hghting to insure adequate activation of the signs? We doubt it.


Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statementfor rejection of Comment 101-242 (Log #276). NUMBER OF COMMITTEE MEMBERS ELIGIBLE T O VOTE: 27 VOTE ON COMMITrEE ACTION:



(Log #276). EXPLANATION OF ABSTENTION:



101- 247- (5-10.3.5 Exception): Reject SUBMITTER: William E. LynchJr. , Isolite COMMENT ON PROPOSAL NO: 101-249 RECOMMENDATION: Photoluminescent path markers should not be included in this Exception until such time as they are able to pass the UL 924 standard. If included, they will be used incorrectly.

Also, the word ~approved" is ambiguous enough to be abused. Photoluminescent path markers are "approved" to UL 1994. SUBSTANTIATION: We appreciate this opportunity to comment on the Proposals for changes to NFPA 101, Life Safety Code. For your information, we are manufacturers of Self-Luminous EXIT signs. These are u'itium powered exit signs and are not to be confused with photoluminescent path markers. Unlike photoluminescent path markers, our signs require no external light source for activation and will work as well in a totally dark environment as in a normally lit office building. Our signs meet the new revised UL 924, Standard for Safety Emergency Lighting and Power Equipment and are listed by UL. Now that you know who we are, we will proceed with our comments.


As evidence of this potential risk, one needs to read the substantiation for the recommended change (Proposal 101-248) to 5-10.3.3 Exception No. 2 submitted by Mr .MannyMuniz of DDC Corporation:

"Photoluminescent exit signs are currendy being used throughout the United States. They meet all the requirements of the Code in terms of size and illumination and have evenly illuminated letters with a minimum luminance of 0.06 footlamberts (0.21 cd/sq m). They are also listed in accordance with UL 924, Standard for Safety

Emergency Lighting and Power Equipment, and UL 1994, Standard for Low Level Path and Lighting Systems.

This is untrue. We have checked with both Underwriters Laboratories and Interteck Testing Services (ETL), who confirm that no photoluminescent sign is listed in accordance with the UL 924 standard. In fact, as far as Underwriters Laboratories is concerned, there is no such thing as a photoluminescent exit sign. There are only photoluminescent path markers. UL has been very deliberate in their attempt to make sure that path markers, approved for use under the UL 1994 standard, are not confused with exit fixtures. For reference we include the following excerpts from UL 1994:

"I.5 These requirements do not cover exit fixtures, exit lights, and self-luminous exit signs (including those intended for floor- proximity installation) intended for use in accordance with NFPA 101, Life Safety Code, or emergency lighting fixtures. Such equipment is investigated under the requirements in UL 924, Standard for Emergency Lighting and Power Equipment.

2.8 PATH MARKER p A photo-luminescent, self luminous, or externally powered marker mounted at a low level that includes the words "EXIT", "TO EXIT', "STAIR', "TO STAIRS", "FIRE ESCAPE", ~TO FIRE ESCAPE", or the like, and may also include a directional indicator. A path marker is intended only for use with and as part of a low level path marking and lighting system. See 1.5 for other limitations.



Despite the above, as Mr. Muniz states, photoluminescent path markers are currently being used throughout the United States. This would not be a problem if they were only being used as they were intended. That is, as part of a low level path marking system in accordance with their listing to the UL 1994 standard. However, through clever and misleading advertising and representations, at least one photoluminescent manufacturer has 1Seen successful in substituting photohiminescent path markers in applications that require signs to meet the UL 924 standard.


Exit Markings. Nowhere in this literature is it explained that these signs are only approved for use as part of a low level path marking system. The drawings as well as the mounting options certainly imply that they can be used anywhere. Why would you need a ceiling or flag mount for a low level path marking application? The name Self-Illuminating is inaccurate - they must have an external light source to be activated - and confusing. We believe that this name is meant to be confused with Self-Luminous Signs - which do meet the UL 924 standard.

Exhibit 2: Letter from California State Fire Marshal Division Chief, Joe Garda to Frank Dobronte of Active Safety. This is a response to a request to use Self-Illuminating exit signs in high level applications. The signs have been represented as approved for low level. This is untrue and intentionally misleading. In this instance, the Fire Marshal approved the use of photoluminescent

ath markers for above door applications in the Napa State ospitai. Exhibit 3: Application for Variance or Waiver with San Jose Fire

Department. Again, Active Safety has been sufficiently unclear in thetr application to cause it to be granted. They requested "UL listed exit sign for low level to be used for high level exit" stating that the "product functions as required for low level use. Requirements for low level exit signs are the same as high level." This is extremely deceptive. While it is true that the requirements for low level exit signs are the same as high level, this does not apply to photolumineseent path markers. This only applies to signs that are are listed to the UL 924 standard.

Exhibit 4: Letter to Active Safety from Thomas Tralnor, Chief Electrical Inspector for the City of San Diego. Here, Active Safety ran into someone who understood the difference between UL 1994 and UL 924. The letter's final paragraph points to the misleading marketing materials for the photoluminescent path markers as follows:

"I note, in passing, that some of your literature on this product indicates that the exit signs may be used over a door or he hung from a ceiling. This is inaccurate and misleading. In order to reduce the possible confusion this could cause, I am forwarding copies of this letter to distributors in the San Diego area."

Exhibit 5: Special announcement from Active Safety to All representatives and distributors, q~Iow you can sell Active Safety's

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N F P A 101 - - F9 9 R O C

exit signage not only for low level but also for high level!H" Again, false information.

Many more examples are available, but we think, unnecessary. There have been repeated attempts to include photoluminescent material as an acceptable light source for exit signage. These efforts include the California Building Code, the International Code Council Hearings in April 1998, and The Underwriters Laboratory's Industry Advisory Conference in September 1998. All these efforts have failed for one simple reason. To date, no photoluminescent material has successfully passed the agreed standard for Safety Emergency Lighting, UL 924. Despite this fact, photoluminescent path markers are marketed and sold for above door applications. This is in direct conflict with the intent of NFPA 101, Life Safety Code and UL 924.

We respectfully request that the Committee reject the inclusion of any positive reference to photoluminescent material at this time. There is no question that the technology is improving, nevertheless, it still must pass the UL 924 standard before it shou ldbe considered for inclusion in the Code. Even then, another important issue must be resolved. How can one insure that every photoluminescent sign in a building receives sufficient light to be activated?

In conclusion, we quote from the 1997 Life Safety Code Handbook A-5-10.$ commentary:


We agree. Adding photoluminescent path markers to the Code at this time would insure that they would be used improperIy, making the job of local building inspectors and fire marshals even more difficult. Exhibits 2 and 3 included with these comments prove that some local authorities already have difficulty interpreting existing requirements. Do you think that anyone made sure that the photoluminescent path markers approved for high level use in the Napa State Hospital or at 3200 Zanker Road in SanJose, California have sufficient hghting to insure adequate activation of the signs? We doubt it.

In order to p ro ted ' the integrity of NFPA 101, Life Safet), Code, photoluminescent material should not be included at th~s time.

Note: Supporting material is available for review at NFPA Headquarters. COMMITI'EE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement for rejection of Comment 101-242 (Log #276). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 25 ABSTENTION: 1 NOT RETURNED: I Paolucd

EXPLANATION OF ABSTENTION: BRYAN: I have abstained on this issue due to professional

associations that could be perceived to create a conflict of interest.

(Log #37) Committee: SA~.-MEA

101- 248- (5-11.2): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-255 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA evaluate the merits of Proposal 101-255, thus permitting the proposal to be Accepted at ROC-preparation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Retain the rejection of Proposal 101-255 as done by SAF-AAC. COMMITrEE STATEMENT: The current wording presents desirable redundancy. There is no conflict with Table 5-3.3.1 given that a reduction for sprinklered buildings has been rejected. The committee action should meet the submitter's intent. NUMBER OF C O M M r r ~ E MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 249 - (5-12.1 Exception No. 2 (New)): Accept in Principle in Part SUBMITTER: Eugene A. Cable, U.S. Deparmaent of Veterans Affairs COMMENT ON PROPOSAL NO: 101-256 RECOMMENDATION: Delete proposed exception and replace with:

Exception No. 2: A common path of travel not more than 150 ft shall be permitted if all of the following are met:

(a) The building is sprinkler protected throughout and (b) there is no fuel fined eqmpment and (c) for an existing building and (d) the egress path is made clear by extra markings, such as

arrows painted on the floor. SUBSTANTIATION: The VA has numerous attic mechanical spaces with a travel distance problem. In some cases the situation is acceptable due to conditions such as full sprinkler protection - unoccupied clear - straight line vision a n d p a t h to exit. The proposed Exception No. 2 as written wouldnot address any of these special conditions. The rewrite would address some of those

eCial conditions and would meet the needs of original submitter. MMITTEE ACTION: Accept in Principle in Part.

Do not delete proposed Exception No. 2, [note that the exception is further revised by the action on Comment 101-251 (Log #CC59)] but renumber it to become Exception No. 3. Insert a new Exception No. 2 to read:

Exception No. 2: In an existing building a common path of travel not more than 150 feet shall be permitted if all of the following are met:

(a) The building is protected throughout by an approved, supervised automatic sprinkler system installed in accordance with Section 7-7

(b) No fuel fired equipment within the space (c) The egresspath is readily identifiable.

COMMITTEE STATEMENT: The exception for existing healthcare occupancies is legitimate and needs to be retained. However, an additional exception applicable to existing buildings, regardless of occupancy, is also needed. This should meet most of the submitter's intent. NUMBER OF COMMrFI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 250 - (5-12.1 Exception No. 2 (New)): Reject SUBMITTER= Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-256 RECOMMENDATION: Delete proposed Exception No. 2. SUBSTANTIATION: The 5-12.1 and 5-12.2 section deals with industrial occupancy mechanical spaces. It does not matter what type occupancy the building might be. The life of a maintenance worker while in an attic should be equally treated. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Comment 101-251 (Log #CC59). NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:


(Log #CCA9) Committee: SAF-MEA

101- 251 - (5-12.1 Exception No. 3): Accept SUBMITFER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-256 RECOMMENDATION: Revise Exception No. $ (shown as proposed Exception No. 2 in Proposal 101-256) to read:

Exception No. $: In existing healthcare occupancies, rooms or spaces complying with the arrangement of means of egress provisions of 13-2.5 and the travel distance limits of I$-2.6. SUBSTANTIATION: The exception, as proposed in the ROP, was too lenient in referencing only travel distance. The arrangement of means of egress provisions of 13-2.5 are also needed because they require a second exit access when a room or

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space becomes excessively large. This is healthcare's indirect way of addressing common path of travel. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:


(Log #341a) Committee: SAF-FIR

101- 252 - (Chapter 6): Reject TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) notes that in response to Mr. Humble's Comment on Aff'u'mative, the same public comment was sent to SAF-IND which has responsibility for the high-rise building provisions in Chapter 32. See Comment 101-486 (Log #341c). SUBMrIWER: Peter W. Szerlag, Arlington, MA COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: I do not know where these two items might fit into NFPA 101. [Note: This comment has been assigned to SAF-FUN, SAF-FIR, SAF-BSF and SAF-IND.]


2. Every high rise building shall have smoke exhaust equipment on every floor (above the seventh floor) which can be remotely activated by the fire deparmaent via radio remote control. SUBSTANTIATION: Item 1 - self evident

Item 2 - This item mirrors the recent FAA allowance of fire detection and fire suppression systems on planes which are interconnected via spread spectrum radio links. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee believes that this provision would be best addressed by the technical committee responsible for NFPA 80, Fire Doors and Fire Windows. The revision mentions maintaining the fire control and smoke control attributes/capabilities of the door which would be appropriately addressed in NFPA 80. This technical committee would be able to discuss the merits of this provision as it applies to a rated fire door. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 24 NOT RETURNED: $ Holmes, Jiig, King

COMMENT ON AFFIRMATIVE: HUMBLE: We agreed to provide direction to the proponent at

the meeting, as a result I would recommend adding the following to the first sentence of the "Committee Statement":

"The SAF-FIR committee acted only on item #1.and recommended that the nrooonent refer item #2 to the SAF- IND...(Remainder uncllanged) ".

(Log #38) Committee: SAF-FIR

101- 253 - (6-2.1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-257 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FIR give consideration to Ms. Stone's comment on affirmative. It reads:

STONE: I agree, but the committee needs to address existing buildings. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-255 (Log #359). COMMITTEE STATEMENT: The action taken on Comment 101- 255 (Log #359) should fulfill the intent of the submitter. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NOT RETURNED: ~ Holmes, Jilg, King


101- 254- (6-2.1): Accept SUBMITrER: Technical Committee on Hre Protection Features COMMENT ON PROPOSAL NO: 101-257

I RECOMMENDATION: In 6-2.1 add the word "barrier" to subsection (a) so that it reads:

(a) separate buildings if a 2-hour or greater vertically aligned fire barrier wall in accordance with NFPA 221, Standard for Fire Walls and Fire Barrier Walls exists between the portions of the building. SUBSTANTIATION: The revision is done for clarification and to correctly reference the type of separation that is required as noted by the negative comments in the ROP by committee members Mr. Cahanin and Mr. Klein. It was not the intent of the committee to require a fire wall as defined by NFPA 221 but to require a fire barrier wall as defined in NFPA 221. COMMITTEE ACTION: Accept. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #359) Committee: SAF-HR

101-255- (6-2.1(a) Exception (New)): Accept SUBMITTER: William E. Koffel Jr., Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-257

I RECOMMENDATION: Add a new Exception to (a) to read as follows:

Excention: Previously approved separation~ betiw¢¢o bui ld ing. SUBS'i'ANTIATION: There may be instances where the authority having jurisdiction has accepted a separation between buildings other than the vertically aligned fire walls having a >_ 2 hr fire resistance rating. COMMITrEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITIY~ ACTION:

AFFIRMATIVE: 22 NEGATIVE: 2 NOT RETURNED: 3 Holmes, Jilg, King

EXPLANATION OF NEGATIVE: BALDASSARRA: I agree with Mr. Francis for this log. I suggest

using the word "existing." FRANCIS: While I agree with the general idea that there may be

existing construction other than the "vertically aligned fire walls having a >-2 hr fire resistance rating and that this eventuality should be provided for, I disagree that the Exception should be worded "Previously approved . . . . This puts burdens on the owner and the authority having jurisdiction to demonstrate approval/disapproval. I believe the generally utilized expression of "Existing..." is appropriate here. By way of example, an assembly accepted by a Board of Appeals or any body with authority to adjudicate an order may enter a finding for a particular circumstance. This may be viewed as other than approved since it was NOT approved by the authority having jurisdiction. Thus the traditional expression of "existing" imparts the necessary meaning.


101- 256- (6-2.4): Reject SUBMITTER: David W. Landmann, Ther iau l t /Landmann Assoc. COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Strike the title and all references to "smoke partition(s)" and insert: "Smoke Barrier I" or "Smoke Barrier 11".. SUBSTANTIATION: For years "smoke barrier" and "smoke partition" have been used interchangeably. Adding "smoke partition" will cause errors and confusion. The proposed language focuses attention on the new feature/requirement, yet creates a hierarchy of smoke resistive construction, similar to fire corridors. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Theproposed text would not develop the clarification as i n t endedbu t could lead to greater confusion by using identification methods that are not currendy found in the document. By using a term " smoke barrier" in the definition for smoke partiuon could lead the document user to associate these two items which was not the intent of the proposed revision and creation of the new section on smoke partitions.

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101- 257- (6-2.4): Reject SUBMITTER= Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Change "smoke partition" to "smoke resisting partition". SUBSTANTIATION: The terminology "smoke partition" is currently used interchangeably with "smoke barrier". Changing the meaning and requirements for smoke partition will cause confusion.

The additional term "resisting ~ would reduce the level of confusion, "smoke resisting partitions" more clearly carries a different meaning. COMMITI'EE ACTION: Reject. COMMITTEE STATEMENT: The proposed text does not add the level of clarification which the submitter intended. The proposed text for smoke partitions was created to address the original confusion which had occurred over the years and how it was ~ L ~ E ~ this document.

OF COMMrlTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITFEE ACTION:

AFFIRMATIVE: 24 NOT RETURNED: 3 Holmes, Jiig, King


101- 258 - (6-2.4): Reject SUBMITTER: Richard M. Pletmer, Orange Beach, AL COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Mr. Klein's comment on affirmative recommends adding an appendix note emphasizing that it is not the intent of this section to require air ducts penetrating smoke partitions to be protected with fire dampers or smoke dampers. I feel adding such a note would actually be confusing and I am wri t ingto recommend that no such appendix note be added. SUBSTANTIATION: While it may not be the intent of this section to require ducts to be protected by dampers, a significant number of consultants, designers, and building owners prefer to incorporate this type of protection. I feel that overemphasizing the intent of this section would send the improper message that fire dampers or smoke dampers" are not desirable for this application. This would be unwise. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Comment 101-259 (Log #39). NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 23 ABSTENTION: 1 NOT RETURNED: 3 Holmes, Jilg, King

EXPLANATION OF ABSTENTION: BROOKS: I agree with Mr. Plettner's reason for recommending

that a note not be added to the appendix (a note emphasizing that it is not ' the intent of the section to require air ducts penetrating smoke partitions to be protected with fire or smoke dampers). I am abstaining from voting negative since no such note was added to the appendix.

hazardous areas), not smoke barriers (i.e., walls to subdivide building spaces under existing Section 6-3).

New Section 6-2.4.4.1 covers the protection of penetrations and openings in smoke partitions, one of which is air ducts. Yesterday afternoon I spoke to Eric Cote, one of the members of our task group that wrote this proposal, on the issue of possible misinterpretation of this new section 6-2.4.4.1 requiring fire dampers a n d / o r smoke dampers in air ducts penetrating smoke partitions. Eric stated that it was not the intent of the task group, or the committee, in the review of this proposal at its meeting on 5 /12 /98 to require fire dampers a n d / o r smoke dampers for air ducts under this section of the code.

Therefore, I would highly recommend that to prevent misapplication of these new code provisions under this section, an appendix note be added for Section 6-2.4.4.1 that would read:

A-6-2.4.4.1 It is not the intent of this section to require air ducts to have fire dampers or smoke dampers in smoke partitions.

It is my recommendation that adding this note to the appendix will save the committee time in the future on interpretauons from the public relating to this issue. It is ~...an ounce (gram) of prevention is worth a pound (kilograms) of cure..." philosophy.

STONE: I agree, but the committee needs to clarify if non-ducted return/supply openings are within the wails above the suspended ceiling is any protection required within the opening? The walls are considered a smoke partition and could be construed to require a smoke damper. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-265 (Log #CC100). COMMITTEE STATEMENT: A Committee Comment was created to specifically address the comments addressed by Comments 101- 258 (Log #414), 101-259 (Log#$9) and 101-264 (Log #356). Committee Comment 101-265 (Log #CC100) should fulfill the intentions of these comments. NUMBER OF COMMITTEE MFaMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 260 - (6-2.4.1): Reject SUBMITrERa James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-264 RECOMMENDATION: In the current 6-2.4.1, delete all three Exceptions and replace with one Exception to read:

F~f¢p~on: Floor o p e n i n ~ as permitted by 6-2.4.2. Add 6-2.4.8 to the list of Exceptions in 6-2.4.2 as Exception No. 4.

SUBSTANTIATION: Editorial. There is no need to list the Exceptions twice. In the paragraph, 6-2.4.8 is missing from the current list of exceptions. COMMITTEE ACTION: Reject. COMMITFEE STATEMENT: The SAF-FIR Committee reviewed the comment and determined that there was merit to the action requested but at this time in the development of this document wished not to implement the revision. The committee wished to maintain the current provisions. A task group has been established to review the entire section on vertical openings for consistency. The proposed revision did highlight a need to make revisions but as further review was being done, other revisions for clarification were noted and it was determined that it should not be done at this time. NUMBER OF COMMrrTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI~E ACTION:



101- 259 - (6-2.4 (New)): Accept in Principle SUBMITIT_.R= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FIR give consideration to Mr. Klein's and Ms. Stone's comments on affirmative. They read:

KLEIN: This new section of the code is being proposed by our committee to address smoke partitions (i.e., walls enclosing


101- 261 - (6-2.4.2): Accept SUBMITTER: Technical Committee on Fire Protection Features COMMENT ON PROPOSAL NO: 101-260

I RECOMMENDATION: Add the following text "penetrations for ~ to the appendix for 6-2.4.2 so that it reads:

A-6-2.4.2 Exception An architectural, exposed suspended grid acoustical tile ceiling with ~ sprinklers, ducted HVAC supply and return air diffusers, speakers, and recessed light fixtures is capable of limiting the transfer of smoke.

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SUBSTANTIATION: The proposed addition of the terms "penetration for" to appendix note A-6-2.4.2 was for clarification. It is to highlight what openings in a ceiling one may find. This committee comment was created to address the issue raised by comment 101-262 (Log #286). COMMITTEE ACTION: Accept. NUMBER OF COMMYI'FEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMIaWEE ACTION:


throughout the code, walls that resist the passage of smoke are required without the use of door dosers. By establishing the door requirements as an identifiable list, the occupancy chapters can easily delete the door-closing requirement. Should it be found that more delete it than keep it, it should be changed to "where required" so as to simplify the code. COMMITrEE ACTION: Accept. NUMBER OF CoMMrlq 'EE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 262 - (6-2.4.2 Exception): Reject SUBMITTER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Delete the current proposed exception to 6-2.4.2 and replace it with two new exceptions.

Exception No.l: A smoke partition shall not be required to extend through the concealed space above a ceiling, provided the construction assembly forming the bottom of the concealed space provides resistance to the passage of smoke equal to that provided by the smoke partition.

Exception No. 2: Smoke partitions on floors of buildings protected throughout by an approved sprinkler system shall be permitted to terminate at the underside of a suspended ceiling system where:

(a) s a m e

(b) same (c) same.

SUBSTANTIATION: Separate the issues of monolithic ceilings (MC) and suspended ceilings (SC). They should be handled differently. The MC option should be permitted in a nonsprinklered zone. The SC option should be permitted in a sprinklered zone only, as you have.referenced in the new appendix note A-6-2.4.2. You also need to move the requirement for sprinklers out of the appendix and into the code for the SC option. If this approach is not taken, the requirements for smoke partitions will be more restrictive that those for smoke barriers. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: It was not the intent of this provision to require the installation of fire sprinklers for this provision to be satisfied. It should be noted that this item is part o f an appendix note and is provided to assist the end user of the document and highlight those penetrations that can be found in a ceiling. A commmee Comment 101-261 (Log #CC101) was created to further clarify the intention of A-6-2.4.2. It should be noted that if the requirement for a fire sprinkler system is required to satisfy a particular provision that it would be deternuned by the applicable occupancy chapters. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NOT RETURNED: $ Holmes, Jilg, King

(Log #CGS00) Committee: SAF-BCF

101- 263 - (6-2.4.3): Accept [ TCC NOTE: The Techmcal Correlating Committee on Safety to [ Life (SAF-AAC) directs that the action o n this comment be [ changeci to show that the asterisk that is currently pos i t ioned be low ] in the Recommendat ion f ield with 6-2.4.3 be moved to accompany

6-2.4.3.4 to which the subject appendix verbiage has particular [ appficability.

SUBM1TTER: Technical Committee on Board and Care Facilities COMMENT ON PROPOSAL NO: CP607 RECOMMENDATION: Reorganize 6-2.4.3 as follows:

6-2.4.3* Doors 6-2.4.3.1 Doors in smoke partitions shall comply with 6-2.4.3.2

through 6-2.4.3.5. 6-2.4.3.2 Doors shall comply with the provisions of 5-2.1. 6-2.4.3.3 Doors shall be without louvers. 6-2.4.3.4 Door clearances shall be in accordance with NFPA 80,

Standard for Fire Doors and Fire Windows. 6-2.4.3.5 Doors shall be self-dosing or automatic closing in

accordance with 5-2.1.8. SUBSTANTIATION: This is only an editorial change in Chapter 6. The change is needed for the occupancy chapters to properly use the new term "smoke partition." In numerous locations


101- 264 - (6-2.4.4.1): Accept in Principle SUBMITrER= Thomas W. Jaeger /Thomas W. Gardner, American Health Care Assn. (AHCA) COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Add a new Appendix A-6-2.4.4.1 to read:

"It is not the intent of this section to require air ducts to have fire dampers or smoke dampers in smoke partitions. It is the intent of this section that non ducted HVAC openings be i~rotected with smoke dampers or smoke operated fire dampers. SUBSTANTIATION: To address the legitimate comments on the affirmative votes of Mr. Klein and Ms. Stone. COMMITTEE ACTION: Accept in Principle.

See Committee Comment 101-265 (Log #CC100). COMMITTEE STATEMENT: The Committee Comment 101-265 (Log #CC100) should meet the intention of the submitter. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #CCI00) Committee: SAF-FIR

101- 265 - (6-2.4.4.3 and A-6-2.4.4.3): Accept I TCC NOTE: The Technical Correlating Committee on Safety to

Life (SAF-AAC) directs that the action on this comment be changed to implement Mr. Baldassarra's comment so that the rust sentence of 6-2.4.4.3 reads:

~Air transfer openings in smoke partitions shall be provided with approved dampers designed to limit the transfer o f smoke." SUBMITrER: Technical Committee on Fire Protection Features COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Add a new 6-2.4.4.$ and A-6-2.4.4.3 that read as follows:

6-2.4.4.3* Any air transfer opening in a smoke partition shall be provided with an approved damper designed to hmit the transfer of smoke. Dampers in air transfer openings shall close upon detection of smoke by approved smoke detectors installed in accordance with NFPA 72, National Fire Alarm Code.

A-6.2.4.4.$ An air transfer opening as defined in NFPA 90A, Standard for the Installation of Air Conditioning and Ventilating Systems, is an opening designed to allow the movement of environmental air between two contiguous spaces. SUBSTANTIATION: The new 6-2.4.4.3 was added to further clarify the intention when a damper designed to limit the transfer of smoke through a smoke partition is required. This was developed to address Comments 101-258 (Log #414), 101-259 (Log #39) and 101-264 (Log #356). COMMITTEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


COMMENT ON AFFIRMATIVE: BALDASSARRA: Suggest editorial improvement: "A~et Air transfer openingll in ~ smoke partitions shall be provided

with an- approved damper~..." Current text suggest requirement can be satisfied by providing

dampers for "any", (i.e., only 1), air transfer opening. The intent is for all openings.

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(Log #40) Committee: SAF-RES

101- 266 - (6-2.4.8(d)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-268 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES imp.lement the change via modification of the wording that recognizes the use of 6-2.4.8 in the residential occupancies chapters. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Add a new paragraph A-6-2.5.8(d) as follows: "Thi~ prohibits means of e~ess down or up the convenience

9pcnin~. |1; ~IQvs nOt prohibit mea~s of escape from goin~ dowll or uo the convenience ooenine within residential dwellin~ units." COI~IMITTEE STATEMI~NT: The Committee feels that an appendix note to this paragraph is more appropriate. It avoids redundency and clarifies of the term "means of egress" as used in Chapter 6. NUMBER OF COMMrlTEE MEMBER5 ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:



101- 267- (6-4.5): Reject SUBMITTER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-273 RECOMMENDATION: Delete the words "Rooms in occupancies containing". SUBSTANTIATION: Editorial. This phrase is unnecessary. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Comment 101-268 (Log #41). NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 24 NOT RETURNED: 3 Holmes, Jil t , King


101- 268 - (6-4.5 (New)): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-273 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FIR reevaluate its action. The language "rooms in occupancies containing hyperbaric facilities shall comply..," doesn' t reflect intent; i t probably should read "rooms containing hyperbaric facilities shall comply..."

Further, SAF-AAC directs that the public comment also request SAF-FIR to evaluate if the proposed wording would require use of NFPA 99 outside that document 's scope if the hy~perbaric facility was not health-care related. SAF-FIR might consider adding

endix guidance directing the user to NFPA 55, Guide on Fire rds on Oxygen-Enriched Atmospheres.

SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise 6-4.5 by deleting "Rooms in" and adding "All" in the beginning of this paragraph and add a new appendix item so that they read:

6-4.5 -Rooms-~AII occupancies containing hyperbaric facilities shall comply with NFPA 99, Standard for Health Care Facilities, Chapter 19, Hyperbaric Facilities, unless otherwise modified by other provisions of this Code.

A-6.4.5 While the scone of NFPA 99. Standard for Health Care Facilities. is limited to laealth care occuoancies, it is the intent of this reouirement to be aoolied to hvoerbaric facilities used in all occuDancies. CO!~dMITTEE STATEMENT: This action is a continuation of the original proposal which showed that a hazard existed with the use of these hyperbaric chambers and that they are being used outside of the traditional health care facility. The committee recognized that there is information contained in Chapter 19 of NFPA 99 which specifically addresses the hyperbaric facilities. It is also noted that hyperbaric facilities had their origination in the health care field and thus those requirements associated with them are

found in a document associated with health care facilities. The committee wishes to use the expertise developed for these facilities as noted in Chapter 19 of NFPA 99 because it is applicable regardless of where one may find these hyperbaric facilities. The use of hyperbaric facilities have moved to other types of occupancy uses and specific requirements associated with their use is needed. The referencing of Chapter 19 of NFPA 99 is the starting point.

The committee also discussed the referencing of NFPA 53, Guide on Fire Hazards on Oxygen-Enriched Atmospheres. It was determined that the reference to NFPA 99 was adequate as NFPA 99 references one to NFPA 53 when appropriate. NUMBER OF COMMITTEE MFaMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #27~) Committee: SAF-FUR

101- 269 - (6-5, A-x-2.4.1.5): Accept SUBMITTER= Marcelo M. Hirschler, GBH Int'[, Inc. COMMENT ON PROPOSAL NO: 101-274 RECOMMENDATION: NFPA 286 should be allowed to remain referenced in NFPA 101, as proposed by the NFPA 101 SAF-FUR Technical Committee. SUBSTANTIATION: This comment is just a clarification related to the TCC (Technical Correlating Committee on Safety to Life, SAF-AAC) Note: TCC states that NFPA 286 is in the Spring 2000 Meeting Cycle, but that is incorrect: NFPA 286 is in the Fall 1999 Meeting, together with NFPA 101. In consequence it is fully appropriate for NFPA 286 to be referenced in the 2000 edition of the NFPA 101, Life Safety Code, as the), are both in the same cycle. If NFPA 286 were to fail (or be bumped to a later cyde) it can later be taken out editorially, as is customarily done in such cases. In fact, the NFPA Fire Tests Committee will be meeting to address comments to NFPA 286just before the NFPA 101 Technical Committees meet, in 1999. COMMITTEE ACTION: Accept. COMMITTEE STATEMENT: The effect of accepting the comment is that no change will be made to wording in the ROP. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:

AFHRMATIVE: 13 NOT RETURNED: 2 Hogan, Lingenfelter


101- 270 - (6-5 and 6-6): Accept in Principle in Part SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-274 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUR give consideration to revisin~ x-2.$.$ Exception to clarify that heavy timber construcuon members are exempt from consideration. The wording currently proposed doesn ' t accomplish this as evidenced by SAF-AXM's rejection of Proposal 101-326 and SAF-END's rejection of Proposal 101-381 which were drafted by SAF-FU1L

Further, SAF-AAC directs that the public comment also request SAF-FUR to make revisions (to A-x-2.4.1.5 et al) so as to remove reference to NFPA 286. Proposed NFPA 286 is being processed via the year-2000 Spring Meeting cycle; it will not be available in time to be referenced by NFPA 101-2000 which is being processed via the 1999 Fall Meeting cycle. SUBSTANTIATION: See the above recommendation: COMMITFEE ACTION: Accept in Principle in Part.

See Committee Actions on Comment 101-269 (Log #273) and Comment 101-271 (Log #307). COMMITTEE STATEMENT: The actions on the referenced comments adequately address the subject. Reference to NFPA 286 is not being deleted because NFPA 286 is in the revision cycle for action at the Fall 1999 meeting. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:


154

N F P A 101 - - F 9 9 R O C

(Log #$07) Committee: SAF-FUR

101- 271 - (6-5, x-2.3 and x-2.4): Accept in Princiifle SUBMITTER= James IL Lathrop, Chemical Fabrtcs and Films Assn./Walicoverings Assn. C O M M E N T O N P R O P O S A L N O : 101-274, 101-277, 101-278, 101- 905 R E C O M M E N D A T I O N : Revise x-2.3 and x-2.4as follows:

x-2.$ Interior Wall or Ceiling Finish Testing and Classification. x-2.3.1 Interior wall or ceiling finish required elsewhere in this

Code to be Class A, Class B or Class C, shall be classified based on test results from NFPA 255, Standard Method of Test of Surface Burnings Characteristics of Building Materials.

Exception: Exnosed oortions of structural members comolvine with the reouire-ments for Tvoe IV(2HH~ construction oerNFP/k 220. Standard on TvDes of Bu-ilding Construction shall l~e exemDt from testing and classification reuuirements.

Exception: Any wall coverinL, s tested in accordance with NFPA ~05, Standard Methods of Fire-Tests for Evaluatin~ Room Fire Growth Contribution of Textile Wall Covering.

x-2.3.2" Products required to be tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, shall be grouped in the following classes in accordance with their flame spread and smoke development.

(a) Class A Interior Wall and Ceiling Finish. Flame spread 0-25; smoke development 0-450. Includes any material classified at 25 or less on the flame spread test scale and 450 or less on the smoke test scale. Any element thereof, when so tested, shall not continue to propagate fire.

(b) Class B Interior Wall and Ceiling Finish. Flame spread 26-75; smoke development 0-450. Includes any material dassified at more than 25 but no more than 75 on the flame spread test scale and 450 or less on the smoke test scale.

(c) Class C Interior Wall and Ceiling Finish. Flame spread 76-200; smoke development 0-450. Includes any material classified at more than 75 but no more than 200 on the flame spread test scale and 450 or less on the smoke test scale.

Exception: Existing interior finish shall be exempt from the smoke development criteria.

x-2.3.3 The classification of interior finish specified in x-2.3.2 shall be that of the basic material used by itself or in combination with other materials.

. . . . . . . . . . ~ . . . . . . . . . . . . . U~.?.., ,% . . . . . . . . . . . . . . . . v . . . . . . . .

x-2.3A Wherever the uses of Class G interior wall and ceiling finish is requirement, Glass A or B shall bepermit ted. Where Glass B interior wall and ceiling finish is required, Class A shall be permitted.

x-2.3.5 Products tested in accordance with NFPA 265. Standard Methods of Fire Tests for Evaluatin~ Room Fire Growth Contribution of Textile Wall Coverings. shall use a Product mounting system, includin~ adhesive, representative 9/" i~¢;¢gl ¢~¢, and shall-c0mDlv with the criteria of x-2.B.5.1 or x-2.~,~.2.

~ 2A.!.~.1" When using method A of the NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:

(a) Flame shall not spread to the ceiling during the 40-kW exposure, and

(b) During the 150-kW exposure the following criteria shall be met:

1. Flame shall not spread to the outer extremity of the sample on the 8 ft x 12 ft (2.4 m x 3.7 m) wall, and

2. The specimen shall not burn to the outer extremity of the 2 ft (0.6 m) wide samples mounted vertically in the comer of the r o o m , a n d

3. Burning droplets that are judged to be capable of igniting the textile wall .covering or that persist m burning fro $0 sec or more shall not be formed and dropped to the floor, and

4. Flashover shall not occur, and 5. The maximum instantaneous net peak rate of heat release

shall not exceed $00 kW (c~ The average OPtical density of smoke throughout the test

shall not exceed 0.07 m -1 x 2A.!.~.2" When using method B of the NFPA 265,

Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:

(a) Flame should not spread to the ceiling during the 40-kW exposure, and

(b) During the 150-kW exposure the following criteria shall be m e t :

1. Flame shall not spread to the outer extremities of the sample on the 8 ft x 12 ft (2.4 m x $.7 m) wall, and

2. Fiashover shall not occur. (q.) The average ontical density of smoke throughout the test

shall not exceed 0.22 m -1 x-2.4 Specific Materials. x-2.4.1 Textile Wall and Textile Ceiling Materials. The use of

textile materials on walls or ceilings shall be limited as specified in x-2.4.1.1 through x-2.4.1.5.

x-2.4.1.1 Textile material having a Class A rating (see x-2.$.2) shall be permitted on the walls or ceilings of rooms or ares protected by an approved, automatic sprinkler system.

x-2.4.1.2 Textile materials having a Class A rating (see x-2.3.2) shall be permitted on partitions that are not more than 3/4 of the floor-to-ceiling height nor more than 8 ft (2.4 m) in height, whichever is less.

x-2A.1.3 Textile materials having a Class A rating (see x-2.3.2) shall be permitted to extend up to 4 ft (1.2 m) above the finished floor on ceiling-height walls and ceiling-height partitions.

x-2.4.1.4 Previously approved, existing installations of textile material having a Class A rating (see x-2.3.2) shall be permitted to be continued to be used.

x-2.4.1.5" Textile materials shall be permitted on walls and partitions where tested in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, (see x-2.$.5L

^.;22 "-7"^L~; . . . . . . . . . . v . . . . . . . . . . . . . . ~, . . . . . . ~, . . . . . . . .

k & ^ ~ l - . ^ . 4 ~ ~ ' [ ~ . . ^ ' 1 " ^~* . . 17^_ E ' % ~ I . . ~ * : - - ~ 1D^ ^ ~ '1~':. e C - - ^ . . ~ ' I ~

t~.\~ ~, ~r~"':~.~ ~he !59 kW e::p~.~:rc ~hc . . . . . . . . ng . . . . . . . . . . . . . . .

x-2.4.2" Expanded Vinyl Wall Coverings. Expanded vinyl wall coverings shall comply with one of the following conditions:

(a) Materials having a Class A rating (see x-2.3.2) shall be permitted on the walls or ceilings of rooms or areas protected by an approved, automatic sprinkler system.

(b) Materials having a Class A rating (see x-2.3.2) shall be permitted on partitions that are not more than $/4 of the floor-to- ceiling height nor more than 8 ft (2.4 m) in height, whichever is less.

(c) Materials having a Class A rating (see x-2.3.3) shall be permitted un to 4 ft (1.2 m) above the finished floor on ceiling- height walls and ceiling-height partitions up tc ". ft (1.2 --~.,,, ~ , ~ " . . . . the ff~'=,hc~ ~c,c,.".

(d) Existing installations of materials with the appropriate wall finish classification for the occupancy involved with the classification in accordance with the provisions in x-2.$.2 shall be permitted to be continued to be used.

(e) Materials shall be permitted on walls and partitions where tested in accordance with NFPA 265. Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverings (see x-2.$.SL. ;;5"..hour requ:r'.~g :!--.~:~c^.:-e~ ".~

155


. . . . . . . . . . . . . . . . - - . . . . t " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . y . . . . . . . . . + ¢ . ~ . . : ~ . - : ~ ^ ~ . . o A 1 K I . . . . o A I ~ O

x-2.4.$ and subsequent paragraphs - no change. SUBSTANTIATION: Most of this comment is editorial, however, there are two technical changes. The first technical change is that the second exception added to x-2.$.1 is not limited to textiles and expanded vinyl vrall coverings. The other technical change is the addition of smoke limits to the "pass/fail" criteria when using NFPA 265.

Currently the Code has two types of interior wall finish that can be tested per NFPA 255 or NFPA 265. These are textiles and expanded vinyls. In fact the Code requires either Class A p e r NFPA 255 AND sprinkler protection or he tested per NFPA 265. As such, these materials can be used on walls in any building area of any occupancy.

The purpose of this proposal is to allow the option of evaluating all interior wall finishes via a room/corner test. ICBO, BOCA, SBCCI, and NFPA (as well as the proposed IBC) all recognize that products tested n accordance with NFPA 265 and meeting the acceptance criteria here are equivalent, ff not superior, to Class A when tested per NFPA 255. In addition, testing per NFPA 265 yields data that can be used in performance designs.

There is no reason not to let other wall coverings be tested per NFPA 265. It should be noted that NFPA 286 is currently bein~ developed and will be very similar to NFPA 265 but will add crtteria for testing interior ceiling finish. It is not the intent of this comment to allow NFPA 265 for interior ceiling finish. Currently BOCA, SBCCI, and NFPA 101, as well as the most recent draft of the proposed IBC, all recognize the use of NFPA 265 for wall coverings other than textiles.

The second technical change is to add smoke limits to the pass/fail criteria when using NFPA 265 testing. This was proposed by Proposal 101-277 and 101-278. Both CFFA and WA objected to these proposals since testing needed to be done to verify the calculations given by the submitter. Since the proposal time, both the original submitter of Proposals 101-277 and 101-278 as well as CFFA and WA have performed additional testing and evaluation. The numbers submitted herein are the same numbers that the

roponent of Proposal 101-277 and 101-278 has submitted to the C.

The following editorial changes are consistent with another submittal and are included herein for ease of correlation by the committee.

1. The exception for Type IV construction materials is moved from x-2.3.3 to x-2.3.2 with expanded wording to clarify the intent. This is at the request of Safety to Life Correlating Committee.

2. The concept of x-2.4.2 is moved to x-2.3.1 to clarify that it applies to both textiles and expanded vinyls when they are tested per NFPA 265. Testing per NFPA 255 is not needed when materials pass NFPA 265. The current draft is clear with regard to expanded vinyls but not for textiles. It is also somewhat hidden in its present location. This is further revised technically as described above.

3. The "pass-fail ~ criteria for NFPA 265 is moved to a new x-2.3.5.1 and x-2.3.5.2 so that it is not with a "specific material" but aPl~slies to any material that uses NFPA 265.

ing this arrangement all tests and all "pass-fail" or classifications a r e | n the x-2.$ section. When NFPA 255 is used the classification system is right there, if NFPA 265 is used the "pass- fail" criteria are right there with the test method. In addition, this will facilitate recognition of NFPA 286 during the next Code cycle by inserting it in x-2.$ as another test method. Since the "pass-fail" criteria will most likely he the same as NFPA 265 it is best to have it independent of a specific material. COMMITTEE ACTION: Accept in Principle.

Revise x-2.$ and x-2.4 as follows: x-2.$ Interior Wall or Ceiling Finish Testing and Classification. x-2.$.1 Interior wall or ceiling finish required elsewhere in this

Code to be Class A, Class B or Class C, shall be classified based on test results from NFPA 255, Standard Method of Test of Surface Burnings Characteristics of Building Materials.

Excention No. 1: Exnosed nortions of structural members comnlvin~ with the reouirements for Tvne IV(2HH~ construction ver ~¢PA~ 220. Standard on Tvoes of Building Construction shall be exemnt from tesfin~ and classification reouirements.

Exceotion No. 2: Interior wall finish testecf in accordance with NFPA -265. Standard Methods of Fire Tests for Evaluating RoQm Fire Growth Contribution of Textile Wall Coverings.

E~ccention No . ~,: Interior wall and ceilin~ finish tested in accordance with NFPA 286. Standard Methods of Fire Tests for

EvalualJn~ Room Fire Growth Contribution of Wall and Ceillt~z Interior ~nish.

x-2.3.2" Products required to be tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, shall be grouped in the following classes in accordance with their flame spread and smoke development.

(a) Class A Interior Wall and Ceiling Finish. Flame spread 0-25; smoke development 0-450. Includes any material classified at 25 or less on the flame spread test scale and 450 or less on the smoke test scale. Any element thereof, when so tested, shall not continue to propagate fire.

(b) Class B Interior Wall and Ceiling Finish. Flame spread 26- 75; smoke development 0-450. Includes any material classified at more than 25 but no more than 75 on the flame spread test scale and 450 or less on the smoke test scale.

(c) Class C Interior Wall and Ceiling Finish. Flame spread 76- 200; smoke development 0-450. Includes any material classified at more than 75 hut no more than 200 on the flame spread test scale and 450 or less on the smoke test scale.

Exception: Existing interior finish shall be exempt from the smoke development criteria.

x-2.3.3 The classification of interior finish specified in x-2.3.2 shall be that of the basic material used by itself or in combination with other materials.

. . . : ' . l . . ~1,. . . . . . . : . . . . . ~ . ~ ' ^ . " 1 " . ~ - - n r l c J l J L T ~ . . . . ~ . ~ : . . . . . ~ l q b ' l D A ,

¢ ) o n ~ - A ~ - - T . . . . . ~" D . . . ' I A : - - - - P ^ - - . * - - . . ~ : ~ - - - - - - - I _ _ _ . ~ L ~ r . . . . . . ' IY . . . . . . . . . . . ~ . . . . . . . . . . .

x-2.$.4 Wherever the uses of Class C interior wall and ceiling finish is requirement, Class A or B shall be permitted. Where Class B interior wall and ceiling finish is required, Class A shall be permitted.

~1-2.$.5 Prgducts tested in accordance with NFPA 265. Standard blethods of Fire Tests for Evaluatin~ Room Fire Growth Ggntrib~l~Ol'/of Textile Wall Coverint, s. or NFPA 286. Standard Methods of Fire Tests for Evaluatin~ Room Fire Growth Ggntributi0rl of Wall and Ceilin~ Interior Finish. Products tested in accordance with NFPA 265 shall comnlv with the criteria of x- 2.3.5.1 or x-2.3.5.2. Products tested in accordance with NFPA 286 shall comniv with the criteria of x-2.~.5.2.

a 2A.!.~.I* When using method A of the NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:

(a) Flame shall not spread to the ceiling during the 40-kW exposure, and



2. The specimen shall not bum to the outer extremity of the 2 ft i (0.6 m) wide samples mounted vertically in the comer of the room, and

$. Burning droplets that are judged to be capable of igniting the textile wall covering or that persist in burning fro $0 sec or more shall not be formed and dropped to the floor, and


shall not exceed 300 kW (c) For new installations the average optical density of smoke

throughout the test shall not exceed 0.07/n-1 "- 2A.!.5.2" When using NFPA 286 or method B of the

NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:

(a) Flame should not spread to the ceiling during the 40-kW exposure, and


1. Flame shall not spread to the outer extremities of the sample on the 8 ft x 12 ft (2.4 m x ~.7 m) wall, and

2. Fiashover shall not occur. (c~ For new installations the average ontical density of smok:

throughout the test shall not exceed () .~-m q x-2.4 Specific Materials. x-2.4.1 Textile Wall and Textile Ceiling Materials. The use of

textile materials on walls or ceilings shall be limited as specified in x-2.4.1.1 through x-2.4.1.5.

x-2.4.1.1 Texdle material having a Class A rating (see x-2.$.2) shall be permitted on the walls or ceilings of rooms or areas protected by an approved, automatic sprinkler system.

x-2.4.1.2 Textile materials having a Class A raung (see x-2.$.2) shall be permitted on partitions that are not more than $/4 of the

156

N F P A 101 - - F 9 9 R O C

floor-to-ceiling height nor more than 8 ft (2.4 m) in height, whichever is less.

x-2.4.1.3 Textile materials having a Class A rating (see x-2.3.2) shall be permitted to extend up to 4 ft (1.2 m) above the finished floor on ceiling-height walls and ceiling-height partitions.

x-2.4.1.4 Previously approved, existing installations of textile material having a Class A rating (see x-2.3.2) shall be permitted to be continued to be used.

x-2.4.1.5" Textile materials shall be permitted on wails and partitions where tested in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, or NFPA 286. Standard Method~ of Fire Tests for Evaluatlnz Room Fire Growth Contribution of Wall and Ceiling Interior Finish (see x-2.3.5L

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x-2.4.2" Expanded Viny l Wall Coverings. Expanded vinyl wall coverings shall comply wi th one o f the fo l l ow ing condi t ions:

(a) Mater ia ls hav ing a Class A ra t ing (see x-2.3.2) shall be permi t ted on the walls o r ceil ings o f rooms or areas pro tec ted by an approved, automat ic spr ink le r system.

(b) Mater ia ls hav ing a Class A rat ing (see x-2.3.2) shall be permitted on partitions that are not more than 3/4 of the floor-to- ceiling height nor more than 8 ft (2.4 m) in height, whichever is less.

(c) Materials having a Class A rating (see x-2.3.3) shall be I permitted up to 4 ft (1.2 m~ above the finished floor on ceiling- . height walls and ceiling-height partitions up to. ~ ft ~`..° -.-~--~ -~.~ t̂" . . . .

(d) Existing installations of materials with the appropriate wall finish classification for the occupancy involved with the classification in accordance with the provisions in x-2.3.2 shall be permitted to be continued to be used.

(e) Materials shall be permitted on walls and partitions where tested in accordance with NFPA 265. Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Wall Coverint, s or ~zPA 286. Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Wall and Ceilin~ Interior Finish (see x-2.3.5),, "+ + " " -f^--:=-- ' :~- ~,. ~hc.:=. :cqu:::==g . . . . . . . . . . . "n =.cc=,:d=nz: ;',-+& -.;. 2.~.~ ~:c,'-~cd +&c t:x+dtc m-~c~-~ zc, mpl':= ":-'&

x-2.4.3 and subsequent paragraphs - no change. COMMITTEE STATEMENT: The Committee Action does everything the commenter requested and additionally expands the use of NFPA 286. See Comment 101-269 (Log #273). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 10 NEGATIVE: 2 ABSTENTION: 1 NOT RETURNED: 2 Hogan, Lingenfelter

EXPLANATION OF NEGATIVE: ADAIR: There is no assurance that the other materials have

burning characteristics comparable to textile wall coverings. Many more test data need to be available before a proper decision can be made. Furthermore, one table included in the argument indicates that an obscuration of 0.22/m corresponds to a limit of visibility of 13 ft. What is the reason for choosing this measurement?

This action by the committee should be reversed until such time as more data are available to indicate the limits selected make any sense.

BABRAUSKAS: I do not support the proposal for inserting smoke limits, based on the following reasoning:

I do not believe in the concept that individuals are going to be injured from ~ fires of extremely low heat release rate simply through smoke obscuration alone. There are no credible experimental data to support such a view, and none has been put forth with the proposal.

The measurements in the NFPA 265 test duct reflect the smoke concentration in the upper gas layer (with only a small dilution due to entrainment outside the doorway). Americans have now been pretty universally trained by NFPA's educational programs that you drop to the floor when confronted with smoke, you don't walk with your nose high in the air. The proposed scheme in no way reflects that the occupants will be in the lower, unvitiated gas layer and not in the smoke layer. Remember:. if the HRR is such that flashover has occurred, then of course the layer will drop to the floor, but then the product will be failed on HRR alone and smoke is irrelevant.

The test method in question is one where the smoke is being measured which is that of the upper hot gas layer of the room of fire orion, as measured from a very small test room. It may be reasonable to suppose that the smoke will then fill a corridor. With sufficient stirring, smoke will also come down low. But the needed calculations, modeling, or tests to assess the dilution that takes place in this realistic situation have not been put forth. COMMENT ON AFFIRMATIVE:

CLARKE: Delete last 8 words of proposed new text in x-2.3.1, Exception No. 1, so it reads:

Excention No. 1: Exnosed nortions of structural members t;gmplying with the reouirements of Twe IV (2HH~ construction her NFPA 220. Standard on Types of B-uilding Construction. - It is pleonastic to indude the phrase "...shall be exempt from testing and classification requirements." EXPLANATION OF ABSTENTION:

HIRSCHLER: I abstain on this comment because I have a potential client interest on the issue.


101- 272 - (6-5.1.2): Reject SUBMITrER: Richard P. Thornberry, Business Institutional Furniture Manufacturers COMMENT ON PROPOSAL NO: 101-276 RECOMMENDATION: Reject the commitlee action and accept the original proposal or leave the existing text as is. SUBSTANTIATION: The proposed new Exception to 6-5.1.4 will still require testing of thin materials (less than 1/28 in. thick) in accordance with NFPA 255 to determine a Class A rating. The intent of the present Exception to 6-5.1.2 was to allow small scale testing such as NFPA 264 to determine the comparable flammability to paper of such thin materials which is a more economical approach without sacrifldng, fire safety.

Presently, none of the three model budding codes requires any flammability testing of interior finish materials less than 1/28 in. thick. So accepting the original proposal would be consistent with those codes.

In any case, requiring the thin materials to be tes tedper NFPA 255 to determine a Class A rating has not been jnst if iedand will be a significant economic burden to BIFMA's members. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: See Committee Statement for the action taken in the ROP on Proposal 101-276. There are known cases where thin materials have created a real flame spread problem. The commenter has not submitted adequate substantiation to accept the comment. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:


157

N F P A 101 - - F 9 9 R O C

EXPLANATION OF NEGATIVE: BABRAUSKAS: I believe the issue should be studied more

carefully, as I have said in my suggestion for IBC 2000. Research at Warrington Fire Research Centre has shown that with some paints applied in multiple layers significant hazard (i.e., recorded fire deaths) have occurredwith thicknesses as little as 0.5 mm (0.019 in.). Reference: Murrell, J. M., and Rawiins, P., Fire Hazard of Multilayer Paint Surfaces, pp. 329-338 in Proc. 4th International Fire and Materials Conference, Interscience Communications Ltd., London (1995). In addition to addressing the hazard, I believe that unnecessary burden should be avoided. Consequently, if there are any general classes of material (e.g., maybe PVC coatings?) where thicker layers can be allowed without need of individual testing, then a strategy should be taken which differentiates product types. Thus, I believe the item should be held over to the next cycle in active development, along the fines I have suggested. EXPLANATION OF ABSTENTION:



101- 273 - (6-5.1.2 Exception): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-276 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUR revise the proposed Exception to 6-5.1.4 so as to combine subparts (a) and (b) into one sentence that is more understandable. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Reword the Exception to x-2.1 to read: "...simulating actual installation if they meet the requirements of

Class A interior wall or ceiling finish when tested in accordance with x-2.$.1 using inorganic reinforced cement board as the substrate material." COMMITTEE STATEMENT: The Committee Acdon should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12 ABSTENTION: 1 NOT RETURNED: 2 Hogan, Lingenfelter

EXPLANATION OF ABSTENTION: HIRSCHLER: I abstain on this comment because I have a

potential client interest on the issue.


101- 274 - (6-5.$.1.5.1 and 6-5.3.1.5.2): Accept in Principle SUBMIT]TA~ Marcel. M. Hirschler, GBH Int'l, Inc. COMMENT ON PROPOSAL NO: 101-277 RECOMMENDATION: Revise the requirements for textile wall coverings, as follows:

6-5.$.1.5.1 When using Method A of the NFPA 265, Standard Fire Test for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:

(a) Flame shall not spread to the ceiling during the 40 kW exposure, and

(b) During the 150 kW exposure, the following criteria shall be m e t :

1. Flame shall not spread to the outer extremity of the sample on the 8 ft x 12 ft (2.4 m x $.6 m) wall, and

2. The specimen shall not burn to the outer extremity of the 2 ft (0.6 m) wide samples mounted vertically in the corner of the room, and

$. Burning droplets that are judged to be capable of igniting the textile wall covering or that persist in burning for 30 sec or more shall not be formed and dropped to the floor, and


shall not exceed 300 kW, and (c~ The average ootical density of smoke throughout the NFPA

265 test shall not exceed 0.07 m -1. 6-5.3.1.5.2 When using Method B of the NFPA 265, Standard Fire

Test for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:


(b) During the 150 kW exposure, the following criteria shall be met:

1. Flame shall not spread m the outer extremities of the sample on the 8 f t x 12 ft (2.4 m x 3.7 m) wall, and

2. Flashover shall not occur, and ~cl The average ontical densitv of smoke throut, hout the NFPA

265 test shall not exceed 0.22 m -1. SUBSTANTIATION: Interior finish materials have always been reouired to meet both flame snread and smoke ohscuratiorl

This comment is identical in concept and pass/fail criteria to what has been proposed to the International Building Code and the International Fire Code and accepted by the committee at the March 1999 hearings. This differs from the original proposal in that the concerns of the technical committee were considered. In consequence a series of room-corner fire tests on 10 different construction materials was undertaken. The results suggested the logical pass-fail criteria.

The reason for this requirement is that it is known that if excessive smoke is released, this may hinder escape or rescue, through lack of visibility, and trap occupants inside a burning building. The way in which this has long been recognized in NFPA 101, Life Safety Code, and in the building codes, is by requiring that interior wall and ceiling finish materials be classified in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, the Steiner tunnel test, where they must meet flame spread requirements as well as a smoke developed index requirement of no more than 450. In fact, such a requirement is still included in Section 6-5.5 of the Life Safety Code, as well as in Section 805.1 of the Final Draft of the International Building Code and in Section 806.2 of the Final Draft of the International Fire Code.

In the late 1980s it was discovered, by conducting full scale room/corner fire test research, that the flame spread indices produced by the Steiner tunnel test, ASTM E84, may not reliably

edict all aspects of the fire behavior of wall coverings. Therefore, 265, Standard Fire Test for Evaluating Room Fire Growth

Contribution of Textile Wall Coverings, was developed, as a test that uses a reasonable sized ignition source to show that the material will not spread fire to involve objects remote from the area of origin, and that the textile product will not generate sufficient energy to cause the room of origin to flash,vet. However, when the test method was originallydeveloped it did not include smoke obscuration measurements. The latest edition of NFPA 265 now incorporates smoke obscuration measurements and therefore the omission can now be rectified. The smoke obscuration requirement for NFPA 255 is a smoke developed index (SDI) of 450. Unfortunately, SDI or smoke developed index cannot be assessed directly with a test other than the Steiner tunnel. Therefore, the SDI must be converted into other units that are universal. The SDI is calculated by measuring the optical density of the material under test and calculating the area under the curve of optical density versus time.

It has now become clear that building material can have low flame spread and heat release but high smoke obscuration. Heat release is by far the more important characteristic in terms of fire hazard. However, some materials may exhibit adequate heat release characteristics and still have undesirable smoke release. Table 1 shows a set of 10 commercial building materials tested in the NFPA 265 room-corner test and in the ASTM E84 Steiner tunnel tesL These results were taken from the paper "Heat and Smoke Measurements of Construction Materials Tested in a Room- Corner Configuration According to NFPA 205", by Marcel. M. Hirschler and Marc L. Janssens. The materials were chosen to be representative of those with good fire performance: the highest one of them (varnished pine planks) had a flame spread index value of 70, while all other values were less than $0. Moreover, almost all the materials had relatively low smoke developed indices: Table 1 shows that 6 materials had SDI under 50 and 9 had SDI under 450. However, one material didn' t meet the 450 requirement for SDI, while having very low flame spread index (10). That same material produced a very high optical density (an average of 0.205 m a, much higher than anything else), when tested in the NFPA 265 room- corner test, while giving very low heat release.

Therefore, since the use of the NFPA 265 room-corner test method has become mandatory for textile wall coverings, as shown in :~ection 6-5.$.1.5 of the Life Safety Code and in Section 805.5.1 of the Final Draft of the International Building Code and Section 806.2.2 of the Final Draft of the International Fire Code, and for expanded vinyl wall coverings (see Section 6-5.3.5.1 of the Life Safety Code and Section 803.6 of the Final Draft of the

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N F P A 101 - - F 9 9 R O C

Table 1 Major Test Results for Building Materials Tested in NFPA 265 Material Pk RHR Av OD Av RSR Pk RSR E84 SDI

(kW) (m "i) (m s s") (m s s a) - Ceiling Tile 22 0.063 0.18 0.$ 0 FR Composite Panel 128 0.088 0.50 0.6 15 Mineral Wool 35 0.066 0.19 0.3 0 Phenolic Foam 153 0.060 0.20 0.4 0 Pine: Flashover* 1460 0.120 0.61 8.5 105 Polyimide Foam 40 0.071 0.21 0.4 0 Textile Wailcovering, on Calcium 109 0.037 0.15 0.$ 10

Silicate Board Thermoplastic Sheet 40 0.295 1A0 7.0 1000 Expanded Vinyl Wallcovering, on 359 0.160 0.74 8.9 120

ypsum Board Commercial Vinyl Wallcovering, on 126 0.169 0.65 4.5 80

G}spsum Board *This material went to flashover at 348 seconds

Table 2 Tenability Values Proposed for Smoke Visibility OD

fit) ~om.~ T. j i n (for people familiar with the environment): 13 T .J in (for people unfamiliar with the environment): 42 0.06 D. Rasbash: 33 0.08 V. Babrauskas: 6 0,52 D. Purser (based on irritancy): 6 0~52 Notes: T. Jin, "Studies of Emotional Instability in Smoke from Fires", J. Fire Flammability, 12. 130-142 (1981). D.J. Rasbash, ~Sensitivity Criteria for Detectors Used to Protect Life', Fire International, No. 49, pp. 30-44, Sept. (1975). V. Babrauskas Technical Note 1103, Natl Bur. Stds, Gaithersburg, MD, 1979. D.A. Purser, ~'l'oxicity Assessment of Combustion Products", Section 2 Chapter 8, in SFPE Handbook of Fire Protection Engineering, 2nd Edn, P.J. DiNenno et al eds, NFPA, Quincy, MA 1995, pp 2-85--2-146.

International Building Code) and is also starting to be used for other materials (such as vinyl waiicoverings), it is critical that building materials should not be allowed to use the room-corner test as a way of "passing" a test when they would have failed the smoke requirement in the Steiner tunnel test.

This problem of materials with high smoke release and low heat release is not restricted to the USA. A publication from Sweden (B. Ostman, L. Tsantaridis, J. Stensaas and PJ. Horde, "Smoke Production in the Cone Calorimeter and the Room Fire Test for Surface Products - Correlation Studies", Tratek (Swedish Inst. Wood Technology Research) Report, I 9208053, Stockholm, Sweden, June 1992) presents data on 28 building materials tested in Europe using the European version of the room corner test, ISO 9705. These data also show the same pattern as the tests conducted in the USA: usually, but not always, high smoke obscuration occurs with materials causing early flashover. In fact, in that series, 14 building materials cause early flashover and high smoke obscuration, 11 building materials have late (or no) flashover and low smoke obscuration, but 2 of the 28 building materials exhibit very high smoke obscuration and do not cause flashover to occur, at least until the ignition source is raised to 300 kW. It is this last group of materials, which are undesirable, which this proposal is addressing. Such materials, including wallcoverings, would not be accepted if they had to be tested using the ASTM E84 Steiner tunnel test, because of their high smoke development, and should similarly be excluded when testing with the room-comer test.

A fact-finding investigation was therefore made to assess the logical threshold criterion for smoke obscuration testing. Several authors have proposed smoke tenability limits as survival criteria. Smoke tenability limits have been measured based on the needed visibility to permit escape and prevent disorientation and, in one case, on the irritancy inherent in smoke. The idea is to allow people present in a fire situation to see far enough that they can escape the fire before being overcome by the effects, of heat or toxicity (or before their eyes become so irritated by smoke that they can no longer see properly). This is usually expressed in terms of visibility distances (in feet or meters), which can then be easily converted to optical density. Table 2 shows the values that have been proposed for smoke tenability limits, with proposed visibilitl/ ranging from 2 m (6 ft) to 13 m (42 ft). Those values need to be taken into account when developing smoke obscuration requirements.

Comparing the actual fire test results obtained, in Table 1, with the results of the fire safety analysis, in Table 2, it appears that a threshold of 6 ft visibility is too mild, while a threshold of 35 ft visibility appears too severe. In consequence, a visibility threshold of 4 m (13ft) appears to be reasonable, and in tune with the experimental observations that people familiar with the environment can escape easily with that type of smoke obscuration. This means requiring that people can adequately see exits located 13 ft away. Thus, this would usually allow people in a fire situation to see the exits (at least in small rooms), or otherwise see the exit signs (in larger rooms). This visibility threshold requirement can be expressed in terms of properties measured in the room comer test, NFPA 265, namely average optical density, a property often used for smoke requirements. Thus, a requirement of an average optical density of 0.22 m 1, for the NFPA 265 room-comer test (Protocol B, with 3 room walls fully lined), would help ensure safety from smoke obscuration. This requirement would be met by almost all materials which do not cause room flashover, as is clear by the data presented in Table 1 and in the Hgure.

This requirement is also consistent with the requirement laid out by the International Maritime Organization (IMO) for testing interior finish materials using the European /SO 9705 room-comer test. The maritime requirement is a maximum average rate of smoke release of 1.4 mZ/s, with a more severe test [ 'Standard for Qualifying Marine Materials for High Speed Craft as Fire Restricting Materials", IMO Resolution MSC.40 (64) (December 5, 1994), International Maritime Organization, London, UK.)].

When testing is conducted using the NFPA 265 screening test (Protocol A), the heat release requirement (namely $00 kW) is 30 percent of the requirement for the full room (namely 1,000 kW, or flashover). Therefore, it is logical to make the smoke obscuration

2 requirements. In this protocol, 64 ft of wall surface is lined with 2 the material being tested, while 256 ft (4 times as much) of wall

surface is lined in protocol B, but the area lined is the area most likely to be involved in the fire, since it is in the immediate vicinity of the ignition source. Therefore, it is logical to require that the smoke release also not exceed $0 percent of the smoke release requirements of the fully lined room, and a maximum average optical density requirement of 0.07 m "1 is being proposed.

Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE ACTION: Accept in Principle.

I Revise the requirements for textile wall coverings, as follows:

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N F P A 101 ~ F 9 9 R O C

6-5.3.1.5.1 When using Method A of the NFPA 265, Standard Fire Test for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:




2. The specimen shall not burn to the outer extremity of the 2 ft (0.6 m) wide samples mounted vertically in the comer of the room, and

3. Burning droplets that are judged to be capable of igniting the textile wall covering or that persist in burning for 30 sec or more shall not be formed and dropped to the floor, and


shall not exceed 300 kW, and (c) For new installations the average ootical density of smoke

throughout the NFPA 265 test shall not exceed 0.07 m -1. 6-5.3.1.5.2 When using Method B of the NFPA 265, Standard Fire

Test for Evaluating Room Fire Growth Contribution of Textile Wall Coverings, test protocol:



1. Flame shall not spread to the outer extremities of the sample on the 8 ft x 12 ft (2.4 m x 3.7 m) wall, and

2. Flashover shall not occur, and (c~ For ngw installations the average ontical density of smoke

throughout the NFPA 265 test shall not exceed 0.22 m q . COMMITI'EE STATEMENT: The new requirement should be limited to application to new installations. Existing installations need to remain exempt from the new requirement. The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ADAIR: There is no assurance that the other materials have

burning characteristics comparable to textile wall coverings. Many more test data need to be available before a proper decision can be made. Furthermore, one table included in the argument indicates that an obscuration of 0.22/m corresponds to a limit of visibility of 13 ft. What is the reason for choosing this measurement?

This action by the committee should be reversed until such time as more data are available to indicate the limits selected make any sense. EXPLANATION OF ABSTENTION:



101- 275 - (6-5.3.5.1(e)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-279 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUR correct the language by deleting the word "textile" because the paragraph applies to expandedvinyi wall covering materials. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

See Comment 101-271 (Log #307) which corrects the problem. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12 ABSTENTION: 1 NOT RETURNED: 2 Hogan, Lingenfelter

EXPLANATION OF ABSTENTION: HIRSCHLER: I abstain on this comment because I have a

potential client interest on the issue.


101- 276 - (6-5.4.1): Accept in Principle SUBMrITER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-281 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUR give consideration to revising its acdon to clarify further its intent. The proposed wording of 6-524.1 does not fully accomplish the intent. For example, where an occupancy chapter states that interior wall and ceiling finish needs to have a Class A or Class B rating, but the matenal in question is a textile wall covering, then one is permitted to use the special provisions of 6-5 in lieu of NFPA 255. Thus, the wording of 6-5.4.1 is not always correct. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Comment 101-271 (Log #307) which corrects the problem. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


(Log #326) Committee: SAF-FU R

101- 277 - (6-6, x-l.2): Accept in Principle SUBMITTER: James K. Lathrop, Koffei Assoc., Inc. COMMENT ON PROPOSAL NO: 101-285 RECOMMENDATION: Revise definition of "Contents and Furnishings" in x-1.2 as follows:

Contents and Furnishings. Any movable objects in a building that normally are not secured or otherwise put in place for functional reasons, excluding the following:

(a) Parts of the internal structure of the building; and (b) Any items meeting the definition of interior finish.

SUBSTANTIATION: There appears to be something wrong with the definition for contents and furnishings. The addition of "not" does not totally fix it but will bring the problem to the committee's attention. COMMITrEE ACTION: Accept in Prindple.

] Revise the definition of ~Contents and Furnishings" to read: [ Contents and Furnishings. Objects, goods, or products placed I inside a structure for functional, operational or decorative reasons, [ excluding parts of the building structure, building service

equi~Ementment and items meeting the definition of interior finish I . . . "

CoMMrlffEE STATEMENT: The Commmee Acaon retmns a definition but revises it for clarity. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:



101- 278 - (6-6 Contents and Furnishings): Reject SUBMITTER: Richard P. Thomberry, Business Institutional Furniture Manufacturers COMMENT ON PROPOSAL NO: 101-285 RECOMMENDATION: Reject the proposal and delete the

g roposed definition for "Contents and Furnishings". UBSTANTIATION: The proposed definition for "Contents and

Furnishings" is very confusing and ambiguous. It would be preferable not to have any definition rather than the one proposed which may actually cause moreA~roblems interpreting what contents and furnishings are. The definition may be suitable for NFPA 555 but not for NFPA 101 which is adopted as a code and enforced by building and fire officials throughout the country.

For example, is a ceiling fan or hanging light fixture included by the proposed definition? What about a television set or stereo? How about a table? The list is endless. Why is it necessary to have a definition if the text of the requirements is clear? No justification has been given for the need for the definition. Have there been any

~ pi.~lication or interpretation problems with the present Section

COMMITTEE ACTION" Reject. CoMMrlTEE STATEMENT: See Comment 101-277 (Log #326) which revises the definition. A definition is still needed. NUMBER OF COMMYITEE MEMBERS ELIGIBLE TO VOTE: 15

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N F P A 101 - - F 9 9 R O C

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 13 NOT RETURNED: 2 Hogan, Lingenfelter

(Log #341b) Committee: SAF-BSF

101- 279 - (Chapter 7): Hold SUBMYIffER: Peter W. Szerlag, Arlington, MA COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: I do not know where these two items might fit into NFPA 101. [Note: This comment has been assigned to SAF-FUN, SAF-FIR, SAF-BSF and SAF-IND.]


2. Every high rise building shall have smoke exhaust equipment on every floor (above the seventh floor) which can be remotely activated by the fire department via radio remote control. SUBSTANTIATION: Item 1 - self evident

Item 2 - This item mirrors the recent FAA allowance of fire detection and fire suppression systems on planes which are interconnected via spread spectrum radio links. COMMITTEE ACTION: Hold. COMMITI'EE STATEMENT: The recommendation introduces material that has not had public review. As such, it must be held for processing during the next revision cycle. However, SAF-BSF committee offers the following comments for assistance in directing the submitter's recommendation for the year 2003 edition.

There is no technical substantiation to support the need for these changes.

The substantiation based on an FAA allowance is not sufficient evidence for the application of Item #2 to high-rise buildings. This issue would be more appropriately handled in Chapter 32. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14

(Log #CC200) Committee: SAF-BSF

101- 280 - (7-6.1.3, 7-6.1.9, 7-6.2.1, 7-6.5.2): Accept SUBMITTER: Technical Committee on Building Service and Fire Protection Equipment COMMENT ON PROPOSAL NO: 101-329 RECOMMENDATION: Replace the term "protective signaling and control system" with "fire alarm system". SUBSTANTIATION: "Protective signaling and control system" is no longer used by NFPA 72. The appropriate reference is a "fire alarm system". COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14

(Log #157) Committee: SAF-BSF

101- 281 - (7-7.1.5 and Exception): Reject SUBMITTERa Terry A. Brouwer, Waterford, CT COMMENT ON PROPOSAL NO: 101-298 RECOMMENDATION: Accept the proposal. SUBSTANTIATION: NFPA 20 only requires a secondary power supply to a fire pump when the electrical power is not supplied by a reliable utility, thus a back up power supply is almost never needed. Further, the provisions of Article 700 of NFPA 70 only apply to those emergency systems deemed "legally required" by some other code or authority.

As such the Life Safety Code must designate the electrical fire pump as a legally required emergency system which needs a back up power supply. This proposal limits the number of electrical fire pumps which would require emergency power. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: NFPA 20 does not assume that utilities are reliable; that is up to the authority having jurisdiction. If the system is required by NFPA 101, or by local law or variance, the electric motor driven pump would come under the definition of a legally required system under NFPA 70 Ardde 700-1.

If not, the system still must meet the system !mpalrment requirements in NFPA 25. Under this scenario a back up power supply is only one way to maintain the system in operation. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITFEE ACTION:

AFFIRMATIVE: 14


101- 282 - (7-7.3.2): Accept in Principle SUBMITTER: Terry A. Brouwer, W~tterford, CT COMMENT ON PROPOSAL NO: 101-301 RECOMMENDATION: Delete the first sentence of Section 7-7.3.2. SUBSTANTIATION: Based upon the Committee's Statement in rejecting the proposal, the requirements of Section 7-7.3.1 apply to required systems and 7-7.3.2 apply to non-required systems. To maintain consistency, the first sentence of Section 7-7.3.2 should be deleted as it deals with systems installed in lieu of a required automatic sprinkler system. A system installed in lieu of a required sprinkler system would become a required system and thus subject to the requirements of Section 7-7.3.1, not 7-7.3.2. COMMITTEE ACTION: Accept in Principle.

Delete the last sentence of 7-7.3.1. Revise 7-7.3.2 as follows: 7-7.3.2 In no;;" ".~--.2.~=fi~n, ff the extinguishing system is

installed in lieu of a required supervised, automatic sprinkler system, the activation of the extinguishing system shall activate the building fire alarm system.if provided The actuation of an extinguishing system that is not installed in lieu of a required supervised, automatic sprinkler system shall be indicated at the building fire alarm system, if provided. COMMITTEE STATEMENT: The first part of the Committee Action acknowledges that the submitter of Proposal 101-301 was correct. The second part of the Committee Action further darifies the committee's intent regarding when a system is required to activate the building fire alarm system. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON CO M1TIT~ ACTION:

AFFIRMATIVE: 14

(Log #329) Committee: SAF-AXM

101- 283 - (Chapters 8, 9, 32): Reject SUBMITrER: James 1L Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-16, 101-312, 101-315, 101- 332, 101-339, 101-340, 101-343, 101-880, 101-881, 101-882 RECOMMENDATION: Reject Proposals 101-16, 101-312, 101-313, 101-332, 101-339, 101-340, 101-343, 101-880, 101-881, and 101-882. SUBSTANTIATION: Withdrawing NFPA 102 is a major mistake. See Comment 102-1. The negative on Proposal 102-1 by SuRer should be taken very seriously. If SAF-AXM wants some of the material from NFPA 102 in NFPA 101 then decide that item by item and justify it but do not make wholesale transfer from NFPA 102 to NFPA 101. I realize this will not be well received by the committee due to all the work they have done on this, but it is critical that NFPA 102 not be withdrawn. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: NFPA 102 is being deleted. See Comment 102-1 (Log #1) which the SAF-AXM committee rejected so as to move forward with the withdrawal of NFPA 102. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 20 NEGATIVE: 1 NOT RETURNED: 2 Cich, Conner

EXPLANATION OF NEGATIVE: SUTTER: This is in support of my negative vote on this item. I

certainly agree with the submitter that NFPA 102 should be

~ reserved. I feel that the interests of the users of this document are eing poorly met by its incorporation into NFPA 101. NFPA 102 had lonl~ been regarded as the authority on the design,

construction, operaUon, and maintenance of folding and telescoping seating and bleachers and grandstands. At one time, it incorporated everything from design loads to egress requirements. It dealt with safety to life in relation to fire, storm, collapse and crowd behavior. Anyone having questions concerning equipment covered by this standard could turn to it and find his answers. It had been a compact document, concise and to the point. To my mind, trouble started when the sections dealing with means of egress were eliminated from the 1992 edition. The intention of Proposal 102-1 (Log #CP1) is to dismantle totally NFPA 102, entrust the structural provisions to the model codes, and spread the remainder through the Life Safety Code, in spite of the fact that the Life Safety Code specifically deals only with safety from fire. In my opinion, the results of dismantling NFPA 102 will be:

-Elimination of a valuable design and operating tool for those involved with bleachers, grandstands andfo ld ing telescopic seating.

-Introduction of a labyrinth of rules and regulations through which the designers, builders and operators of this specific type of

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N F P A 101 - - F99 R O C

equipment must wade before being able to collect all the data per t inent to their l~rojects.

-Or (heaven forbldl) discontinued use of 101, and more heavily reliance on the model building code.

One of the dangers of being on a committee such as NFPA 101 and having intimate knowledge of the document with which one works is the possibility of believing that the document is a goal in itself. Equally important is the usability of the document. I believe that the pragmatic approach of handling the subject matter of NFPA 102 by discarding some and dispersing the rest among the various chapters of NFPA 101 serves more the purposes of the committee than the needs of the people trying to design, build, and operate by it. Rather, than incorporating parts of NFPA 102 into NFPA 101 and dispensing with NFPA once and for all, as the actions of the committee are designed to do. I would recommend that consideration be given to restoring it to its pre-1992 scope and content. The public would be better served.


101- 284 - (8-1.2.6, 9-1.2.6 (New)): Accept SUBMITTER: James P,. Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-751,101-310 RECOMMENDATION: Add a new 8-1.2.6 and 9-1.2.6 to read:

8-1.2.6 Assembly and Mercantile Occut)ancies in Covered Mall Buildings. The vrovisions of Chanter 8 shall aridly to the assembly occunancv tenant svace. The orovisions of 24.4.-4shall be nermitted to be used outside the assembly occuvancv tenant soace. - 9-1.2.6 Assembly and Mercantile Occuvancies-in Covered M-all Buildings. The provisions of Chapter 9 shall apply to the ~,~fIBl?|y occut)ancv tenant st)ace. The nrovisions of 25-4.4 shall be uermitted to be used outside the assembly occut)ancv tenant st)ace. SUBSTANTIATION: I served as Chair of the Life S~fety Covered Malls Task Group that was convened by the Technical Correlating Committee on Safety to Life. Task group participants, and the life safety technical committees represented by the participants, at the December 1998 meeting included myselfhJim Quiter (SAF-AAC), J im Antell (SAF-HEA), Carl Baldassarra (SAF-RES), Grog Miller (SAF-AXM), Ed Schultz (SAF-MER), Cathy Stashak (SAF-END), Grog Thomas (SAF-IND), and Bill Hiotaky (former chair of SAF- MER). This proposal was drafted by the task group.

See the comment on Proposal 101-751 (on 24-4.4.1 and 25-4.4.1) submitted by the task group in Chair J im Quiter's name. It recommends acceptance of part of Proposal 101-751 submitted by SAF-AXM. The addition of a new 8-1.2.6 and 9-1.2.6 helps complete the paper trail needed to assist the user in applying Code requirements where assembly occupancies are located in a covered mall building.

The action by SAF-AXM on Proposal 101-310 on 8-1.6 Exception and 9-1.6 Exception (which exempts the building construction recluirements for assembly occupancies within covered mall braidings in accordance with 244.4/25-4.4), is appropriate and should be retained. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:


C (Log #CC251)

ommittee: SAF-AXM 101- 285 - (8-1.3 Life Safety Evaluation and 9-1.3 Life Safety Evaluation): Accept SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-333 RECOMMENDATION: Delete the Appendix items A-8-1.3 Life Safety Evaluation and A-9-1.$ Life Safety Evaluation. SUBSTANTIATION: The current Appendix note repeats the definition that appears in the body of the Code. As such, it can be deleted. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITrEE ACTION:



101- 286 - (8-1.6 Exceptions and 9-1.6 Exceptions (New)): Accept in Principle

I TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the refereneed paragraph numbers be generalized to ~8-4.8 and 9-4.8 ~ rather than the numbers a8-4.8.3 and 9-4.8.$ ~ that Mr, Messersmith proposed. SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-313 RECOMMENDATION: The Technical Correlatin~ Committee on Safety to Life (SAF-AAC) requests that SAF-AXM gave consideration to Mr. Messersmith's comment on affirmative. Mr. Messersmith is correct based on the revisions being made by Proposal 101-339. It reads:

MESSERSMITH: In Exception No. 9 to 8-1.6 and 9-1.6, I believe that reference to 8-4.8.2 and 94.8.2 should be to 8-4.8.3 and 9-4.8.3 respectively. SUBSTANTIATION: See the above recommendation. COMMITIXE ACTION: Accept in Principle.

Fix the references as requested by Mr. Messersmith in his comment on affirmative. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMM1TI~E ACTION:


(LOg #47) Committee: SAF-MEA

101- 287 - (8-1.7, A-8-1.7 and A-5-3.1.2): Accept in Principle S U B ~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-314 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA review the portion of Proposal 101-314 applicable to A-5-3.1.2 for consistency with proposed Table 5-3.1.2 being created via Proposal 101-206. SUBSTANTIATION: See the above recommendation. COMMrlTEE ACTION: Accept in Prindple.

[ Retain acceptance of Proposal 101-314 as done by SAF-AXM. COMMITTEE STATEMENT: The SAF-MEA Committee has no objection to including the material. The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:



101- 288 - (8-1.7(3) and (k) (New), 9-1.7.1(3) and (k) (New)): Accept in Principle SUBMITI'ER: Technical Correlating Committee on Safety to Life COMMENT O N PROPOSAL NO: 101-316 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEA review Proposal 101-316 for consistency with proposed Table 5-3.1.2 being created via Proposal 101-206. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Prindple.

] Retain acceptance of Proposal 101-316 as done by SAF-AXM. COMMITFEE STATEMENT: The SAF-MEA Committee has no objection to including the material. The Committee Action should meet the submitter's intent. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITI'EE ACTION:


(Log #CC252) Committee: SAF-AXM

101- 289- (8-2.3.2, 8-4.1, 9-2.3.2, and 9-4.1): Accept SUBMITfER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-333 RECOMMENDATION: Revise as follows:

8-4.1.3 (9-4.1.3) Life safety evaluations shall include assessments of both building systems and management features upon which reliance is placed for the safety of facility occupants. Such asses.~ments shall consider scenarios annronriate to the facility.

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N F P A 1 0 1 - - F 9 9 R O C

In A-8-1.3 Life Safety Evaluation and A-9-1.3 Life Safety Evaluation, delete the second paragraph including subitems (a) through (h).

Delete all of A-8-2.3.2 and A-9-2.$.2. Add a new A-8-4.1.1 and A-9-4.1.1 to read:

A-8-4.1.1 (A-9-4.1.1) Life Safety Evaluations are examples of performance-based approaches to life safety. In this respect,

I significant guidance on the form and process of Life Safety Evaluations is provided by Ghapter $, Performance-Based Design, keeping in mind the firesafety emphasis in Ghapter $. The general approach to performance criteria, scenarios, evaluation, satety factors, documentation, maintenance and periodic assessment (including a warrant of fitness) all apply to the broader considerations in a Life Safety Evaluauon which deals not only with fire but with fire, storm, collapse, crowd behavior and other related safety considerations for which a checklist is provided in A-8-4.1.2/ A-9-4.1.2. Chapter 3 provides guidance, based on fire safety requirements, for a documented case to be made showing that products of combustion in all conceivable fire scenarios will not significantly endanger occupants using means of egress in the facility (for example, because of fire detection, automatic suppression, smoke control, large-volume space, or management procedures). Moreover, means of egress facilities plus facility management capabilities should be adequate to cope with scenarios where certain egress routes are blocked for some reason.

In addition to making realistic assumptions about the capabilities of persons in the facility (e.g., an assembled crowd including many disabled persons or persons unfamiliar with the facility), the life safety evaluation should include a factor of safety of at least 2.0 in all calculations relatin~ hazard development time and required egress time (the combination of flow time and other time needed to detect and assess an emergency condition, initiate egress, and move along the egress routes). This takes into account the possibility that half of the egress routes may not be used (or usable) in certain situations.

Regarding crowd behavior, the potential hazards created by larger masses of people and greater crowd densities (which can be problemauc during ingress, occupancy, and egress) demand that technology, going beyond fire protection engineering, be utilized by designers, managers, and authorities responsible for buildings based on the relaxed egress capacity provisions of Table 8-4.2.3. In very large buildings for assembly use, the hazard of crowd crushes can exceed that of fire or structural failure. Therefore, the building designers, managers, event planners, security personnel, police authorities, and fire authorities, as well as the building construction authorities, should understand the potential problems and solutions, including coordination of their activities. For crowd behavior, this understanding must include factors of space, energy, time, and information as well as specific crowd management techniques such as metering. Pubhshed guidance on these factors and techniques is found in the SFPE Handbook of Fire Protection Engineering, Section 3, Chapter 13, pp. 3-265 - - $-285 (Pauls, J., Movement of People) and in publications referenced therein.

Tables 8-2.$.2 and 8-4.2.3 are based on a linear relationship between number of seats and nominal flow time, with a minimum of 200 sec ($.3 rain) for 2000 seats plus 1 sec for every additional 50 seats up to 25,000. Beyond 25,000 total seats, the nominal flow time is limited to 660 sec (11 rain). Nominal flow time refers to the flow time for the most able group of patrons; some groups less familiar with the premises or less able groups may take longer to pass a point in the egress system. (Although three or more digits are noted in the tables, the resulting calculations should be assumed to provide only two significant figures of precision.)

Add a new A-8-4.1.3 and A-9-4.1.$ to read: A-8-4.1.3 (A-9-4.1.3) Factors to be considered in a Life Safety

Evaluation might include: (1) Nature of the Events Being Accommodated

Ingress, intra-event movement, and egress patterns Ticketing and seating policies/practices Event purpose (e.g., sports contest, religious meeting, etc.) Emotional qualities (e.g., competitiveness) of event Time of day when event held Time duration of single event Time duration of attendees' occupancy of the building

(2) Occupant Characteristics and Behavior Homogeneity Cohesiveness Familiarity with building Familiarity with similar events Capability as influenced by age, physical abilities, etc. Socio-economic factors Small minority involved with recreational violence Emotional involvement with the event and other occupants Use of alcohol or drugs

Food consumption Washroom utilization

(B) Management Clear, contractual arrangements for facility operation/use:

Between facility owner and operator Between facility operator and event promoter Between event promoter and performer Between event promoter and attendee With police forces With private security services With ushering services

Experience with the building Experience with similar events and attendees Through, up-to-date operations manual Training of personnel Supervision of personnel Communication systems and utilization Ratios of management and other personnel to attendees Location/distribution of personnel Central command location Rapport between personnel and attendees

Personnel supportive of attendee goals Attendees respect for personnel due t o :

Dress (uniform)standards Age and perceived experience Personnel behavior including interaction

Distinction between crowd management and control Management 's concern for facility quality (e.g. cleanliness) Management 's concern for entire event experience of attenclees

(i.e., not just during the occupancy of the building) (4) Emergency Management Preparedness

Complete range of emergencies addressed in operations manual

Power loss Fire Severe weather Earthquake Crowd incident Terrorism Hazardous materials Transportation accident (road, rail, air)

Commumcation systems available Personnel and emergency forces ready to respond Attendees clearly informed of-situation and proper behavior

(5) Building Systems Structural soundness

Normal static loads Abnormal static loads (crowds, precipitation, etc.) Dynamic loads (crowd sway, impact, explosion, wind, earthquake) Stability of nonstructural components (e.g. lighting) Stability of movable (e.g., telescoping) structures

Fireprotect ion elre prevention (maintenance, contents, housekeeping) Compartmentation Automatic detection and suppression of fire Smoke control Alarm and communication systems Fire depar tment access routes and response capability Structural integrity

Weather protection Wind Precipitation (attendees rush for shelter or hold up egress of others) Lightning

Circulation systems Fiowline or network analysis

Waywinding and orientation Merging of paths (e.g., precedence behavior) Decis ion/branching points Route redundancies Counterflow, crossflow, and queuing situations Control possibilities including metering Flow capacity adequacy System balance

Movement time performance Flow umes Travel times Queuing times

Route quality Walking surfaces (traction, discontinuities) Appropriate widths and boundary conditions

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N F P A 101 m F 9 9 R O C

Handrails, guardrails, and o the r rails Ramp slopes Step geometr ies Perceptual aspects (orientation, signage, marking, lighting, glare, distractions, etc.) Route choices especially for vertical travel Rest ing/wait ing areas

Levels o f service (overall crowd movemen t quality) Services

Washroom provision and distr ibution Concessions First aid and EMS facilities General a t tendee services

A-8-4.1.3 (A-9-4.1.3) A scenario-based approach to per formance- based fire safety is addressed in Oaapter 3. In addit ion to utilizing such scenarios and, more generally, the at tent ion to per formance criteria, evaluation, safety factors, documenta t ion , main tenance and

eriodic assessment required when the Chapter 3 option is used, Life ty Evaluations should consider scenarios based on characteristics

impor tan t in assembly occupancies. These characteristics include: (a) Whether there is a local or mass awareness of an incident,

event or condit ion that might provoke egress, (b) Whether the incident, event or condit ion stays localized or

spreads, (c) Whether or no t egress is des igned by facility occupants, (d) Whether there is a localized start to any egress or mass start to

egress, and (e) Whether exits are available or no t available. Examples of scenarios - and sets of characteristics - that might

occur in a facility include: Scenario 1. Characteristics: Mass start, Egress desi red (by managemen t and

at tendees) , Exits no t available, Local awareness. Normal egress at end of an event occurs just as a severe weather condit ion induces evacuees at the exterior doors to re tard or stop their egress. The backup which occurs on the egress system is not known to most evacuees who cont inue to press forward (potentially resulting in a crowd crush).

Scenario 2. Characteristics: Mass start, Egress no t desired (by management ) ,

Exits possibly no t available, Mass awareness. An earthquake occurs dur ing an event; the at tendees are relatively

safe in the seating area; the means of egress outside the seating areas are relatively unsafe and vulnerable to aftershock damage. Facility managemen t discourages mass egress until the means of egress can be checked and t e a r e d for use.

Scenario 3. Characteristics: Local start, Inc ident stays local, Egress desi red (by

at tendees and management ) , Exits available, Mass awareness. A localized civil dis turbance (e.g., f irearms violence) provokes localized egress which is seen by at tendees generally who then decide to leave also.

Scenario 4. Characteristics: Mass start, Egress desired, Incident spreads, Exits

no t available, Mass awareness.

In an open-air fadli ty (unpro tec ted f rom wind, precipi tat ion and l ighming), sudden severe weather prompts egress to shelter but no t f rom the facility. The means of egress congest and block quickly as people in f ron t stop once they are under shel ter but people behind them cont inue to press forward (potentially resulting in a crowd crush) .

These example scenarios illustrate some of the broader factors to be taken into account when assessing the capability of both building systems and managemen t features on which reliance is placed in a range of situations, n o t j n s t fire emergencies. Some scenarios also illustrate conflicting motivations of managemen t and at tendees based on differing percept ions of danger a n d differing knowledge of hazards, counter-measures and capabilities. Mass egress might no t be the most appropria te life safety strategy in some scenarios such as Scenario 2.

Table A-8-4.1.3 (A-9-4.1.3) summarizes characteristics in the example scenarios and provides a form for developing other characteristics and scenarios that might be impor tan t for a particular facility, hazard, occupant type, event, a n d management . SUBSTANTIATION: The p roposed material reorganizes, repositions, expands, and clarifies the material p repa red for the ROP. It presents the revised Appendix material in a fashion that should me more useful to the user. COMMITTEE ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GERDES: I believe that this material should be dele ted f rom the

code, The evaluation is a unique per formance issue which goes beyond the typical prescriptive code. I quest ion the scope and dep th of the analysis and whether such evaluation can be comple ted without adequate and validated informational sources. The Code will establish a h igh level per formance issue that one cannot resolve. Identifying all possible scenarios itself could be a career. The potential liability for owners and designers is t remendous .

GESSNER: The reason for my negative vote is the same as those iVen by Mr. Gerdes, Maddox and Miller. Being a representative r IAAM, I can tell you f rom exper ience that there are too many

variables in our industry to establish a s tandard "code" in this area. Al though it appears as though the intent of this code is commendable , it lacks the specifics n e e d e d to be of any use.

MADDOX: It is in tended, according to the substantiation, to provide additional guidance on the subject of a life safety evaluation. The proposal provides an abundancy of topics to consider but no guidance on how to address these topics. The change will result in an even greater state of confusion regarding life safety evaluations than exists under the current code.

MILLER: Even though there are some impor tant factors to be considered, this proposal goes well beyond the scope of this d o c u m e n t to many areas that have no science, engineer ing basis, or answers. It is a list of items that in many instances, if there were definitive answers to, no one would know what to do with the answers and their impact in relation to specific design of a building.

Table A-8-4.1.3 (A-9-4.1.3)

Local Mass Incident Aware- Aware Localized

Scenario 1 X

Scenario 2 X

Scenario 3 X X

Scenario 4 X

Incident Spreads

X

Life Safer,/Evaluation Scenario Characteristics Mau'ix

Local Mass Management

Egress Egress Not Desired Desired

X

X

Exits Exits Not Occupants Start Start Available Available Other

Egress Egress No t Desired Desired

X X

X X

X X

X X X

164

N F P A 101 - - F 9 9 R O C


101- 290 - (8-$.3.$ Exception, 9-$.$.3 Exception): Accept SUBMITrER: Technical Committee on Assembly Occupandes and Membrane S~uctures COMMENT ON PROPOSAL NO: 101-$26

I RECOMMENDATION: Accept Proposal 101-$26 so as to delete the Exception to 8-3.$.$ and the Exception to 9-$.3.3. SUBSTANTIATION: The SAF-FUR committee, in its committee action on Comment 101-271 (Log #$07) corrected the problem. Thus, the material can be deleted from Chapters 8 and 9. COMMITTEE ACTION: Accept. NUMBER OF COMMITIZE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:



101- 291 - (8-$.5.1 and 9-$.5.1 ): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-$$2 RECOMMENDATION: Reject Proposal 101-352. SUBSTANTIATION: There is no technical substantiation for the elimination of sprinklers from large areas such as storage rooms that are 999 sq ft in area. The elimination of sprinklers from enclosed stadia and arenas is also a problem. Section 6-2.4.6 used to contain similar provisions for auiums. This language was eliminated in the 1997 edition with the following substantiation (see 1996 Fall Meeting ROP Proposal 101-134).

"There is no technical basis to allow in all cases the omission of automatic sprinklers at the top of atria which are more than 55 ft above the floor. The present text provides no criteria for the authority having jurisdiction to use in approving such an admission. If an engineering analysis determines that the omission of automatic sprinklers at the top of the atrium will not adversely affect the safety of occupants, a request for exemption can be made to the authority having jurisdiction in accordance with the equivalency concept of Section L57

The same theory should apply to stadia and arenas. A true engineering analysis that really proves that sprinklers are not needed could be handled as an alternate already allowed by the Code. Putting the exceptions actually in the Code, without guidance on how to make an approval of the analysis makes it too easy for the sprinklers to be omitted.

One of the items often overlooked in this kind of analysis is the structural members of the roof. While an analysis might show that sprinkler discharge might no t extinguish the fire below, the sprinklers will still provide cooling near the ceiling to prevent structural collapse. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The engineering analysis, as required for the use of the exception that exempts ceiling sprinklers, provides the level of safety needed. Storage rooms less than 1000 sq. ft are adequately protected by rated construction in these unenclosed stadia. This represents no change from the provisions of NFPA 102 which are being moved into NFPA 101. Further, if the facility utilizes the decreased egress widths permitted of smoke-protected assembly seating, then the facility will be fully sprinklered. NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITrEE ACTION:



101- 292 - (8-$.5.1 Exceptions and 9-3.5.1 Exceptions (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-$$2 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-AXM give consideration to Mr. Messersmith's comment on affirmative. Mr. Messersmith is correct based on the revisions being made by Proposal 101-$$9. It reads:

MESS E~ , MITH: In item "(c)" of Exception No. 5 to 8-$.5.1 and in item (c) of Exception No. 2 to 9-$.5.1, I befieve that reference to "8-4.8.4" and "9-4.8.4" should be to "8-4.8.5 and 9-4.8.5" respectively. SUBSTANTIATION: See the above recommendation.

COMMrUI~E ACTION: Accept in Principle. Fix the references as requested by Mr. Messersmith in his

comment on affu~aative. COMM/TrEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:



101- 293 - (8-4.5.12 and Exception (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-$$5 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the extinguishing systems provisions of NFPA 101, review Proposal 101-335 for correlation. SUBSTANTIATION: See the above recommendation. COMMITIT, E ACTION: Accept in Principle.

[ Retain the Committee Action on Proposal 101-$$5. COMMITI'EE STATEMENT: There is no correlation issue with the change proposed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14

(Log #415b) Committee: SAF-AXM

101- 294 - (84.5.12 and Exception (New)): Accept in Principle SUBMITI'ER: John G. O'Neill, Gage-Babcock & Assoc. Inc. COMMENT ON PROPOSAL NO: 101-$$5 RECOMMENDATION: I do not object to the proposal since it does not include changes to the installation criteria for sprinkler

tems. BSTANTIATION: I serve as Chair of the Technical Correlating

Committee on Automatic Sprinkler Systems (NFPA 13). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

NFPA 13 provides guidance for incorporating such hose stream demands, as proposed, in the sprinkler system design. Further the committee continues to support cost-effective rem_slons in overall fire protection criteria, which would encourage complete sprinkler systems in accordance with NFPA 13. COMMITIT, E ACTION: Accept in Principle.

[ Retain the Committee Action on Proposal 101-335 in the ROP. C O ~ STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 25 VOTE ON COMMITI'EE ACTION:



101- 295 - (84.5.12 and Exception (New)): Accept in Principle SLrBMITIT, R: Maurice M. Pflette, Mechanical Designs Ltd COMMENT ON PROPOSAL NO: 101-335 RECOMMENDATION: I support the committee action on Proposal 101-355. SUBSTANTIATION: I serve as Chair of the NFPA Technical Committee on Standpipes (NFPA 14). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

The use of 1-1/2 in. first aid fire-fightinghose lines should be permitted for regular stages over 1000 sq ft in area and for all legitimate stages. The current edition of the Life Safety Code requires stages to be protected by a Class III standpipe system in accordance with NFPA 14-1996, Standard for the Installation of Standpipe and Hose Systems, which requires a flow of 500 gpm at 100 psi. This hydraulic criteria often require the installation of a fire pump. The burden of installing a fire pump for the stage's two oudets can be avoided by permitting the installation of hose oudets in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems. COMMITTEE ACTION: Accept in Principle.

Retain the Committee Action on Proposal 101-$35 in the ROE COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent.

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N F P A 101 u F 9 9 R O C

NUMBER OF COMMITrF~ MEMBERS ELIGIBLE TO VOTE: 25 VOTE ON COMMITTEE ACTION:


(Log #$58) Committee: SAF-AXM

101- 296- (8-4.7.4.2): Reject SUBMITI"ER: Wilfiam E. KoffelJr., Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-$$8 RECOMMENDATION: Do not delete paragraph 8-4.7.4.2. SUBSTANTIATION: This comment is being submitted in case the Life Safety Technical Committee on Means of Egress does not continue to recognize photoluminescent signs. COMMITTEE ACTION: Reject. COMMITIXE STATEMENT: The SAF-MEA Committee retained the recognition of photoluminescent signs at its ROC-preparation meeting. The committee thanks the submitter for raising the subject for consideration. NUMBER OF COMMITIEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:



101- 297 - (8-4.8.1.1 and 9-4.8.1.1 (New)): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-$$9 RECOMMENDATION: Add a new 8-4.8.1.1 and 9-4.8.1.1 to read:

"A Life Safety Evaluation in accordance with 8-4.1 (9-4.1) shall be performed for grandstands providing seating for more than 300

~ e r g o n $ . "

UBSTANTIATION: During the incorporation of the requirements for grandstands from NFPA 102 the provision for standby personnel was lost. We believe that requirement can better be addressed by referring the user to the Life Safety Evaluation section for a more comprehensive and more complete review. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has no t provided substantiation to impose such an onerous requirement to perform a life safety evaluation for so small a facility. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 25 VOTE ON COMMYITEE ACTION:



101- 298 - (9-4.5.12 Exception (New)): Accept in Principle SUBMITTER: Technical Correlating Commtttee on Safety to Life COMMENT ON PROPOSAL NO: 101-$51 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the extinguishing systems provisions of NFPA 101, review Proposal 101-335 for correlation. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

[ Retain the Committee Action on Proposal 101-351. COMMITTEE STATEMENT: There is no correlation issue with the change proposed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14

(Log #415c) Committee: SAF-AXM

I01- 299 - (9-4.5.12 and Exception (New)): Accept in Principle SUBMITTER: J o h n G. O'Neill, Gage-Babcock & Assoc. Inc. COMMENT ON PROPOSAL NO: 101-$51 RECOMMENDATION: I do not object to the proposal since it does not include changes to the installation criteria for sprinkler systems. SUBSTANTIATION: I serve as Chair of the Technical Correlating Committee on Automatic Sprinkler Systems (NFPA 13). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

NFPA 15 provides guidance for incorporating such hose stream demands, as proposed, in the sprinkler system design. Further the committee continues to support cost-effective revisions in overall fire protection criteria, whxch would encourage complete sprinkler systems in accordance with NFPA 13. COMMITrEE ACTION: Accept in Principle.

| Retain the Committee Action on Proposal 101-$51 in the ROP. COMMITIT.E STATEMF2qT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 25 VOTE ON COMMITTEE ACTION:



101- 300 - (9-4.5.12 and Exception (New)): Accept in Principle SUBMITrER= Maurice M. Pilette, Mechanical Designs Ltd COMMF.aNT ON PROPOSAL NO: 101-551 RECOMMENDATION: I support the committee action on Proposal 101-$51. SUBSTANTIATION: I serve as Chair of the NFPA Technical Committee on Standpipes (NFPA 14). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

The use of 1-1/2 in. first aid fire-fightinghose lines should be permitted for regular stages over 1000 sq f t in area and for all legitimate stages. The current edition of the Life Safety Code requires stages to be protected by a Class III standpipe system in accordance with NFPA 14-1996, Standard for the Installation of Standpipe and Hose Systems, which requires a flow of 500 gpm at 100 psi. This hydraulic criteria often require the installation of a fire pump. The burden of installing a fire pump for the stage's two outlets can be avoided by permitting the installation of hose outlets in accordance with NFPA 13, Standard for the Installation of

ACTION: Accept in Principle. [ Retain the Committee Action on Proposal 101-$51 in the ROP.




101-301- (9-4.8.1 and 9-4.8.1 ): Accept SUBMITrER= Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-$$9 RECOMMENDATION: Revise 9-4.8.1 so that it reads:

9-4.8.1 General. Grandstands shall comply with the provisions of this Chapter as modified by 9-4.8.

Exception. Existing grandstands shall be permitted to be continued to be used subject to the approval of the authority having jurisdiction.

Delete A-9-4.8.1. Delete the reference to NFPA 102 in 33-1.1. Delete the reference to NFPA 102 in Appendix B.

SUBSTANTIATION: NFPA 102 is being withdrawn and applicable portions are being moved into NPFA I01. Thus, NFPA 101 will no longer be able to reference NFPA 102. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 23 VOTE ON COMMITTEE ACTION:


(Log #202) Committee: SAF-END

101- 302 - (10-2.1.2 Exception and 11-2.1.2 Exception): Reject SLrBMITITA~ Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-357 RECOMMENDATION: Reconsider the Committee Action and reject the proposal. SUBSTANTIATION: We agree with the negative comments made

MMITrEE ACTION: Reject. COMMITTEE STATEMENT: The committee needs to retain the acceptance of Proposal 101-$57. The "independent means of egress" is an adequate safeguard. Schools are required to run emergency egress and relocation drills to familiarize the occupants with emergency egress. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 13 NEGATIVE: 1 NOT RETURNED: 1 Ewing

166

N F P A 101 - - F9 9 R O C

EXPLANATION OF NEGATIVE: DUFFIN: The proposal is needlessly subjecting young children to

vertical egress travel hazards, potential increased travel distances, and the potential effects from hot smoke and other combustion products. I am not assured that the proposed "dedicated independent egress facilities" provides equivalent risk to the current code provisions. Same substantiation as contained in my ROP letter ballot Log #M7-END. This is "sections 10-2.1.2 and 11-2.1.2 of the current (1997) edition of NFPA 101 allow second grade students to normally occupy areas that involve additional vertical egress (via stairs) over that of preschool, kindergarten, and first grade students. The proposal references that preschool, kindergarten, and first grade students be subject to additional vertical egress (via stairways) along with the second graders. The .proposal indicates that this can be accomplished through the use of dedicated independent egress facilities" for preschool, kindergarten, first grade, and second grade students. The proposal indicates this will eliminate the hazard of younger students being "run over by older students,"

"Dedicated independent egress facilities" as proposed will not prevent preschool, kindergarten, and first grade students from being trampled in an emergency situation. (I refer only to preschool, kindergarten, and first grade students in accordance with the existing edition of the Code.) With visitors, substitute teachers, and older students being commonplace in educational occupancies, how can it be assured that " independent egress facilities in the area" will be truly dedicated to preschool, kindergarten, and first grade student usage only. Even if these stairs were truly dedicated, kindergarten, first grade, and especially preschoolers-children as Ykoung as 2 years old, could be trampled by other preschool,

indergarten, and flrst grade students. These preschool, kindergarten, and first grade students will

/~nerally be capable of ser-preservation. Some probably will not. so, in an emergency situation, the younger students may become

confused and panicky. Confusion and panic has the potential to result in accidents involving preschool, kindergarten, and first grade students using stairs for egress. Stairs are one of the most common building elements used on a "normal" non-emergency basis as the means of vertical travel. Stairs are also one of the most common scenes of accidents during non-emer~enc~, usage. The frequency of non-emergency stair accidents, even ff soars are "dedicated independent egress facilities," will occur more frequently for preschool, kindergarten, and first grade students if they are subject to more frequent stair travel over the "normal" course of the day.

The serious nature of the proposal is further augmented by Title $ of The Americans with Disabilities Act of 1990 which exempts elevators in new and existing educational occupancies that are less than 5 stories high or are less than $000 sq ft per story. Disabled preschool, kindergarten, and first grade students will also be subject to increased stair travel during both emergency and nonemergency usage, with the potential for stair accidents also occurring more frequently.

The reference to the "public library" is out of context with the concern of preschool, kindergarten, and first grade students in an educational occupancy. The normal adult to preschool, kindergarten, andf i rs t grade student ratio is higher at a public library with an older sibling or adult. This lends to more capable assistance with stair egress at a public library than at an educational occupancy. The decreased adult to preschool, kindergarten, and first grade student ratio within an educational occupancy results in the potential for less capable assistance available for preschool, kindergarten, and first grade students to egress stairs in both emergency and non-emergency situations and the increased potential for accidents involving stairs.


101- 505 - (10-2.1.2 Exception and 11-2.1.2 Exception): Reject SUBMITIT_,R: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-357 RECOMMENDATION: Delete the proposed Exceptions to 10-2.1.2 and 11-2.1.2. SUBSTANTIATION: Considerations to the location of younger children in educational occupancies should be made in addition to the hazards of such children being trampled by older individuals on stairs. Vertical egress travel, especially the use of stairs in the upward travel direction, is more difficult for a large number of smaller children and may lengthen the time of exit travel to unacceptable levels. The installation of dedicated egress routes from these areas does not address the issues of such difficulties in egress travel. The best solution to egress travel by large numbers of smaller children is to regulate their location in the building and, hence, the amount of vertical travel necessary in the means of egress for such a population.

Further consideration should also be given to the comments of the negative ballot submitted by Mr. Duffin. COMM1TIT~ ACTION: Reject. COMMITTEE STATEMENT: See Comment 101-302 (Log #'202). NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 13 NEGATIVE: 1 NOT RETURNED: 1 Ewin K

EXPLANATION OF NEGATIVE: DUFFIN: Exceptions should not be added as proposed. Also,

see my Explanation of Negative on Comment 101-$02 (Log #202).

(Log#331) Committee: SAF-END

101- $04- (10-2.5.6, 11-2.5.6): Accept SUBMITTER: James 1L Lathrop, KoffelAssoc., Inc. COMMENT ON PROPOSAL NO: 101-370 RECOMMENDATION: Retain appendix A-10-2.5.6 and A-11-2.5.6.

A-10.2.5.6 (A-11-2.5.6) A corridor roofed over and enclosed on its long side and open to the atmosphere at the end may be considered an exterior corridor if either:

(a) Clear story openings for the corridor are provided on both sides of the corridor and above adjacent roofs or buildings, and such dear openings are not less than one half the height of the corridor walls, or

(b) The corridor roof has unobstructed openings to the sky not lesg than 50 percent of the area of the roo£

The openings are to be equally distributed, and, if louvers are installed, they are to be fixed open with a clear area based on the actual openings between louver vanes. SUBSTANTIATION: This appendix note was developed after extensive work with school officials and designers in the state of Florida. Although one side is not 50 percent open, it was determined by the committee at the time that it was equivalent. Deletion of the rest of the material is a good change, but keep the appendix note so that a very common arrangement in wanner climates will continue to be acceptable. COMM/TIXE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- $05 - (10-2.9(b) and 11-2.9(b)): Reject SUBMITIT.R: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-574 RECOMMENDATION: Please reconsider the action taken. Suggest (b) be worded as follows:

(b) ~ g C & normally . . . . . . . . . . r.__:-a =~ace= subject to student occupancy durin~ periods of darkness.

Delete the Exc@don. SUBSTANTIATION: Most emergency lighting needs are well covered by the existing Code provisions. A problem often arises about the need for emergency lighting in classrooms, etc. that are subject to use during nontraditional hours of school operation. The time for darkness changes significantly where jurisdictions are under day light savings times. The proposed wording deals with that, and clearly indicates it applies to student occupied spaces. Also, the term ~assembly use spaces ~, as proposed, indicates the provisions only applies rooms or spaces with an occupant load of 50 or more. If this is the intent, it needs more darificatinn, however, if that is the intent, reconsideration is needed. Students, especially the very young ones, need the emergency lighting regardless of the numbers involved. COMMITIT~ ACTION: Reject. COMMITTEE STATEMENT: The submitter's wording would require all rooms to have emergency lighting because due to daylight savings time and other seasonal differences, educational occupancies might be operated for part of the day when it is dark outside. The committee's use of "assembly use spaces" is not the same as "assembly occupancy" and thus does not require at least 50 or more persons to be present. The action taken in the ROP is correct. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:


167

N F P A 101 m F 9 9 R O C


101- 306 - (10.2.11.1 Exception No. 3 and 11-2.11.1 Exception No. 3): Reject SUBMITrER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-$76 RECOMMENDATION: Delete the proposed Exception No. 3 to paragraphs 10-2.11.1 and 11-2.11.1. SUBSTANTIATION: There has been no technical justification to the elimination of exterior openings for ventilation purposes in rooms located higher than three stories above grade. The provision for exterior openings for ventilation purposes has been a significant life safety feature of the Code, and to eliminate it with no technical merit or further explanation is a mistake. There is no reason that an exterior opening is justifiable for ventilation purposes on the first three floors of a buildings, but is not needed on upper floors.

In addition, many fire department have access to apparatus that can provide for rescues at much greater heights than three stories, but without access to the interior of the building are useless for emergency escape purposes.

Further consideration should also be given to the comments of the negative ballot submitted by Mr. Duffin. COMMIT1T_,E ACTION: Reject. COMMITTEE STATEMENT: The windows on lower floors are for rescue purposes. On hil{her floors, where rescue is not an option, there is no need to reqmre a rescue window. Ventilation is not an issue. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: DUFFIN: I disagree with the Committee Statement. This

proposal, as worded, can be construed to potentially affect ventilation. In addition, the "option of rescue" should be performance-based and not prescriptively limited.

Same substantiation as contained m my ROP letter ballot on Proposal 101-376. No technical documentation has been presented to me that verifies windows for ventilation can be removed in rooms higher than $ stories without causing a life safety concern for the occupants of those rooms. The applicable technical documentation should be forwarded to my attention for review. In addition, I feel the applicable sections could be made

~ erformance-based by requiring windows for rescue in rooms igher than 3 stories or within the rescue capabilities of the arriving

fire department as determined by the authority having jurisdiction, whichever is greater. (Reliable rescue apparatus is available that has rescue capability for rooms higher than $ stories.)

(Log #$65) Committee: SAF-END

101-307- (10-3.1 Exception No. 1 and 11-3.1 Exception No. 1 ): Accept in Principle SUBMITrER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-377 RECOMMENDATION: Renumber existing 10.3.5 to 10-3.5.1 and relocate proposed 10-3.1 Exception No. 1 to a new 10-$.5.2.

Renumber existing 11-3.5 and Exception to 11-$.5.1 and relocate proposed 11-$.1 Exception No. 1 to a new 11-3.5.2. SUBSTANTIATION: It is bad Code language to write requirements by means of exceptions. These exceptions have been relocated to paragraphs which otherwise contain the requirements for the installation of sprinkler protection in these various occupancy types. All of the basic requirements for the installation of sprinkler protection should be located in a common section of the Code regardless of the intent of installation requirements. COMMITTEE ACTION: Accept in Principle.

Do as the submitter has requested and also add as a new second sentence to 10.$.1 and 11-$.1 the following:

"Where the provisions of 6-2.4.5 are used, the requirements of 10/11-$.5.2 shall be met." COMMITTEE STATEMENT: The committee agrees that an exception should not present a stricter requirement than the base paragraph. It has agreed to relocate the material to 10-$.5 and 11-3.5. However, there needs to be a statement left in 10-3.1 and 11-3.1 directing the user to the sprinkler requirements. The Committee Action accomplishes this. This should meet the submitter's intent.

NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:


15


101- 308 - (10.3.2.1(a) 1 Exception): Reject SUBMITTER: Catherine L. Stashak, Des Haines Fire Dept., IL COMMENT ON PROPOSAL NO: 101-$79 RECOMMENDATION: Revise text:

Exception to (a)(1): P.ccm= cnc!c::ng cn!y : ' : h:nd! 'ng cqu'F=..¢nt. Rooms enciosln~ furnaces, hearing and air handling equipment, or comnressor euuinment that does not e~gg¢0, ~'ly 9f the followine criteria: - -

15 osi~ steam 160 nsi~ hot water 200°F overatin~ temnerature

Heat inout ratine of less than 200.000 Btu. Such rooms shall not be used for storage unless otherwise

=

pr0tccted as reuuired. For installations in attics, t~h¢ 0raft stoppin~ reouirements of 6-2.6.1¢b) shall annlv. SUBSTANTIATION: Boilers ancl other similar heating appliances are classified on the basis of (among other things) working pressure, temperature and heat input rating. The exception to this requirement should not be limited to heat values such as Btu's. Borrowing information from the ASHRAE-HVAC Systems and Equipment Handbook (1996), and the State of Illinois Office of the State Fire Marshal-Boiler and Pressure Vessel Safety Act (1997), the above criteria should provide clearer triggering points for the 1-hr enclosure. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The issue is moot because Comment 101-309 (Log #CC300) rejects Proposal 101-379. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 14 NOT RETURNED: I Ewing

(Log #CC300) Committee: SAF-END

101- 309 - (10-$.2.1(a)1 Exception): Accept SUBMITTER: Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-379 RECOMMENDATION: Reject Proposal 101-$79. SUBSTANTIATION: The action taken on Proposal 101-379 would create possibly unsafe conditions not intended by the committee. The language of the 1997 edition of the Code needs to be retained. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- 310 - (10-$.$.2 Exception, 11-3.3.2 Exception): Accept SUBMITTER: Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-$81 RECOMMENDATION: Accept Proposal 101-581. Thus, this will delete 10-3.3.2 Exception, 11-$.$.2 Exception, A-10.3.g.2 Exception, and Ad1-3.3.2 Exception. SUBSTANTIATION: During RUG preparation, the SAF-FUR committee further revised its rewrite of section 6-5 so as to address the subject adequately. Thus, the material in Chapters 10 and 11 can be deleted. COMMIT1"EE ACTION: Accept. NUMBER OF COMMI'IWEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


168

N F P A 1 0 1 - - F 9 9 R O C


101- 311 - (10-3.4.2.1 Exception No. 1): Reject SUBMITFER= James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-383 RECOMMENDATION: Reject proposal I01-585. SUBSTANTIATION: This system has been used for years throughout the country with no adverse reports. When it was put in the Code, it was reported that California, St. Louis, and San Antonio had all been using this concept with no problems. This exception is in the final draft of the International Fire Code and a proposal to remove it was defeated. The authority having jurisdiction can mandate that fire alarm stations be installed in areas such as auditoriums, gymnasiums, etc. that might be used at night. If the school is used for night school, the authority having jurisdiction has the power to require manual stations be reinstalled. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee needs to retain acceptance of Proposal 101-385. See the substantiation for Proposal 101-383 where it is explained that the current exception is not j.ustified for new construction. In new construction it is feastble to install an NFPA 72-complying fire alarm system. NUMBER OF COMMHq'EE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:



101- 312 - (10-3.4.3, 11-3.4.3): Accept SUBMITrER: Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-386

I RECOMMENDATION: Revise 10-3.4.3.1.2 and 11-$.4.$.1.2 to read: 10-3.4.3.1.2 (11-3.4.3.1.2) Where acceptable to the authority

having jurisdiction, the fire alarm systems shall be permitted to be used for other emergency signaling or for class changes, provided the fire alarm is distinctive in signal and overrides all other use. SUBSTANTIATION: Adding wording that specifically permits the fire alarm system to be used for other emergency signaling helps to clarify committee intent. Based on the recent rash of non-fire emergencies in the schools, it is important to darify that the fire alarm system can be used for multiple purposes provided that the fire alarm is distinctive in signal and overrides all other uses. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITFEE ACTION:



101- 313- (10-3.5): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-588 RECOMMENDATION: Accept proposal 101-388. SUBSTANTIATION: The original submitter is correct in asking for sprinkler protection in all educational occupancies. Loss of a school is a tremendous financial burden on any community, and fire sprinklers, when installed at the right time, are tremendously cost effective. COMMrITEE ACTION: Reject. COMMITrEE STATEMENT: The submitters substantiation address the property protection, not life safety issues. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ENDTHOFF: My negative vote on Comment 101-313 (Log #241)

and 101-475 (Log #249) is because I disagree with the level of safety the code provides without fire sprinklers. Sprinklers can be installed without raisin[g the cost of construction by properly applying the trade-ups m both the Life Safety Code and the building code. I believe the dme is right to offer a higher level of protection and stop avoiding our responsibilities.


101- $14 - (10-3.5, 11-3.5): Accept in Principle SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-264 RECOMMENDATION: Renumber existing 10-3.5 to 10-3.5.1 and relocate proposed 10-$.1 Exception No. 1 to a new 10-3.5.2.

Renumber existing 11-3.5 and Exception to 11-3.5.1 and relocate proposed 11-3.1 Exception No. 1 to a new 11-3.5.2. SUBSTANTIATION: It is bad Code language to write requirements by means of exceptions. These exceptions have been relocated to paragraphs which otherwise contain the requirements for the installation of sprinkler protection in these various occupancy types. All of the basic requirements for the installation of sprinkler protection should be located in a common section of the Code regardless of the the intent of installation requirements. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-307 (Log #365). COMMITIT~ STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- $15 - (10-4.1.2 through 10-4.1.6): Reject SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-594 RECOMMENDATION: Retain the existing 10-4.1.2 through 10- 4.1.6. SUBSTANTIATION: The reference to these provisions of Chapter 10 are needed in order to address specific reqmrements not found in Section 32-7. For example, Section 32-7 does not contain a requirement for smoke barriers as found in 10-4.1.$, requires emergency lighting only in the windowless or underground portions of the structure, contains different requirements for the installation of smoke venting facilities, and makes no requirement for the installation of a voice alarm system. No technical justification has been provided for the elimination of these requirements from Chapter 10. COMMITrEE ACTION: Reject. COMbHTTEE STATEMENT: The SAF-END Committee has determined that the requirements of Section 32-7 are adequate for educational occupancies. Section 32-7 has applicability to any occupancy. Chapter 10 should not address the subject differently unless it needs to. There is no documentation that special requirements are needed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:


EXPLANATION OF NEGATIVE: FREELS: I agree with the substantiation given by Mr. Bush. I feel

that current sections 104.1.2 through 104.1.6 should not be omitted from the Code. These sections provide additional occupancy-specific requirements, which are not adequately addressed in Section 32-7.


101- 316 - (10-5.2.2 Exception, 11-5.2.2 Exception): Reject SUBMITrER: Art Black, Carmel Fire Protection Assoc. COMMENT ON PROPOSAL NO: 101-395 RECOMMENDATION: Accept proposal as printed in the November 1999 (1799) ROP. SUBSTANTIATION: I serve as Chair of the NFPA Technical Committee on Carbon Monoxide and Fuel Gas Detectors (NFPA 720). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

At the ROP meet ingfor the Technical Committee on Carbon Monoxide and Fuel Gas Detectors held in San Diego, California, the committee reviewed the Life Safety Code proposals referencing NFPA 720, Recommended Practice for Installation of Household Carbon Monoxide Warning Equipment.

169

N F P A 101 - - 1¢99 R O C

While there was no official vote taken, the committee members present indicated that the reference to NFPA 720 in the appendix m both the proposals was appropriate. COMMIT1T~ ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Comment 101-318 (Log #52a). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- 317 - (10-5.2.2 Exception and 11-5.2.2 Exception): I TCC NOTE: The Technical Correlating Committee on Safety to :Life (SAF-AAC) directs that the action on this comment be changed to "Accept in Principle. Reject Proposal 101-$95. ~ The SAF-END committee was pleased that the SAF-BSF committee supported the SAF-END's right to address the subject as done in the ROP, but in the action on Comment 10b$18 (Log tS52a) the SAF-END committee reversed itself and rejected Proposal 101-395. Thus, for correlation purposes the action on Comment 101-317 (Log #52) needs to be changed. SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-395 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the building service systems provisions of NFPA 101, review Proposal 101-395 for correlation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Retain the language of the Proposal. COMMITTEE STATEMENT: It is within the scope of SAF-END to modify the reference to NFPA 54 for these specific occupancies if there is sufficient technical justification to do so. If SAF-END addresses the comments from SAF-AAC there are no further correlation issues within NFPA 101. NUMBER OF COMM1TIXE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14

(Log #52a) Committee: SAF-END

101- 318 - (10-5.2.2 Exception and 11-5.2.2 Exception): Accept in Principle SUBMITTERa Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101495 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-END:

(1) further justify its proposed use of NFPA 720 outside the scope of that document, and

(2) explain the inadequacies of the current text that requires the gas space heaters to be installed per the requirements of NFPA 54. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Reject Proposal 101-395. COMMITTEE STATEMENT: See the substantiation submitted by the Chair of the NFPA Technical Committee on National Fuel Gas Code in Comment 101-319 (Log #357). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITrEE ACTION:



101- 319 - (10-5.2.2 Exception and 11-5.2.2 Exception): Accept SUBMITIT.R: Mike Gorham, Northwest LP Gas Co. COMMENT ON PROPOSAL NO: 101495

] RECOMMENDATION: Reject the proposal. SUBSTANTIATION: I serve as Chair of the NFPA Technical Committee on National Fuel Gas Code (NFPA 54). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

NFPA 54, National Fuel Gas Code, contains no requirement for CO detectors. The National Fuel Gas Code has ventilation

requirements and combustion air requirements as well as other provisions which ensure that permitted installations are safe. The substantiation documents no needed level of safety. Indeed, vent free heaters (gas-fired) are required to be equipped (by the appropriate ANSI Z21 standard) with an oxygen depletion sensor (ODS) pilot which shuts the unit down before it begins producing CO. The National Fuel Gas Code permits heaters so equipped and in limited input ratings to be installed even in bathrooms and bedrooms. ODS-equipped vent-free heaters have enjoyed a superb safety record - especially in relation to CO problems - since their introduction. The proposed CO detectors are simply not necessary for safety. The proposed requirement should be deleted. A suitable alternate course may be to have the Exception read: "Unvented gas space heaters equipped with an oxygen depletion sensor, built in accordance with the appropriate ANSI Z21 standard and installed in compliance with NFPA 54, National Fuel Gas Code." COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101-320- (11-3.2.1(a)1 Exception): Reject SUBMITI'ER: Catherine L Stashak, Des Plaines Fire DepL, IL COMMENT ON PROPOSAL NO: 101-405 RECOMMENDATION: Revise text:

F~.ception to (a) (1) . . . . . . . . . . . . . . . . . ~, vu. 1 . . . . . . . . . . mg cc~u:p..-::.':'~ Rooms enclosing furnaces, heating and air handling eouinment, or compressor eouinment that does not exceed any of the following criteria: - -

200°F operating temnerature 120 wallon caoacitv Heat-innut ratin~ of less than 200.000 Btu. Such rooms shall no t be used for storage unless otherwise

vrotected as reouired. For installations i-n attics, the draft stonoin~ reouirements of 6-2.6.1(b) shall aDOIv. - - - SLfBSTANTIATION: Boilers and other similar heating appliances are classified on the basis of (among other things) working pressure, temperature and heat input rating. The exception to this requirement should not be limited to heat values such as Btu's. Borrowing information from the ASHRAE-HVAC Systems and Equipment Handbook (1996), and the State of Illinois Office of the State Fire Marshal-Boiler and Pressure Vessel Safety Act (1997), the above criteria should provide clearer triggering points for the 1- hr enclosure. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The issue is moot because Comment 101-321 (Log #CC301) rejects Proposal 101-405. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- 321 - (11-3.2.1(a)1 Exception): Accept SUBMITTER= Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-405

] RECOMMENDATION: Reject Proposal 101-405. SUBSTANTIATION: The action taken on Proposal 101-405 would create possibly unsafe conditions not intended by the committee. The language of the 1997 edition of the Code needs to be retained. COMMITTEE ACTION: Accept• NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


170

N F P A 101 - - F 9 9 R O C


101- $22- (11-4.2): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-408 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-END give consideration to Mr. Wood's explanation of negative addressing the need to substantiate new requirements that apply retroactively to existing buildings. It reads:

WOOD: The proposal will require all existing high rise buildings containing educational occupancies to be retrofitted with automatic sprinkler systems. I am aware of the excellent record of fire safety in buildings protected by automatic sprinkler systems, and do not argue against the merits of such installations. However, applying such requirements retroactively to existing buildings will have the potential effect of prohibiting adoption o f updated editions of the Life Safety Code in many jurisdictions, including my own. Furthermore, data relative to the number of fires, fire deaths or fire injuries in high-rise educational occupancies without automatic sprinkler protection was not presented. I suspect that such data would indicate a relatively low fire experience and even lower death/ injury impact. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Retain the acceptance of Proposal 101-408. Also, let the following paragraph serve as additional subs tantadon for the acceptance for Proposal 101-408.

The SAF-END committee feels that there is suificient risk involved with existing educational facilities located in a high-rise building to warrant compliance with the sprinkler provisions of 32-8.2.1 when consideration is given to the height above the level of exit discharge, extended evacuation times and limitations of fire suppression forces to effect rescue from outside of the building.

The Committee agrees with the substantiation provided by the proposer of proposal 101-408. COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 1 3 NEGATIVE: 1 NOT RETURNED: 1 Ewing

EXPLANATION OF NEGATIVE: WOOD: I continue to register a "No" vote on this item with the

explanation being the same as my original explanation of negative vote on Proposal 101-408 in the ROP:

The decision will require all existing high rise buildings containing educational occupancies to be retrofitted with automatic sprinkler systems. I am aware of the excellent record of fire safety in buildings protected by automatic sprinkler systems, and do not argue against the merits of such installations. However, applying such requirements retroactively to existing buildings will have the potential effect of prohibiting adoption o f updated editions of the Life Safety Code in many jurisdictions, including my own. Furthermore, data relative to the number of fires, fire deaths or fire injuries in high rise educational occupancies without automatic sprinkler protection was not presented. I suspect that such data would indicate a relatively low fire experience and even lower death/ injury impact.


101- $23 - (12-1.3 Hospital and 13-1.3 Hospital): Accept in Principle

I TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed so that in addition to adding the wording to 12-1.1.1.2 and 13-1.1.1.2, the same words will be deleted from the definition of "Hospitaff in 12-1.3 and 13-1.$. This was intended by the SAF- HEA action but not explicitly stated. SUBM1TI'ER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-420 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-HEA reconsider its action, adhere to the guidelines used by the glossary task ~ o u p , and move explanatory material out of the definitions and into the appendix. A definition is not to have an "include list" attached to it. SUBSTANTIATION: See the above recommendation. COMMITYEE ACTION: Accept in Principle.

I In 12-1.1.1.2 and 13-1.1.1.2 add a new sentence and position it just prior to the current second sentence to read:

"The term hospital, wherever used in this Code, shall include general hospitals, psychiatric hospitals, and specialty hospitals." COMMITTEE STATEMENT: The new sentence is wording identical to that currently part of the definition. The committee disagrees that it should be moved to the appendix. It is important that it be retained. Therefore, it is being added to the body of the Code, but separate from the definition. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 324 - (12-1.$ Nursing Home and 13-1.$ Nursing Home): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed so that in addit ion to adding the wording to 12-1.1.1.2 and 13-1.1.1.2, the same words will be de leted from the definition of "Nursing Home" in 12-1.3 and 13-1.3. This was intended by the SAF-ttF~ action but not explicit ly stated. SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-4~ RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-HEA reconsider its action, adhere to the guidelines used by the'glossary task [group, and move explanatory material out of the definitions and mto the appendix. A definition is not to have an "include list" attached to it. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

In 12-1.1.1.2 and 13-1.1.1.2 add a new sentence and position it just prior to the current second sentence, but immediately after the new sentence being added by the action on Comment 101-323 (Log #54) to read:

"The term nursing home, wherever used in this Code, shall include nursing and convalescent homes, skilled nursing facilities, intermediate care facilities, and infirmaries in homes for the aged." COMMITTEE STATEMENT: The new sentence is wording identical to that currently part of the defmition. The committee disagrees that it should be moved to the appendix. It is important that it be retained. Therefore, it is being added to the body of the Code, but separate from the definition. This should meet the submitter's intent. NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 17 NOT RETURNED: 1 Cxowley


101- $25 - (12-1.$ Ambulatory Health Care, 13-1.3 Ambulatory Health Care): Reject SUBMITI'ER: Mayer D. Zimmerman, U.S. Dept. of Health and Human Services COMMENT ON PROPOSAL NO: 101-417 RECOMMENDATION: Delete the words ~ : : : ~r ~ : - r : F:'2cn~. 7.: ~he mine ~me , add a new sentence: "Facilities with fewer than four patients at the same time shall be r)ermitted to comply with another Chanter of this Code". - SUBSTANTIATION: The committee rejected my recommendation to delete the words "four or more patients at the same time" from this section, with two Committee Statements: 1. The submitter has not provided adequate substantiation to make the requirements so strict", and 2. The level of risk where there are fewer than four patients is less because of the high staff-patient ratio.

I believe I did provide adequate substantiation by stating that patients in an AHC are often undergoing surgery and are anesthetized or otherwise rendered incapable of self preservation. If the committee feels that the AHC requirements are too strict for a facility, perhaps that facility would qualify to come under Chapter 26/27 Business Occupancies, and certainly could utilize that chapter. I believe that Chapter 12-6/13-6 is indeed the appropriate

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occupancy chapter for facilities with anesthetized patients undergoing surgery, ff the level of protection provided is too great, and protection-m-place is not required, the facility should fall under another occupancy. Leave this occupancy for those patients for whom it was intended, regardless of whether there are tow, three, four, or more than four patients.

Staff-patient ratio is a poor justification for allowing a lesser level of safety. Anyone famihar with any health care occupancy (not just ambulatory health care centers) knows full well that the number of staff present at any given time is unreliable and cannot be depended upon. Staff is often called away for a variety of reasons

• (telephone call, bathroom visit, needed in another OR, etc.). In deleting the "four or more" requirement, the committee

should consider adding a statement to the effect that facilities with fewer than four patients may utilize another Chapter of this code.

• The fire protection features of an occupancy chapter should be predicated upon the nature of the patients, not the presence (or absence) of staff.

I urge the committee to reconsider its position on this issue of critical importance. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The change proposed by the submitter does not add clarity. The subject is adequately cdvered by the current definition. Also, the wording proposed would not be appropriate for a definition. Requirements are not to be made part of definitions. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16 NEGATIVE: 1 NOT RETURNED: 1 Crowley

EXPLANATION OF NEGATIVE: ZIMMERMAN: Again, I cannot agree with the substantiation

provided. Current Section 12-1.2.2 states that certain ambulatory care facilities "...shall be permitted to be classified as business occupancies..." Placing this statement as part of the definition of an ambulatory health care does indeed add clarity to the definition by defining the occupancy. The wording provided is a definition-it is a statement that other occupancy chapters may apply. I must go on record again as being opposed to the concept that a building which provides medical treatment to a patient which anesthetizes him or otherwise renders him incapable of self-preservation could be a business occupancy merely because fewer than four patients are treated at the same time. Perhaps the time has come to divide the new ambulatory health care facilities chapter(s) into two parts; one part for ambulatory sur~i.cal centers and one part for ambulatory health care facihties. I cannot see that even a single patient who is on life support equipment, or even not on life support equipment but in a critical care area such as an operating room, could be in a facility classified as a business occupancy. NFPA 99, Health Care Facilities, requires that facilities with a critical care area have a Type 1 essential electrical system with a generator, but this committee would call the occupancy a business occupancy.


101- 326 - (12-2.2.2.6, 12-2.2.2.7, 13-2.2.2.6, 13-2.2.2.7): Reject SUBMITTER: Kenneth S. Fanlstich, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101429 RECOMMENDATION: Accept proposal 101-429 in principle. In lieu of the text proposed, add the following new text in the same place to 12-2.2.2.6 and 13-2.2.2.6 as follows: "..., enclosures of linen chutes,...".

At the same time, 12-2.2.2.7 and 13-2.2.2.7 should be revised to included similar text. Add the words "...or linen chute enclosure..." after the text "...in a stair enclosure..." SUBSTANTIATION: This proposal should have been accepted for the reasons provided in my negative technical committee ballot. In lieu of permitting a door in any required enclosure of a vertical opening to be held open as suggested by the proposal, limit it to linen chute doors. This is the typical compliance problem. It should be the committee's intent to permit doors to linen chutes to be held open if the requirements of 5-2.1.8 are followed. Following the requirements of 5-2.1.8 provides adequate protection. By not permitting this measure, the level of safety is actually lowered in real life situations. We have seen time after time at health care facilities where these doors to linen chutes are blocked open because it is not convenient for staff to hold the door open while placing soiled linen into the chute. To prevent only

one linen chute door to close at a time, 12-2.2.2.7 and 13-2.2.2.7 should also be modified so all linen chute doors in a vertical enclosure close at the same time, similar to what is reqOired for stair doors. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 101-329 (Log #146). NUMBER OF COMMITTEE MEMBER~ ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 17 NOT RETURNED: 1 Crowiey

(Log *~28 $) Committee: SAF-HEA

101- $27 - (12-2.2.2.6, 13-2.2.2.6): Reject SUBMITrER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101429 RECOMMENDATION: Add the following text to the list of doors that may be held open.

"...linen enclosure, trash chute enclosure...". SUBSTANTIATION: These doors are often tied or wired in the open position because the individual loading the trash or linen can not easily hold the door open and load material into the chute at the same time. This is not an uncommon occurrence. By allowing these doors to be held open by an automatic closing device that will release upon activation of a smoke detector installed in accordance with the requirements of 5-2.1.8(c) you would be assuring the door will be closed during a fire. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 101-329 (Log #146).. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 17 NOT RETURNED: 1 Crnwley


101- $28 - (12-2.2.2.6, 13-2.2.2.6): Reject SUBMITTER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-429 RECOMMENDATION: Add an Exception to 12-2.2.2.6/13-2.2.2.6 to read:

"One door at a time. within a reouired enclosure of the same vertical opening, may be held onen bv an automatic release de~ce." SUBSTANTIATION: This might meet the intent of submitter and meet the needs of the situation and committee's concerns. The ability to hold open laundry chute doors is important to staff operational needs. But, the need is only temporary while a person is placing soiled linen within a chute door opening. In fact within my facilities the chute doors are electronically interlocked so only one chute door can be open at a given time. This is to prevent injury to employees from linen falling from above.

Please, the committee must pay attention to those in the field who are well aware of the nurse/staff - fire protection interface. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 101-$29 (Log #146). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMIT17EE ACTION:



101- 329- (12-2.2.2.6 and 13-2.2.2.6): Reject SUBMITrER: Peter A. Larrimer, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-429 RECOMMENDATION: Accept the original proposal. SUBSTANTIATION: This will clarify that it is already permitted. Chapter 12 and 13 do not prohibit what the submitter is requesting. 12-2.2.2.6 permits ~ doors to be held open only if... On the other hand, 12-3.1 requires vertical openings to comply with 6-2.4 and 6-2.4 specifically permits certain vertical servtce openings (6-2.4.10) to be automatic closing. Even more important is that 6-2.4 does not restrict any types of fire doors from being automatic closing in accordance with 5-2.1.8, 6-2.3.2.1(b) requires fire doors

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to be self or automatic closing. (NFPA 80 2-8.7 does not restrict them from being automatic closing either.)

This deficiency is frequently cited byJCAHO and this fix has seemed to work the best. Please read the negative comment, it is right on target. COMMITTEE ACTION: Reject. COMMHWEE STATEMENT: This paragraph applies to means of egress doors. Thus, it is not an appropriate location for provisions applicable to linen chutes. Linen chutes are addressed 12-5.4 and 15-5.4. Also, the committee realtirms its earlier action in the ROP. See the committee statement for the rejection of Proposal 101429. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMIITEE ACTION:


(Log #$39) Committee: SAF-HEA

101- 330- (12-2.2.2.10): Reject SUBMITTER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101430 RECOMMENDATION: Accept the original proposal. SUBSTANTIATION: The issue is not and should not be death of a patient. This feature is for safety and is listed as a requirement in other occupancy chapters such as 1 and 2 family dwellings, lodging and rooming and Board and Care. The cost of adding this feature in NEW hospitals is minimal. The condition of the occupants in a healthcare occupancy and the real possibility that they may need assistance while in a bathroom is evidenced by the requirement for nurse call systems in bathrooms. If the patient activates the call system, but the staff can not open the door because it is locked, valuable time will be lost. l reiterate, the cost of this feature is minimal and the potential benefit can be life saving. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The issue raised by the submitter is not a problem. See the Committee Statement for the rejection of Proposal 101430. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 351 - (12-2.3.3 Exception No. 1): Reject SUBMITTER: Kenneth S. Fanlstich, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101433 RECOMMENDATION: Change action on this proposal from Reject to Accept in Principle. In lieu of using the words "litter borne", add the word "non-ambulatory" to the exception as follows:

"...use of non-ambulatory inpatients..." SUBSTANTIATION: The Technical Committee rejected my proposal since my substantiation was considered inadequate. This comment provides additional rationale why a reduction in the level of safety does not happen. If ambulatory inpatients are treated in spaces served by 44 in. wide corridors, they can egress/relocate by themselves given the fact they are ambulatory by definition. Even if staff assistance is needed, egress is easily done since obstacles such as gurneys, crash carts, etc. won't be located in these corridors.

A typical situation where this can be an issue is as follows: A clinic is consti'ucted contiguous to a Healthcare occupancy without (for whatever reasons) a 2 hour separation. The clinic then must meet healthcare requirements. Even if only ambulatory inpatients being treated for drug/alcohol dependency use this clinic space, 8 ft wide corridors would be needed. But what purpose or needed safety would these 8 ft wide corridors serve for these ambulatory inpatients?

Accepting my proposal as revised would permit 44 in. wide corridors where all occupants (inpatients, staff, etc.) are ambulatory. COMMITTEE ACTION: Reject. COMMITTEE STATFaMENT: The submitter's suggested wording would change the Code significantly withoutproper justification. NUMBER OF COMMfVrEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 332- (12-$.4.3.1): Reject SUBMITEER: Peter A. Larrimer, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-442 RECOMMENDATION: Accept the original proposal. SUBSTANTIATION: This proposal does not have a big potential impact ton buildings as stated by the committee, especially in new health care facilities. The fire alarm system hardware (cost of system) is effectively already required by the existing codes as shown by ## below.

The committee states "The requirement is not justified for waterflow alarms where there is only a single sprinkler system." Sprinkler waterflow alarm provide only one input to the hospital fire alarm system compared to all of the other alarm devices such as manual pull stations and smoke detectors that would be affected by the committee's response. The case identified by the committee will need to be handled on a case by case basis, even as it is today. Most existing sprinkler systems in health care facilities have water flow switches on at least a per floor basis. Existing hospitals aren't even required to be sprinklered. When is the last time you went into a sprinklered hospital that had only one sprinkler zone for the whole building? I never have. My proposal permits zoning by zone, area, or floor so a single flow switch on a floor in an existing system would be permissible.

The committee's argument that "non patient care floors might not be zoned by smoke compartments and there might not be any central staff location to which staff could respond" has nothing to do with my personal. Nowhere is there any mention of a ~central staff location to which staff can respond". My proposal would permit a non-subdivided floor to be treated exactly the same way it IS n o w .

The time honored "Dr. Red" announcement coming over any loudspeaker is only valuable when "Dr. Red" knows "where to go". That is what my proposal is asking for. What the committee is permitting is equivalent to saying Dr. Red, Dr. Red... without telling the hospital staff where Dr. Red needs to "report". Not only that, loudspeakers may not be present.

Exception No. 2 to %6.$.5 addresses hospitals among others. I am not asking to have everyone in the building be notified as the committee contends, just "the attendants and other personnel require to evacuate occupants". On a floor where everyone evacuates himself or herself, such as a non-subdividied floor, this proposal would not mandate anything additional to what is already required. No attendants or other personnel would need to be notified, just those occupants on those floors.

## NFPA 101 requires the fire alarm installation to be in accordance with NFPA 72. NFPA 72 requires the following:

1-5.7.1.1 The primary purpose of the fire alarm system annunciation is to enable responding personnel to identify the location of a fire quickly and accurately and to indicate the status of emergency equipment or fire safety functions that might affect the safety of occupants in a fire situation. All required annunciation means shall be readily accessible to responding personnel and shall be located as required by the authority having jurisdiction to facilitate and efficient response to the fire situation.

1-5.7.1.2 Fire alarm system serving two or more zones shall identify the zone of origin of the alarm initiation by annunciation or coded signal.

1-5.7.3 For the purpose of alarm annunciation, each floor of the building shall be considered as a separate zone. Where a floor is subdivided by fire or smoke barriers and the fire plan for the protected premises allows relocation of occupants from the zone of origin to another zone on the same floor, each zone on the floor shall be annunciated separately for purposes of alarm location.

The only thing that I am asking for in the proposal is to prohibit a general evacuation signal from being used where the responding personnel are the hospital staff (the attendants and other personnel require to evacuate occupants from the zone of origin).

If the responding personnel were only the fire department, then a general evacuation signal with a simple annunciator to direct the fire department personnel would be sufficient. Even then, the system would have to be zoned by floor as a minimum to meet 1-5.7.3. But, where hospital staff are the responding personnel (RACE) the staff shouldbe properly notified by the alarm system.

See my comment on ROP 101-444. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Code currently requires alarm annunciation. The submitter's wording would require a specific form of occupant notification that would have to be by voice. Note that %6.$ requires audible and visible signals. The change is not justified as a minimum requirement of this Code.

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NUMBER OF COMMITI 'EE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- $$3 - (12-$.4.$.1): Accept SUBMITrER: Peter A. Lammer , Dept. o f Veterans Affairs COMMENT ON PROPOSAL NO: 101-444

[ RECOMMENDATION: Reject the proposal. SUBSTANTIATION: How does the technical commit tee expect the designer of a fire alarm system to design to an administrative plan that does n o t exist for a new fadUty? Generally, the user writes the plan after taking occupancy of the facility. What is adequate informat ion (very subjective)? For new facilities that do no t have these plans in ~31ace, this r equ i rement is meaningless. An appendix note with this information may help the designer "add on to an existing building where a plan is in place, but, for facility to be newly constructed, a designer can no t "adequately" design to a non existent plan.

With the acceptance of my proposal (See my c o m m e n t on 101- 442), you could do exactly what you are t r~ng to do for an add on, let the designer de te rmine the level of noufication and annuncia t ion based on the existing fire alarm system and evacuation plan. COMMITrEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


today's standards. "Dr. Red" depends on h u m a n actions - is given over a non-listed - unreliable PA system - and most importantly is delayed.

Second, even according to the heal th care commit tee member represent ing National Electrical Manufacturers Association - new fire alarm systems are required to be zoned according to smoke compar tments .

Third, adequate substantiation was provided - logically" speaking. But here are a couple examples - actual cases where thin submitter was involved in litigation.

Patient 's bedding on fire - patient 's clothing quickly (second) ,involved. Room smoke detec tor activates. Fire alarm system sounds a coded a l a r m . [Coded signal does no t readily identify the zone]. Nursing staff in the immediate area walk away f rom the fire room to the coded signal chart and count the bells twice to conf i rm code. Forty plus seconds tick by while the pat ient is bu rn i ng to death. F i n d i n g the coded signal means their ward - nurses beg in the room to room effort to search for fire and close doors. The 6th room very near where the nurse was to begin with - the burn ing pat ient is discovered - valiant efforts taken - but pat ient dies within days. Early warning without immediate notification is a was te .

Now I ask the commit tee - how does it make any sense at all that additional smoke detect ion is a d d e d - sophisticated early detect ion devices, yet the commit tee would allow a general evacuation signal for the entire building with no ready means to notify staif where the fire is located. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: See C o m m e n t 101-334 (Log #378) and C ommen t 101-$52 (Log #147). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITrEE ACTION:



101- 334- (12-3.4.3.1): Reject SUBMITTER: Eugene A. Cable, U.S. Depar tmen t of Veterans Affairs COMMENT ON PROPOSAL NO: 101-445 RECOMMENDATION: Revise text:

~Occupant Notification. Occupant notification shall be accompl ished automatically and without delay in accordance with 7-6.B." SUBSTANTIATION: I am very much relieved to see the committee 's s ta tement that anything "involving a delay in staff notification is unacceptable for heal th care occupancies". Section 7-6 is get t ing tough to follow - the three added words above would make the committee 's in tent more clear.

I hear this criticism of code writing on a regular basis: "If that is what ~ in tended - why didn ' t the.lust say i t " . Here is an opportuni t~ to keep it simple - and make code in tent clear.

As stated m another commen t there are many fire alarm features available today to prevent unwanted alarms - such as alarm verification. Unfortunately they involve delaying alarms. In health care we do n o t want to sacrifice early warning. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The words "without delay" were removed to allow alarm verification, especially for smoke detector activations. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 355- (12-$.4.3.1): Reject SUBMITrER: Eugene A. Cable, U.S. Depa r tmen t of Veterans Affairs COMMENT ON PROPOSAL NO: 101-441 RECOMMENDATION: Add text:

"This notification shall include means to readily identify, without delay, the zone or area where fire is detected."

Excention: Where alarm system zonin~ does no t match smoke comnartments , notification by zone n e t NFPA 72 is accept~lPl¢~ SUBSTANTIATION: First, the "time hono red "Dr. Red ~ a n n o u n c e m e n t is terribly antiquated, inadequate, and obsolete by

(Log #$82) Committee: SAF-H EA

101- 336- (12-3.4.3.1): Reject SUBMITTER= Eugene A. Cable, U.S. Depar tment of Veterans Affairs COMMENT ON PROPOSAL NO: 101-444 RECOMMENDATION: Revise text:

~Notification of staff shall automatically and without delay provide adequate informat ion to implemen t the building evacuation and relocation plan." SUBSTANTIATION: The "without delay" text is n e e d e d due to confusion concerning alarm verification feature. A $0 sec to 60 sec alarm verification feature for smoke detect ion before an alarm is activated is totally counter-product ion and in fact negates the early warning benef i t of smoke detect ion in heal th care occunancies. Yes, alarm verification may be of benefi t in o ther occupancies where everyone is s leeping and false alarms are a serious problem but n o t in heal th care where staff are present 24 hr per day within the critical smoke compartments .

Said ano ther wa F. in my VA experience, most times staff discovers a fire in hea l th care occupancies prior to smoke detection. Occasionally a smoke detector will activate the fire alarm system at the same t ime staff discovers the fire, and very se ldom a smoke detector will activate jus t pr ior to staff discovery. Allowing a $0 see to 60 sec delay would relegate smoke detect ion to almost always activating after staff activates manual pull.

Case in po in t - a litigation case I worked as exper t witness: A corr idor smoke detec tor is located jus t outside a patient 's room. The patient 's bedd ing catches fire - 4 p m - a passing doctor discovers the fire at the m o m e n t first smoke enters the corridor. Doctor immediately goes to assist pat ient and at tempts to cont ro l /ext inguish fire. During doctor 's a t tempts to help pa t ien t the corr idor smoke detec tor trips, doc tor is unable /unwil l ing to leave pat ient to summon help - so smoke detect ion is first to sound alarm which immediately brought addit ional staff to the doctor 's assistance. An additional ~0 sec to 60 sec delay - while pat ient bedding is burn ing - is critically important . If such a delay was des igned into the system the litigation outcome would have been drastically affected.

The same scenario serves as an example support ing the need for heal th care fire alarm systems to immediately, automatically, notify staff of the alarm location. Delays correctly allowed by Code - awaiting a "Code Red ~ a n n o u n c e m e n t is total unacceptable - not to men t ion the Code Red a n n o u n c e m e n t is given over a non-llsted - no reliability PA system.

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COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Per the Committee Action on Comment 101-353 (Log #148), the sentence proposed to be modified has been deleted. The issue is moot. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


COMMITTEE STATEMENT: The proposed change has introduced new material that has not had public review. As such, it must be held for processing during the next revision o/de. With respect to the deletion of Exception No. 1, see Comment 101-337 (Log #151)• NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITFEE ACTION:



101- 337- (12-3.4.5.$): Reject SUBMITTER: Joshua W. EIvove, U.S. Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-445 RECOMMENDATION: Accept proposal which deletes 12-$.4.5.3 in its entirety. SUBSTANTIATION: I recognize this recommendation will likely appear in ROPs in perpetuity, so long as the requirement for smoke detectors is included in the Code (as will be the case should it ever be deleted). Yet, l 'm forced to continue the argument and agree with Mr. Crowley and Mr. Zimmerman that there is no technical or statistical evidence of a need for this costly addition, especially since all new nursing homes will be protected by QRS: The health care section voted to endorse this change for the 1997 edition because this requirement was being self-imposed by the industry. However, the proponent of this change did (does) not represent the entire industry, ff some facilities wish to install additional detection based upon their lack of staffing, let them do so voluntarily at their own expense. Do not force the rest of the industry to add protection when there is nothing to substantiate it technically or at fadlities that may have "suffident" staff. COMMITFEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has not provided any new information that would justify the deletion of the requiremenL NUMBER OF COMM1TIT~ MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16 NEGATIVE: 1 NOT RETURNED: 1 Crowl~

EXPLANATION OF NEGATIVE: ZIMMERMAN: I still cannot see any.j.ustification-technical,

financial, ethical or otherwise-for reqmrmg corridor smoke detection in a building protected throughout by quick response sprinklers. The mandated addition of detection provides no additional safety since smoke detectors are not redundant to sprinklers. Smoke detectors do not extinguish fires.

(Log #377) Committee: SAF-H EA

101- 339- (12-3.4.5.3): Reject SUBMITI'EPa Eugene A. Cable, U.S. Deparmaent of Veterans Affairs COMMENT ON PROPOSAL NO: 101-445 RECOMMENDATION: Delete 12-3.4.5.$ in its entirety. SUBSTANTIATION: There was no technical substantiation for adding corridor smoke detection last code cycle. The submitter is correct that QR sprinkler protection is adequate to providing life safety in accordance with the Life Safety Code objective.

(a) Ours and other research has shown - back in 1991 - that smoldering fires are not a nroblem in heath care occupancies, it takes approximately 4 hr in a closed room to build up lethal amounts of products of combustion. Staff will discover the situation before 4 hr.

(b) There are ample redundancies to automatic sprinklers, particularly staff and other patients actions in the area.

(c) The corridor smoke detection system only politically "obviates" the need for in-room smoke detection. The corridor smoke detection system in no-way-is equal to or substitutes for in room smoke detection from a performance analysis perspective. Even the in-room smoke detection benefit is highly questionable - intimate with ignition fires are almost always fatal (my experience) regardless of in-room detectors a n d / o r QR sprinklers.

I have to state - that as long as 12-3.4.5.3 is in the Code - I will always point to it as an example of bad code - a requirement added, with no technical substantiation. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 101-$$7 (Log #151). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 338- (12-3.4.5.3): Hold SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-445 RECOMMENDATION: Revise to read: 12-3.4.5.$* Nursing Homes and Limited Care Facilities. An

approved, automatic smoke detection system shall be installed in corridors throughout smoke compartments containing patient sleeping rooms and in spaces open to corridors as permitted i~ a u z f n g ~.zr',.~ by 12-3.6.1.

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+IJ~l~++ATl~1'IA+I~O~lq~Heal+th " care 'occupants have, in large part, varied degrees of physical disability, and their removal to the outside or even disturbance by moving is inexpedient or impractical in many cases. Similarly, recognizing that there may be an operating necessity for the restraint of the mentally ill, often by use of barred windows and locked doors. Fundamentally, early discovery and extinguishment of incipient fires, and prompt notification must be relied on to reduce the occasion for evacuation of buildings of this class to a minimum. Only a monitored, complete smoke detection system will assure the ~fotimum safety of the unfortunate occupants.

MMITrEE ACTION: Hold.

(Log #CC$50) Committee: SAF-HEA

101- $40 - (12-$.6.$.1): Accept SUBMrlTER: Technical Committee on Health Care Occupancies COMMENT ON PROPOSAL NO: 101-446 RECOMMENDATION: At the beginning of the new third sentence to 12-3.6.3.1 and 13-3.6.3.1, replace the word "Undercuts" with "Clearance between bottom of door and the floor covering'. SUBSTANTIATION:, The chaT,~.,ge in terminology is being made to avoid using the word undercut which has a negative connotation. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


(Log #2"84) Committee: SAF-HEA

101- 341 - (12-3.6.3.1 and 13-3.6.3.1 ): Reject SUBMITTER: Robert J. Thompson, U.S. Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-446 RECOMMENDATION: Revise new third sentence to read:

"Undercuts averaging 1 in. (2.5 cm) across the width of the door shall be permitted for corridor doors." SUBSTANTIATION: Floors across door width in closed or open position may be uneven, but the effectiveness of this requirement is retained bg this revision. COMMITI'EE ACTION: Reject. COMMITI'EE STATEMENT: The 1 in. maximum is what the committee intends. The submitter has not justified why the measurement should be an average.

175

N F P A 101 - - F9 9 R O C

NUMBER OF COMMITIT, E MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- $42 - (12-$.6.$.$ and 15-$.6.$.$ (New)): Accept in Principle SUBMITYER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-448 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-HEA give consideration to Mr. Crowley's comment on affirmative. SAF-AAC notes that the prol?osed first sentence introduces/perpetuates bad precedence• It reads:

CROWLEY: The first sentence is an incomplete list and stated in negative terms. Delete the first sentence. Add "only" to the beginning of the next sentence. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

[ Move the proposed first sentence of 12-$.6.$.$ and 15-$.6.$.$ to [ Appendix A-12-$.6.$.3. and A-15-$.6.$.$, but position the sentence [ to become the first sentence of the Appendix items.

COMMITrEE STATEMENT: The material addressed by the first sentence is helpful and needs to be retained in the Appendix. It should not be deleted. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


(Log #$$6) Committee: SAF-HEA

101- $45 - (Ambulatory Healthcare Chapters 18 and 19 (New)): Accept in Prindple TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) notes that the two uew chapters on ambulatory health care occupancies will be numbered to become Chapters 20 and 21 (not 18 and 19) per action on Comment 101-1 (Log #1). SUBMITrER= James IC Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: (paragraph # changes are not shown in legislative format) (changing health care to ambulatory health care is not shown is legislative format)

SECT!ON 12 6 CHAPTER 18 NEW AMBULATORY HEALTH CARE FACILITIES

P 1 J A D T ~ n 1 0 ] K ~ [ I ? T . . .T 'C 'AT T L I P A r P ~ , ' ~ I , ¢ " . . r ~ T T D A M P T I ~ e '

SECTION 18-1 GENERAL REQUIREMENTS 18-1.1 Application. 18-1.1.1 General. 18-1.1.1.1 The requirements of this chapter apply to

(a) New buildings orpor t ions thereof used as ambulatory health care occupancies (see Section 1-4.1); and

(b) Additions made to, or used as, a ambulatory health care occupancy (see 1-11.6 and 18-1.1.4); and

Exception to (b): Additions classified as occupancies other than ambulatory health care that are properly separated from the ambulatory health care occupancy in accordance with 18-1.2.1 and conform to the requirements for the specific occupancy i~

~I, ~ apprcpr 'ate. (¢) Alterations, modernizations, or renovations of existing

ambulatory health care occupancies (see 1-11.7 and 18-1.1.4); and (d) Existing buildings or portions thereof upon change of

occupancy to a ambulatory health care occupancy (see 1-11.12).

. . . . . :--`1 . . . . :'-~ . . . . . * " ~ " " " - - bcc~ prc;-~ac~ ":~ acc~.rdance with

!2 !.1.!.2 Th':: chapter c :~b! 'ahe: l'fc ~ c ~ " requirement, for ~hc

";Y~;?::.^7" ~g~ ZZ"-:.L".:Y2~...-'2:7 ". =27 :L~':L2 -.'~." Y "2 ~:;=7. ~ "

1 0 1 1 1 • " L ] ' ~ I * I I , , , . . . . . . . . . . . . . : - . . l k ~ l l I - . - - * 1 - * ~ . ^ . ' 1 . . - . ~ B I g A ~

" - - . . . . . . . . . . . . . . . . . . . . . . J r . . . . . . . . . . JL"" " ~ . . . . . . . . . . . . . . . . . . C ^ . ~ t - . ~ : . . . . ~ j i n i ) ~ = + . ^ ~ ` 1 . . . . . . . . . : - ` 1 .1 I - . . . . . . . . . . . . ! k . . . . . . . ~11 .

. . . . . . . . . . . . . . . . . . ", . . . . . . . . . . . . . . . . . . " 1 . . . . . . . . . . . . l

18-1•1.1•2 ~ Ambulatory health care facilities shall comply with the provisions of Chapter $6 and this .CJa~&e,L ~ - , whmhever is more stringent . . . . . r . . . . . . . . . . . . . . . . . . . . .

C

18d.1.1.3 -4-2-6A-A~ This .Qlap_ted_ ~E-~OH- establishes life safety requirements, in addition to those required in Chapter $6, for the design of all ambulatory health care facilities * ~ a t meet t h e

rcqu~rcmcn:z of as described in 18-13. 18-1.1 •1.4 ~ Buildings or sections of buildings that primarily house patients who, in the opinion of the governing body of the facility and the governmental agency having jurisdiction, are capable of judgment and appropriate physical action for self-preservation under emergency conditions shall be permit ted to comply with chapters of the Code other than Chapter 18. 1 0 1 1 1 ~ I ' * . k ~ l l l . . . . . . . . . : . ~ A . l - . ~ . : ~ 1 , . . . : I A : - - - - 1,. . . . . : . . . . . + ~ : ~

Z.v- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . ~ . . . . .

of thin Code :: . . . . . . . . . . . . . . . . . . . . .1 . . . . . . . . . . . . . . ~ . . . . . . . 1 . ^ ~ + . . ~ 1 ^ ^ b ~ ` 1

9 1 1 1 O l ) • . . ' l ~ l : . . . . . . . * : . . . . ¢ / - . • . : I A : ~ - - * 1 ~ * k . . . . . . I ` 1 ~ .

= 7";~E'..~:'^'2"1"g ~ 2 %'A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

I ~ . , : 1 . - I : . . . . . . . . , . =1~ . . . . £ . . A + I - . . . . . . . . . . . . . ~ i - - . ^ . . ~ ' l ~ ^ A : ~ 1 ~1 1

that dc . . . . v . . . . . e hc . . . . . ~ . . . . . . . . . . . . . . . . . . . . . . . . r - - - -

18-1.1.1.5 ]4-* The recpirements of this chapter are based on the assumption that staff is available in all patient occupied areas to perform certain fire safety functions as required in other lP8aragraphs of this chapter.

-1.1.2" Goals and Objective. The ~oals and obiectives of Sections |-~ and 1-6 shall be met cbjec~;'e e f * . - ~ : z chapter i: te pre'Ade a

, c ~ c . .~c =rcm ~.e e~ect~ c. =re with due consideration for functional requirements. This is accomplished by limiting the development and spread of a fire emergency to the room of fire origin and reducing the need for occupant evacuation, except from the room of fire origin. 18-1.1.$ Total Concept. All ambulatory health care facilities shall be designed, constructed, maintained, and operated to minimize the possibility of a fire emergency requiring the evacuation of occupants. Because the safety of ambulatory health care occupants cannot be ensured adequately by dependence on evacuation of the building, their protection from fire shall be provided by appropriate arrangement of facilities, adequate staffing, and development of operating and maintenance procedures composed of the following:

(a) Design, construction, and compartmentation; and (b) Provision for detection, alarm, and extinguishment; and (c) Fire prevention and the planning, training, and drilling in

programs for the isolation of fire, transfer of occupants to areas of refuge, or evacuation of the building. 18-1.1.4 Additions, Conversions, Modernization, Renovation, and Construction Operations. ~ . . . . . . . . . . . . . . . . . . , 18-1.1.4.1 Additions. Additions shall be separated from any existing structure not conforming t o the provisions within Chapter lg by a fire barrier having at least a 2-hr fire resistance rating and constructed of materials as required for the addition. (See 1-11.2 and 1-11.61 18-1.1.4.2 Communicating openings in dividing fire barriers required by 18-1.1.4.1 shall occur only in corridors and shall be protected by approved self-closing fire doors. (See also Section 6-20

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N F P A 101 - - F 9 9 R O C

18-1.1.4.$ Doors in barriers required by 18-1•1.4.1 shall normally be kept closed.

l~ceptlon: Doors shall be permitted to be held open if they meet the requirements of 1 8 - 2 . 2 . 2 . 6 . 18-1•1.4.4 Chan~es of O c c u v a n c v C~avc.'-z'~,:=. C=.=vc::'~.".= Changes of occuoancv shall comply with 1-11.12. A :a=:::~'c==.

CZ=:Z, 'Y ,=5;72~ ' f C . ~ = ' = : ? 2 3 % 7 7 7~:~==":= ='YO:Z2.Y.';';.; . . . .

. . . . 11 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ¢~ . . . . . . . . [ " . . . . • - *

occup==c 7 =uSc!.~:'K~cat]an. Exception: A chan~e from a hospital or nursin~ home to an

amhqlatory health c~re occunancv shall not be considered a change in OCCUPancY. 18-1.1.4.5" Renovations, Alterations, and Modernizations.

::7::= :~Z~:~ ~=? ~.: ..".Z~ "-='- • .~ :=-" " :~7.%~ ;'22=:=3277.:". ~=.-T':~ . . . . . accard=.=cc "•-'~ . . . . . ($¢e 1-11•73 . . . . . . . . . . . a . . . . . . . . . . . . . . .

fadliW, the =utcmzdz :p-nk!er requ'remc=~ ~f C =pier 1~ :h~!

I S n o + i v . . . . . . . . . . . . . ~ . . . . . . g . . . . I " I " . . . . . ~ . . . . . . . . . . . I " . . . . . . . . . . - - . ^ - - +~ . . . . . . : . . . . . * . ^C 1 q 1 ~ - - - -A 1 CA O q q . t , , . ~ l l - 1 . . . . . h .

smc . . . . . . . v . . . . . . . . . . r- . . . . . . . . . . . . . ~, . . . . . . 1 --- -~-r . . . . . , supc:--zcd =utan:='2c :prinklcr =}:tam "n =cccrd=:c= ; ; ' ~ !£ 2.E.2.

are den*- in = ncnzp~n-~Jered facw-"/, ~ e ::qu'rcrn.en~ cf !~ ~,5.!

. . . . . . l . . . l ~ l l - - ^ * __ . . , I I . . . . 1 1 4 : - . - g ' ^~ • k - - I . . . . * L . ~ +

18-1.1.4.6 Construction~epair and Improvement Operations. See 1-11.11 for life safety provisions during construction. 18-1.2 Mixed Occupancies. (See also 4-1.12.) 18-1.2.1" Sections of ambulatory health care facilities shall be permitted to be classified as other occupancies provided they meet all of the following conditions:

(a) They are not intended to serve ambulatory health care occupants for purposes of ho~mim~, treatment, or customary access by patients incapable of self-preservation;

(b) They are separated from areas of ambulatory health care occupanoes by construction having a fire resistance rating of at least-~, 1 hr.

L -~:~;.~k ~. .k'=:~=-~'].:-'--. =.:7~'2" ~.:.::,.'L'~'.~'~'-'.'.'L ~'--' -'_--."~'2: 2;~

t~ ~c c!a~'ficd a= Su~!nc=~ czcupa~c'c= c.r ='a~u[~t~. G" .~.cz2*..% care fact . . . . . , r . . . . . . . . . . . . . . . . . . . . . . r . . . . . . . . . . . . . . . . . . . c a : - . . . . . . . . . . b . . . . . * l ^ . . . b . ~ 0 a . . - g= . . . . : . . . . . . . . . . . 4 . . . . . . . . . . : ^ - -

C . . . . . . . . . . 1 . . ^ ^1+1~ ^+1^ - -~ . , , I . . . . . . 1 "+ * - . k ^ . - for . . . . . . . . . . . . . . . . . . c~'e p . . . . . . . . . . . . . : . . . . . . . . . c. lg i .2 .3 ?==bulz.tc~" ~c=.!~ ~..-c :ccup===c"cz in bu~l~ng: ~::~i=:g ^ . ! - . . . . . . . . . . . . . ' . 0 . I ~ I I I . . . . . . . I . + ^ I . . . . . . . + ^ + 4 g . - - - - * k - - - - L - . . .

18-1.2.$ All means of egress from ambulatory health care occupancies that traverse non-ambulatory health care spaces shall conform to requirements of this Code for ambulatory health care occupancies.

Exception: It shall be permissible to exit through a horizontal exit into other contiguous occupancies that do not conform with ambulatory health care egress provisions but that do comply with requirements set forth in the appropriate occupancy chapter of this Code, provided the occupancy does not contain high hazard contents. Th..c hc.-.zcntz2 e==:-t :~=21 corn_p! 7 : : -~ ~ c rcqu'rcr:..cn= : f

1 8-1.2.4 Egress provisions for areas of ambulatory health care facilities that correspond to other occupancies shall meet the corresponding requirements of this Code for such occupancies.

. . . . . . X" . . . . . . ~ -gg " .1 .-_+11 k . . . . . . + g ' ^ . + h . . . . . . . . ' . . . - ~ - ^ I - . . ' ^ ^4 "

fac'l'fiz= =~=l[~='.•c rc..ean~ ",f c=rz=:. -r=.','~c~ in =zcc.=.~=zc -;-:~

18-1.2.5 Any area with a hazard of contents classified higher than that of the ambulatory health care occupancy and located in the same building shall be protected as required in 18-$.2.

18-1.2.6 Non-ambulatory health care related occupancies dassified as containing high hazard contents shall not be permitted in buildings housing ambulatory health care occupancies. 18-1.$* Spedal Definitions. Ambulatory Health Care Facility. A building or part thereof of-~ b ~ used to provide services or treatment to four or more ~atients at the same time that meets the criteria of ~ (a) or (b)

elow. (a) Those facilities that provide, on an outpatient basis, treatment

for patients t~g~ would render the patients incapable of taking action for self-preservation under emergency conditions without assistance from others.

(b) Those facilities that provide, on an outpatient basis, ~ngiea~ . . . . . . . . . . . . . :-:" . . . . . . . ' anesthesia oatients incanable of taking action for segDreservation under emer~encv condition without assistance of o ther .

medi=2, au-c . . . . . . . . . , . . . . . ~, . . . . . . . . . . . . . . . . . .

2! hr b=~: fer thc hc.ua!ng ~f f~.u: cr :-..=re Fcr=~r- "a'h~. a=c

A. . . + . . . . : A ~ + ~ . ~ I I . . . . . . . . . . - I I : - - . ' . - - , ~ . . . . . . . I - . . . . . . + . I

. . . . . a -+= ^= i l ~ l - "~ " . . . . . 1 I I I . . . . . . . I . . - - - - : . - - I ~c;'c!c~mc==~l d."~ . . . . . . . . . . . . . . . . . . . . . . . . . --- . z . . . . .4 . . . . .

~T• . . _ • - - - - I LT^ - -~ A I . . . . : IA : . . . . . . ~ ^C - I - . , . . ' I A : . . . . . . . I - - - - oA I . . _

I . . - . ; . C~ . + I * . - I . . . . . . : . . . . . 4 . . . . . . . . . . . . C C . . . . . . . . . . . . . . . .

O J F l O t h . . 1-" . . . . . . . . . . . . . . . . . . . . . . . . . ~ , . . . . . . . ~ . . . . . . . . . . . . . . . . . . . . / " s - - . - I ^ . 11 - . - - 11 : ~ - - h * . , 1 . . . . . . : . . . . AI . . . . . I . . . . * k . . . . . I . I I I - . . I

I . . . . . . C^ . . I . . . . . . . 4

18-1.4 Classification of Occupancy. (See 18-1.$.) 18-1.5 Classification of Hazard of Contents. The classification of hazard of contents shall be as defined in Section 4-2. 18-1.6 Minimum Construction Requirements. 1 O • I ~ 1 I ~ ^ - ~ I~ . . . . . . . . . g 1 Q I ~ . + I - . . . . . . 11 , . - . ~g " . ~ ^ - - . ' - - . . I . . - I I k - -

COU'--':-h'-=3L~.~:E .'%~3=--"=.2--2,2..% ~'i:.~:%:~L;.L"--'=\:.'~,-:_L,":__

t he . : - - ~ .~T • I . . . . I - -C - - . . : * J : - - - - I - . . . . . C - - I - , . . : 1~ i . ' - - - - . ~ ^ l I i . ^ . t . ^ I . . . . . . •

..^"_.P:.'Z=.] ;C~: .-2",:.TA .'77X"TP.:,S.'.Z 7C;:Z:T 2:-~_ : - - : k \ . . . . . . . "~'L":L" ;-~.'v."=5 .-'~;~'~1-7;; :';~i4*'~?'i=;~'i-~:A:. gS",e=g ! . . . . f . g . ^ ! . . . . * I . ^ - - . . " . . . . ! . . . . ! . Z . . - I ! - - ^ . ~ . . . . . . * ^A . . . . * ^ - - .

~-. O ~L~ - - l * k . . . . . . . . . . . . . ~ ^ . . I ~ ^11 k - I . ' - - . ' * ^A ~ * I . . - - ~ . . . . C 1 8 1 . . . . . . . . . . . . . . . . . v . . . . . . . . . . . . . . . . . . . . . . . . . . . . z v " - - l . . . , : l J : . . . . . . . . . . . ~.~ . . . . . . = * * ^J I - . , , " IP - -~ I ^ 10 1 ~ 0 I . - - ^ ~ 6 ] 11

~ - -L . I ^ 10 I ~ 0 l ' s~ - - . * - - . ~ ^ - - ~ . - - - T . ' - - : ~ . : ^ - - .

iS-i.6.iForpurposesof]-8-1.fi,~the numf~erof stories shall be counted starting with the primary level of exit discharge and ending with the highest occupiable level• For the purposes of this section, the primary level of exit discharge of a building shall be that floor that is level with or above finished grade of the exterior wall line for 50 percent or more of its perimeter. 18-1.6.2 Buildings of one story in height housing ambulatory health care facilities shall be of any construction type in accordance with NFPA 220, Standard on Types of Building Construction. (See 6-2•1.) 18-1.6.$ Buildings of two or more stories in height housing ambulatory health care fadfities shall be of Type I(445), Type I(352), Type II(222), Type II(111), Type III(211), Type IV(2HH), or Type V(111) construction. (See 6-2.1.)

Exception: Buildings constructed of Type 1I(000), Type III(200), or Type V(000), if protected throughou.t by an approved, u~.ervised automatic sprinkler system m accordance with Section

18-1.6.4 Any level below the level of exit discharge shall be separated from the level of exit discharge by at least Type II(111), Type II[(211), or Type V(111) construction. (See 6-2.1.).

Exception: Separation shall not be required for such letels if they are under the control of the ambulatory health care facility and any hazardous spaces are protected in accordance with Section 64. 18-1.6.5 Where new ambulatory health care facilities are located in existing buildings, the authority having jurisdiction shall be permitted to accept construction systems of lesser fire resistance than required by 18-6.1.6.2 through 18-6.1.6.4 if it can be demonstrated to the anthority's satisfaction that prompt evacuation of the facility can be achieved in case of fire or that the exposing

1 7 7

N F P A 101 - - F9 9 R O C

occupandes and materials of construction present no threat of fire ~aecnletration from such occupancy to the ambulatory health care

ity or to the collapse of the structure. 18-1.6.~,g All interior walls and partitions in buildings of Type I or Type II construction shall be of noncombustible or limited-combustible materials.

^ -

I°!.n~.5 Fer cc.~'_-u~-cn rcqu ' rcmcn= of c=clc:urc; ~.f-'crt/:cr2 . . . . : __ . ~ ^ . . . . . . 4L'I . . . . . . 1O 91

iE~?6%%%~iS?:/.g;~°mo;; ~ one level belo. the level of exit discharge shall have all such lower levels separated from the level of exit discharge by at least Type lI(111 ) cons t ruc t ion .

. . . . N . . . . I . ^111 . . - - . k . . . . . : . . . . . . . . k ^ - ^~ ' . . . . . . . : - - . - - - - ~ l . ~a #~

. . . . . . . . . I - . ~ . K I ^ ^ . k . . r ~ ^ * 1 ^~ . k . . . . . . . . . . g " . . . . . L . l g )a ' t g . O g=*

w t ~ . n G . . . . . . . . . . . ~ . . . . . . . 1 " . . . . . / 1 O g 1 P . . . . | ~ . . . . : . . . . . ~ .

7, ~'; V~"..Z,-:'~2",:\~Z . . . . . . . . . . . ;7, ~ ' ; ' ; ; N~k~?.,~'~2 - , ~ _ , . . . . . . ~ ; . . . . . . . . . . . . . . . . . . . . . . . . . . " 7 Z " . I 2 ~ . ' Y _ : : 7 , E . ~ Z I ; ' Z T ' 3 7 Z : . ~ 22~:; '3~.2L':~;.~22"'E~'~Z-'~ . + . : . . . . ; ' T ' k . . . . . . : ' . : . . . . C ~^ . ; : ~ - - . • 0 ¢') . 11 . . . . . . k 10 ~ . t . - I I ~ ^~

1N E.I.I.2 The: :ecf i :n c :=bl i :hc : I'~: =.=fc~" rcqu'remen=~, "n

10 ~ 1 0 ID . . . . . M

1961 g S ^ - : ^ ' n ^ ~ _ : . : ^ _ (e^. ,o !.~.) ,7, , '~ ' , , ~;'C.72~ZT..~2"~27-C-_TZ2..~Z. ,~ . . . . . . 10 ~ I [ I t ) . . . . . . ..1 \

"1 ~. ~:iZ~'?~7;?~;~=-7;f"?f g;i .g. ~T ;:~.';:~3:. ~f : - = - ' : , :~-_': ~ : cour. . . . . . . . . ~, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . with "..,hc ~g.!.c:t cccup ' :~£ love(. F~r ~.c ~u.'p=,:c- c~:..h': :..-odor:,

~ Z ~ 2 . 2 S L . " ^'-'" Z ' ^ ' ~ L % ~ : 7 222"~2."~P . . . . . . . . . . . . . . . . . . . . . . . . . . . .

a c c o r d a . ~ . . . . : . , . , , r ~ o a ,,on e.^--A~.A ^-- "1" . . . . . . r ~ :,A:__

3 r r .

. . . . . + : ^ - - . D . . : I J : . . . . . . . # - - . ~ . ^ A I ^£T . - - - - I I / g ' l / ~ t ~ ' t ? . - - ^ T l l / g l ~ t P C t

~ 6.1.6.4 ~ ' " ~ . . . . ~ ~ . . , . . . . . t.^ , ^ . = , ^~ _~:. ~:._,. . . . . ~^ . ~_ . . . . . ~ 1 I - ^ - - ~ k - - I . . . . I ~d? - - . . : ~ ~ : . - - k - -~^ k . . - - ~ 1 - -~ . * m . - - ^ 11111 1 \

T . - - - - l l l l q t 15 - - - - m . - - - - XT /1115 . . . . ~ - - . . . # : ^ - - / ~ =,= 0 1 • .

k IkJklrA,la[

in ex2=,'A~- b'a2~ir;,-=, "&c w,.:~c.r:r" ~a-A~- :--N-~-~c'.:.on r.N̂ --*-! ~c

#1- , . . . . . . . : . J k . . 10 ~ 1 d~ O . ]1~ . . . . . ~ . 1 O ~ 1 d~ A : . ( " : . * . - - - k .

. . . . . . . . . : . . . . A ___ . ^ . . ! _1_ -~Y .... . . . . . . : . . . . . . . . * - - ~ * k - - . # --2-'~.-^

. . . . . - - . : ^ - - ~" . . . . . . . K . . . . . . . . . . * ^ ~ K . ^ - - I - . . . I - ~ ^ - - . K^ . I * L . . . . .

18-2 Means of Egress Requirements. 18-2.1 General. Every aisle, passageway, corridor, exit discharge, exit locat ion , and access shall be m accordance with Chapter 5.

Exception: As modified by 18-2.2 through 18-2.11. 18-2.2 Means of Egress Components. 18-2.2.1 Components of means of egress shall be limited to the types described in $6-2.2.

18-2.2.2 Special locking arrangements complying with 5-2.1.6 shall be permit ted on exterior doors. 18-2.2.3 Any door in an exit passageway, horizontal exit, smoke barrier, stairway enclosure, or hazardous area enclosure shall be permitted to be held open only by an automatic release device that complies with 5-2.1.8. The required manual fire alarm system and the systems required by 5-2.1.8, Exception(c), shall be arranged to initiate the dosing action of all such doors by zone or throughout the entire facility. 18-2.2.4 Where doors in a stair enclosure are held open by an automatic device as permitted in 18-6.2.2.$, initiation of a door closing action on any level shall cause all doors at all levels in the stair enclosure to close. 18-2.3 Capacity of Means of Egress. 18-2.3.1 The capacity of any required means of egress shall be determined in accordance with theprovisions of 36-2.3 and shall be based on its width as defined in Section 5-$. 18-2.3.2 The minimum width of any corridor or passageway required for exit access shall be 44 in. (112 cm) in clear width. 18-2.$.$ Doors in the means of egress from diagnostic or treatment areas, such as X-ray, surgical, or physical therapy, shall provide a minimum clear width of 32 in. (81 cm). 18-2.4 Number of Exits. 18-2.4.1 At least two exits of the types described in $6-2.2 that are remotely located from each other shall be provided for each floor or fire section of the building. 18-2.4.2 Any room and any suite of rooms of more than 2500 ft2 (232 m2) shall have at least two exit access doors remotely located from each other. 18-2.4.3 At least two exits of the types described in 36-2.2 shall be accessible f rom each smoke compartment. Egress shall be permitted through adjacent compartments, but shall not require return through the compartment of fire origin. 18-2.5 Arrangement of Means of Egress. (See $6-2.5.) 18-2.6 Travel Distance to Exits. 18-2.6.1 Travel distance shall be measured in accordance with Section 5-6. 18-2.6.2 Travel Distance.

(a) The travel distance between any room door required as an exit access and an exit shall not exceed 100 ft (30 m); and

(b) The travel distance between any point in a room and an exit shall not exceed 150 ft (45 m).

Exception: The maximum travel distance permitted in (a) or (b) above shall be increased by 50 ft (15 m) in buildings protected throughout by an approved, automatic sprinkler system. 18-2.7 Discharge from Exits. (See $6-2.7.) 18-2.8 Illumination of Means of Egress. Means of egress shall be illuminated in accordance with Section 5-8. 18-2.9 Emergency Lighting and Essential Electrical Systems. 18-2.9.1 Emergency lighting shall be provided in accordance with Section 5-9. 18-2.9.2 Where general anesthesia or life-support equipment is used, each ambulatory health care facility shall be provided with an essential electrical system in accordance with NFPA 99, Standard for Health Care Fadlities.

Exception No. 1: Where battery-operated equipment is provided and acceptable to the authority havingjurisdictmn.

Exception No. 2: This requirement shall not apply to a facility that uses life-support equipment for emergency purposes only. 18-2.10 Marking of Means of Egress. Means of egress shall have signs in accordance with Section 5-10. 18-2.11 Special Means of Egress Features. (Reserved.) 18-$ Protection. 18-$.1 Protection of Vertical Openings. (See $6-$.1.) 18-5.2 Protection from Hazards. (See 56-$.2.) 18-5.2.1 Laboratories employing quantities of flammable, combustible, or hazardous materials that are considered as severe hazard shall be protected in accordance with NFPA 99, Standard for Health Care Facilities. 18-5.2.2 Anesthetizing locations shall be protected in accordance with NFPA 99, Standard for Health Care Fadlifies. 18-$.$ Interior Finish. (See $6-$.$.) 18-$.4 Detection, Alarm, and Communication Systems. 18-5.4.1 General. Ambulatory health care facilities shall he provided with fire alarm systems in accordance with Section 7-6, except as modified by 18-$.4.2 through 18-$.4.5. 18-5.4.2 Initiation. Initiation of the required fire alarm systems shall be by manual means in accordance with 7-6.2 and by means of any detection devices or detection systems required. 18-5.4.5 Occupant Notification. Occupant notification shall be accomplished automatically, without delay, upon operation of any

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fire alarm activating device by means of an internal audible alarm in accordance with 7-6.3.

18-3.4.4 Emergency Forces Notification. F'we department notification shall be accomplished in accordance with 7-6.4.

ExcelStion: Smoke detection devices or smoke detection systems equipped with reconfirmation features shall not be required to automatically notify the fire deparunent unless the alarm condition is reconfirmed after a maximum 120-sec time period. 18-3.4.5 Emergency Control. Operation of any activating device in the required fire alarm system shall be arranged to accomplish automatically, without delay, any control functions required to be performed by that device. (See 7-6.5.) 18-3.5 Extinguishment Requirements. (See 36-3.5.) 18-3.5.1 Isolated hazardous areas shaft be permitted to be protected in accordance with 7-7.1.2. Where more than two sprinklers are installed in a single area, water flow detection shall be provided to sound the building fire alarm or notify by a signal any constantly at tended location, such as PBX, security, or emergency room, whereby necessary corrective action shall be directed. 18-3.5.2 Portable fire extinguishers shall be provided in ambulatory health care facilities in accordance with 7-7.4.1. 18-3.6 Corridors. (See 36-3.6.) 18-3.6.1 Openings. Miscellaneous openings such as mail slots, pharmacy pass-through windows, laboratory pass-through windows, and cashier pass-through windows shall be permitted to be installed in vision panels or doors without special protection,

~ rovided the aggregate area of openings per room does not exceed 0 in2. (135 cm ~) and the openings are installed at or below half

the distance from the floor to the room ceiling. Exception: For rooms protected throughout by an approved,

superased automatic sprinkler system in accordance with Section 7-7, the aggregate area of openings per room shall not exceed 80 in 2. (520 cm~). 18-3.7 Subdivision of Building Space. 18-3.7.1 Ambulatory health care facilities shall be separated from other tenants and occupancies by walls having at least a 1 -hr fire resistance rating. Such walls shall extend from the floor slab below to the floor or roof slab above. Doors shall be constructed of at least 13/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be equipped with positive latches. These doors shall be self-closing and shall be kept in the closed position except when in use. Any vision panels sha l lbe of fixed fire window assemblies in accordance with 6-2.3.2.2. 18-3.7.2 The ambulatory health care facility shall be divided into at least two smoke compartments on patient t reatment floors.

Exception: Facilities of less than 5000 ft 2 (465 m ~) and protected by an approved, automatic smoke detection system.

Exception: (See 101-454) 18-3.7.3 Any required smoke barrier shall be constructed in accordance with Section 6-3 and shall have a fire resistance rating of at least I hr.

Exception: Dampers shall not be required in duct penetrations of smoke barriers in fully ducted heating, ventilating, and air conditioning systems for buildings protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 7-7. 18-3.7.4 Vision panels in the smoke barrier shall be of fixed fire window assemblies in accordance with 6-2.5.2.2.

2 2 18-3.7.5 At least 15 n e t f t (1.4 net m ) per ambulatory health care facility occupant shall be provided within the aggregate area of corridors, patient rooms, t reatment rooms, lounges, and other low hazard areas on each side of the smoke compartment for the total number of occupants in adjoining compartments. Smoke barriers shall be provided to limit the size of each smoke compartment to an area not exceeding 22,500 ft ~ (2100 m~), and to limit the travel distance from any point to reach a door in the required smoke barrier to 200 ft (60 m).

Exception: The area of an atrium separated in accordance with 6-2.4.6 shall not be limited in size. 18-3.7.6" Doors in smoke barriers shall be at least 13/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be self-closing. A vision panel shall be required. 18-3.7.7 Doors in smoke barriers shall normally be kept closed, or, if held open, they shall be equipped with automatic devices that will release the doors upon activation of:

(a) The fire alarm system, and either (b) A local smoke detector, or (c) A complete automatic fire extinguishing system or complete

automatic fire detection system. 18-4 Special Provisions.

(See Section 36-4. For operating features requirements see Section 18-7.) 18-5 Building Services. 18-5.1 Utilities. Utilities shall comply with the provisions of Section 7-1. 18-5.2 Heating, Ventilating, and Air Conditioning. 18-5.2.1 Heating, ventilating, and air conditioning shall comply with the provisions of Section 7-2 and shall be in accordance with the manufacturer's specifications.

Exception: As modified in 18-6.5.2.2. 18-5.2.2 Any heating device other than a central heating plant shall be designed and installed so that combustible material will not be ignited by it or its appurtenances. If fuel-fired, such heat ing devices shaft be chimney or vent connected, shall take air for combustion directly from the outside, and shall be designed and installed to provide for complete separation of the combustion system from the aunosphere of the occupied area. Any heating device shall have safety features to immediately stop the flow o f fuel and shut down the equipment in case of either excessive temperature or ignition failure.

Exception: Approved, suspended uni t heaters shall be permitted in locations other than means of egress and patient treatment areas, provided such beaters axe located high enough to be out of the reach of persons using the area, and provided they are equipped with the safety features required above. 18-5.3 Elevators, Escalators, and Conveyors. Elevators, escalators, and conveyors shall comply with the provisions of Section 7-4. 18-5.4 Rubbish Chutes, Incinerators, and Laundry Chutes. Rubbish chutes, incinerators, and laundry chutes shaft comply with the provisions of Section 7-5.

SECTION 18-6 Reserved SECTION 18-7" OPERATING FEATURES

18-7.1 Attendants, Evacuation and Relocation Plan, Fire Drills. 18-7.1.1 The administration of every ~=:p".=1, .-.:==-='=g ~.c.m=, ==~

ambulatory health care facility shall have, in effect and available to all supervisory personnel, written copies of a plan for the protection of all persons in the event of fire and for their evacuation to areas of refuge and for evacuation from the building when necessary. All employees shall be periodically instructed and kept informed with respect to their duties under the plan. A copy of the plan shall be readily available at all times in the telephone .~.~erator's position or at the security center.

e provisions of 18-7.1.2 to 18-7.2.3 inclusive shall apply. 18-7.1.2* Fire exit drills in ambulatory health care occupancies shaft include the transmission of a fire alarm signal and simulation of emergency fire conditions. Drills shall be conducted quarterly on each shift to familiarize facility personnel (nurses, interns, maintenance engineers, and administrative staff) with signals and emergency action required under varied conditions. When drills are conducted between 9:00 p.m. (2100 hours) and 6:00 a.m. (0600 hours), a coded announcement shall be permitted to be used instead of audible alarms. Exception: The movement of infirm or bedridden patients to safe

areas or to the exterior of the building shall not be required. 18-7.1.3 Employees of ambulatory health care facilities shall be instructed in life safety procedures and devices. 18-7.2 Procedure in Case of Fire.. 18-7.2.1" For ambulatory health care occupancies, the proper protection of patients shall require the prompt and effective response of ambulatory health care personnel. The basic response required of staff shall include the removal of all occupants directly involved with the fire emergency, transmission of an appropriate fire alarm signal to warn other building occupants and summon staff, confinement of the effects of the fire by closing doors to isolate the fire area, and the execution of those evacuation duties as detailed in the facility's fire safety plan. (See Appendix A for a more detailed suggested emergency plan.) 18-7.2.2 A written facility fire safety plan shall provide for

(a) Use of alarms, (b) Transmission of alarm to fire department, (c) Response to alarms, (d) Isolation of fire, (e) Evacuation of immediate area, (f~ Evacuation of smoke comnartmenc (g) Preparation of building for evacuation, and (h) Extinguishment of fire.

18-7.2.3 All £-aegtl W personnel shall be instructed in the use of and response to fire alarms, and, in addition, they shall be instructed in the use of the code phrase to ensure transmission of an alarm under the following conditions:

(a) When the individual who discovers a fire must immediately go to the aid of an endangered person.

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(b) During a malfunction of the building fire alarm system. Personnel hearing the code announced shall first activate the building fire alarm using the nearest mm':::~ a!arm :m~== fire ~a rm box and then shall execute immediately their duties as outlined in the fire safety plan. 18-7.3 Maintenance of Exits. Proper maintenance shall be provided to ensure the dependability of the method of evacuauon selected . . . . . . . . . . . . . . . . . . . .

~ ' ~ . T ~ o k i n g . Smoking regulations shall be adopted and shall include the following minimal provisions:

(a) Smoking shall be prohibited in any room, ward, or compartment where flammable liquids, combustible gases, or oxygen is used or stored and in any other hazardous location. Such areas shall be posted with "NO SMOKING" signs or the international symbol for no smoking.

Exception to (a): In ambulatory health care facilities where smoking is prohibited and signs are prominently placed at all major entrances, secondary signs with no smoking language shall not be required.

(b) Smoking by patients classified as not responsible shall be prohibited.

Exception to (b): Where the patient is under direct supervision. (c) Ashtrays of noncombustible material and safe design shall be

provided in all areas where smoking is permitted. (d) Metal containers with self<losing cover devices into which

ashtrays can be emptied shall be readily available to all areas where smoking is permitted. 18-7.5 Furnishings, Bedding, and Decorations. 18-7.5.1" Drapen'es, curtains, including cubicle curtains, and other loosely hanging fabrics and films serving as furnishings or decorations in ambulato .ry.health care occupancies shall be in accordance with the pro~s~ons of 6-6.1. (See 18-$.5.3.)

Exception: Curtains at showers. 18-7.5.2 Newly introduced upholstered furniture within ambulatory health care occupancies shall meet the criteria specified when tested in accordance with the methods cited in 6.6.2(b) and 6-6.$. 18-7•5.$ Newly introduced mattresses within ambulatory health care occupancies shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(c) and 6-6.4. 18-7.5.4 Combustible decorations shall beproh ib i t ed in any ambulatory health care occupancy unless flame~retardant~

Exception: Combustible decorations of such limited quantities that a hazard of fire development or spread is not present, such as Photographs and paintings.

8-7.5.5 Soiled l inen or trash collection receptacles shall not exceed 32 gal (121 L) in capacity. The average density of container capacity in a room or space shall not exceed 0.5 gal per ft ~ (20.4 L per m~). There shall be not more than $~ gal (1~1 L) capacity ., within any 64 ft z (5.9 m ~) area- Mobile soiled linen or trash collection receptacles with capacities greater than 32 gal (121 L) shall be located in a room protected as a hazardous area when not attended.

Exception: Container size and density shall not be limited in hazardous areas. 18-7.6* Engineered Smoke Control Systems. New engineered smoke control .systems shall be tested in accordance with established engineering principles and shall meet the performance requirements of such testing prior to acceptance. Following acceptance, all engineered smoke control systems shall be tested periodically in accordance with recognized engineering principles. Test documentat ion shall be maintained on the premises at all times. 18-7.7 Portable Space Heating Devices. Portable space heating devices shall be prohibited in all health care and ambulatory health care facilities.

Exception: Portable space heating devices shall be permitted to be used in nonsleeping staff and employee areas where the heating elements of such devices are limited to not more than 212°F (100oc). 18-7.8 Construction, Repair, and Improvement Operations. 18-7.8.1 Construction, repair, and improvement operations shall comply with 1-$.11. 18-7.8.2 The means of egress in any area undergoing construction, repair, or improvements shall be inspected daily for meeting the requirements of 5-1.9.1 and shall also meet the requirements of NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.

EXISTING AMBULATORY HEALTH CARE FACILITIES

SECTION 19-1 GENERAL REQUIREMENTS 19-1.1 Application. 19-1.1.1 General. 10-1.1.1.1 The requirements of this chapter apply to existing buildings or portions thereof currently occupied as an ambulatory health care occupancy 19-1.1.4) 10-1.1.1.2 Ambulatory health rare facilities shall comply with the provisions of Chapter 36 and this ~ whichever is more stringent. 10-1.1.1.3 This ~ establishes life safety requirements, in addition to those required in Chapter 36, for the design of all ambulatory health care facilities ~ 10-1.$. 10-1 •1.1.4 Buildings or sections of buildings that primarily house patients who, in the opinion of the governing body of the facility and the governmental agency having jurisdiction, are capable of judgment and appropriate physical action for serf-preservation under emergency conditions shall be permitted to comply with chapters of the Code other than Chapter 19. 19-1.1•1.5" The requirements of this chapter are based on the assumption that staff is available in all patient occupied areas to perform certain fire safety functions as required in other paragraphs of this chapter. 19-1.1.2" Goa~ ~ d Objective. The ~oals and 9~ectives of Sections 1-5 and 1-6 shall be met with due consideration for functional requirements. This is accomplished by limiting the development and spread of a fire emergency to the room of fire origin and reducing the need for occupant evacuation, except from the room of fire origin• 10-1.1.3 Total Concept. All ambulatory health care facilities shall be designed, constructed, maintained, and operated to minimize the possibility of a fire emergency requiring the evacuation of occupants. Because the safety of ambulatory health care occupants cannot be ensured adequately by dependence on evacuation of the building, their protection from fire shall be provided by appropriate arrangement of facilities, adequate staffing, and development of operating and maintenance procedures composed of the following:

(a) Desigr~., construction, and compartmentation; and (b) Provision for detection, alarm, and extinguishment; and (c) Fire prevention and the planning, training, and drilling in

programs for the isolation of fire, transfer of occupants to areas of refuge, or evacuation of the building. 10-1.1.4 Additions, Conversions, Modernization, Renovation, and Construction Operations. (Se= al:v I ~.~ :=:~ ! ~.7.) 10-1.1.4.1 Additions. Additions shall be separated from any existing structure not conforming to the provisions within Chapter 19 by a fire barrier having at least a 2-hr fire resistance rating and constructed of materials as required for the addition. (See 1-11.9 and 1-11.6) 10-1.1.4.2 Communicating openings in dividing fire barriers required by 10-1.1.4.1 shall occur only in corridors and shall be protected by approved self-closing fire doors. (See also Section 6-2.) 10-1.1.4.$ Doors in barriers required by 19-1.1.4.1 shall normally be kept closed•

Exception: Doors shall be permitted to be held open if they meet the requirements of 19-2.2.2.6. 19-1.1.4.4 Chan~es of Occunancv. Chan~es of occuoancv shall comply with 1-I].12.

Exception: A chan~e from a hosnital or nursln~ home to an ambulatory health care occunancv shall not be considered a ghaagr_m_x.~ma~ 10-1.1.4.5" Renovations, Alterations, and Modernizations. (See 1- LL_TA 19-1.1.4.6 Construction Reoair and Imorovement Operations. See 1-11.11 for life safety provisions during construction. 10-1.2 Mixed Occupancies. (See also 4-1.12.) 19-1•2•1" Sections of ambulatory health care facilities shall be permitted to be classified as other occupancies provided they meet all of the following conditions:

(a) They are not intended to serve ambulatory health care occupants for purposes of treatment, or customary access by patients incapable of self-preservation;

(b) The~, are separated from areas of ambulatory health care occupancies by construction having a fire resistance rating of at least-~ 1 hr.

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19.1.2.3 All means of egress from ambulatory health care occupancies that traverse non-ambulatory health care spaces shall conform to requirements of this Code for ambulatory health care occupancies.

Exception: It shall be permissible to exit through a horizontal exit into other contiguous occupancies that do not conform with ambulatory health care egress provisions but that do comply with requirements set forth in the appropriate occupancy chapter of this Code, provided the occupancy does not contain high hazard contents. 19.1.2.4 Egress provisions for areas of ambulatory health care facilit iesthat correspond to other occupancies shall meet the corresponding requirements of this Code for such occupancies. 19.1.2.5 Any area with a hazard of contents classified higher than that of the ambulatory health care occupancy and located in the same building shall be protected as required in 19-3.2. 19-1.2.6 Non-ambulatory health care related occupancies classified as containing high hazard contents shall not be permitted in buildings housing ambulatory health care occupancies. 19-1.3" Special Definitions. Ambulatory Health Care Facility. A building or part ~ used to provide services or treatment to four or more patients at the same time that meets the criteria of(a) or (b) below.

Ca) Those facilities that provide, on an outpatient basis, treatment for patients that would render the patients incapable of taking action for self-preservation under emergency conditions without assistance from others.

(b) Those facilities that provide, on an outpatient basis, anesthesia that would render the oatients incaoable of taking action for self-oreservation under emergency condition without assistance of other. 19-1.4 Classification of Occupancy. (See 19-1.$.) 19-1.5 Classification of Hazard of Contents. The classification of hazard of contents shall be as defined in Section 4-2. 19-1.6 Minimum Construction Requirements. 19-1.6.1 For purposes of 19-1.6, the number of stories shall be counted starting with the primary level of exit discharge and ending with the highest occupiable level. For the purposes of this section, the primary level of exit discharge of a building shall be that floor that is level with or above finished grade of the exterior wall line for 50 percent or more of its perimeter. 19-1,6.2 Buildings of one story in height housing ambulatory health care facilities shall be of any construction type in accordance with NFPA 220, Standard on Types of Building Construction. (See 6-2.1.) 19-1.6.3 Buildings of two or more stories in height housing ambulatory health care facilities shall be of Type I(443), Type I(332), Type II(222), Type I I ( l l l ) , Type III(211), Type W(2HH), or Type V ( l l l ) construction. (See 6-2.1.)

Exception: Buildings constructed of Type II(000), Type III(200), or Type V(000), if protected throughout by an approved, ~u~.ervised automatic sprinkler system in accordance with Section

19.1.6.4 Any level below the level of exit discharge shall be separated from the level of exit discharge by at least Type II(111), Type III(211), or Type V(111) construction. (See 6-2.1.)

Exception: Separation shall not be required for such levels if they are under the control of the ambulatory health care facility and any hazardous spaces are protected in accordance with Section 6-4. 19.1.6.5 In existing buildings, the authority having jurisdiction shall be permitted to accept construction systems of lesser fire resistance than required by 19.6.1.6.2 through 19-6.1.6.4 if it can be demonstrated to the authority's satisfaction that prompt evacuation of the facility can be achieved in case of fire or that the exposing occupancies and materials of construction present no threat of fire penetration from such occupancy to the ambulatory health care facility or to the collapse of the structure. 19-1.6.2~g All interior walls and partitions in buildings of Type I or Type II construction shall be of noncombustible or limited-combustible materials. 19-1.6.6 All buildings with more than one level below the level of exit discharge shall have all such lower levels separated from the level of exit discharge by at least Type II(111) construction. 19-1.7 Occupant Load. (See 36-1.7.) * 19-2 Means of Egress Requirements. 19-2.1 General. Every aisle, passageway, corridor, exit discharge, exit location, and access shall be in accordance with Chapter 5.

Exception: As modified by 19-2.2 through 19-2.11. 19-2.2 Means of Egress Components.

19-2.2.1 Components of means of egress shall be limited to the types described in 36-2.2. 19-2.2.2 Special locking arrangements complying with 5-2.1.6 shall be permit ted on exterior doors. 19-2.2.3 Any door in an exit passageway, horizontal exit, smoke barrier, stmrway enclosure, or hazardous area enclosure shall be permitted to be held open only by an automatic release device that complies with 5-2.1.8. The required manual lure alarm system and the systems required by 52.1.8, Exception(c), shall be arranged to initiate the dosing action of all such doors by zone or throughout the entire facility. 19-2.2.4 Where doors in a stair enclosure are held open by an automatic device as permitted in 19-6.2.2.3, initiation of a door closing action on any level shall cause all doors at all levels in the stair endosure to close. 19-2.$ Capacity of Means of Egress. 19-2.$.1 The capacity of any required means of egress shall be determined in accordance with the provisions of $6-2.$ and shall be based on its width as defined in Section 5-3. 19-2.$.2 The minimum width of any corridor or passageway required for exit access shall be 44 in. (112 cm) in dear width. 19.2.$.3 Doors in the means of egress from diagnostic or treatment areas, such as X-ray, surgical, orphysical therapy, shall provide a minimum clear width of 32 in. (81 cm). 19-2.4 Number of Exits.

Exception: existing $4-in. (86-cm) doors. 19-2.4.1 At least two exits of the types described in $6-2.2 that are remotely located from each other shall be provided for each floor or fire section of the building. 19.2.4.2 Any room and any suite of rooms of more than 2500 ft ~ (232 m 2) shall have at least two exit access doors remotely located from each other 19-2.4.3 At least two exits of the types described in 36-2.2 shall be accessible from each smoke compartment. Egress shall be permitted through adjacent compartments, but shall not require return through the compartment of fire origin. 19-2.5 Arrangement of Means of Egress. (See $6-2.5.) 19.2.6 Travel Distance to Exits. 19.2.6.1 Travel distance shall be measured in accordance with Section 5-6. 19-2.6,2 Travel Distance.


(b) The travel distance between any point in a room and an exit shall not exceed 150 ft (45 m).

Exception: The maximum travel distance permitted in (a) or (b) above shall be increased by 50 ft (15 m) in buildings protected throughout by an approved, automatic sprinkler system. 19-2.7 Discharge from Exits. (See 36-2.7.) 19-2.8 Illumination of Means of Egress. Means of egress shall be illuminated in accordance with Section 5-8. 19-2.9 Emergency Lighting and Essential Electrical Systems. 19-2.9.1 Emergency lighting shall be provided in accordance with Section 5-9. 19-2.9.2 Where general anesthesia or life-support equipment is used, each ambulatory health care facility shall be provided with an essential electrical system in accordance with NFPA 99, Standard for Health Care Facilities.

Exception No. 1: Where battery-operated equipment is provided and acceptable to the authority having jurisdiction.

Exception No. 2: This requirement shall not apply to a facility that uses life-support equipment for emergency purposes only. 19.2.10 Marking of Means of Egress. Means of egress shall have signs in accordance with Section 5-10. 19.2.11 Special Means of Egress Features. (Reserved.) 19-3 Protection. 19.3.1 Protection of Vertical Openings. (See 36-3.1.) 19-5.2 Protection from Hazards. (See 36-3.2.) 19-3.2.1 Laboratories employing quantities of flammable, combustible, or hazardous materials that are considered as severe hazard shall be protected in accordance with NFPA 99, Standard for Health Care Facilities. 19-3.2.2 Anesthetizing locations shall be protected in accordance with NFPA 99, Standard for Health Care Facilities. 19-3.3 Interior Finish. (See 36-3.3.) 19-3.4 Detection, Alarm, and Communication Systems. 19-3.4.1 General. Ambulatory health care facilities shall be provided with fire alarm systems in accordance with Section 7-6, except as modified by 19-3.4.2 through 19-3.4.5. 19-3.4.2 Initiation. Initiation of the required fire alarm systems shall be by manual means in accordance with 7-6.2 and by means of any detection devices or detection systems required.

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19-3.4.3 Occupant Notification. Occupant notification shall be accomplished automatically, without delay, upon operation of any fire alarm activating device by means of an internal audible alarm in accordance with 7-6.3.

. . . . . . . . . . . . . . . . . l=, . . . . . . . . . . .

19.3.4.4 Emergency Forces Notification. Fire depar tment notification shall be accomplished in accordance with 7-6.4.

Exception: Smoke detection devices or smoke detection systems equipped with reconfirmation features shall no t be required to automatically notify the fire depar tment unless the alarm condition is reconfirmed after a maximum 120-sec time period. 19-3.4.5 Emergency Control. Operation of any activating device in the required fire alarm system shall be arranged to accomplish automatically, without delay, any control functions required to be performed by that device. (See 7-6.5.) 19-3.5 Extinguishment Requirements. (See 36-3.5.) 19-3.5.1 Isolatgd hazardous areas shall be permitted to be protected in accordance with 7-7.1.2. For new installations in exisdng ambulatory, health care facilities, where more than two sprinklers are installed in a single area, water flow detection shall be provided to sound the building fire alarm or notify by a signal any constantly at tended location, such as PBX, security, or emergency room, whereby necessary corrective action shall be directed. 19-3.5.2 Portable fire extinguishers shall be provided in ambulatory health care facilities in accordance with 7-7.4.1. 19-3.6 Corridors. (No requirements) 19-~.7 Subdivision of Building Space. 19-3.7.1 Ambulatory health care facilities shall be separated from other tenants and occupancies by walls having at least a 1 -hr fire resistance rating. Such walls shall extend from the floor slab below to the floor or roof slab above. Doors shall be constructed of at least 13/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be equipped with positive latches. These doors shall be self-closing and shall be kept in the closed position except when in use. Any vision panels shall be of fixed fire window assemblies in accordance with 6-2.3.2.2. 19-3.7.2 The ambulatory health care facility shall be divided into at least two smoke compartments.

Exception: Facilities of less than 5000 fC (465 m ~) and protected by an approved, automatic smoke detection system.

Exception: (See 101-498) 19-3.7.3 Any required smoke barrier shall be constructed in accordance with Section 6-3 and shall have a fire resistance rating of at least 1 hr.

Exception: Dampers shall not be required in duct penetrations of smoke barriers in fully ducted heating, ventilating, and air conditioning systems for buildings protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 7-7. 19-$.7.4 Vision panels in the smoke barrier shall be of fixed fire window assemblies in accordance with 6-2.$.2.2. 19-3.7.5 (reserved) 19.3.7.6" Doors in smoke barriers shall be at least 13/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be self-closing. A vision panel shall be required. 19-3.7.7 Doors in smoke barriers shall normally be kept closed, or, if held open, they shall be equipped with automatic devices that will release the doors upon activation of:


automatic fire detection system. 19-4 Special Provisions. (See Section 36-4. For operating features requirements see Section 19-7.) 19-5 Building Services. 19-5.1 Utilities. Utilities shall comply with the provisions of Section 7-I.

Exception: Existing installations shall be permitted to be continued in service provided the systems do not present a serious hazard to life. 19-5.2 Heating, Ventilating, and Air Conditioning. 19-5.2.1 Heating, ventilating, and air conditioning shall comply with the provisions of Section 7-2 and shall be in accordance with the manufacturer's specifications.

Exception: As modified in 19-6.5.2.2. 19.5.2.2 Any heating device other than a central heating plant shall be designed and installed so that combustible material will not be ignited by it or its appurtenances. If fuel-fired, such heating devices shall be chimney or vent connected, shall take air for combustion directly from the outside, and shall be designed and installed to

provide for complete separation of the combustion system from the atmosphere of the occupied area. Any heating device shall have safety features to immediately stop the flow of fuel and shut down the equipment in case of either excessive temperature or ignition failure.

Exception: Approved, suspended unit heaters shall 'be permitted in locations other than means of egress and patient treatment areas, provided such heaters are located high enough to be out of the reach of persons using the area, and provided they are equipped with the safety features required above. 19-5.$ Elevators, Escalators, and Conveyors. Elevators, escalators, and conveyors shall comply with the provisions of Section 7-4. 19-5.4 Rubbish Chutes, Incinerators, and Laundry Chutes. Rubbish chutes, incinerators, and laundry chutes shall comply with the provisions of Section 7-5.

SECTION 19-6 Reserved SECTION 19-7" OPERATING FEATURF_~

19-7.1 Attendants, Evacuation and Relocation Plan, Hre Drills. 19-7.1.1 The administration of every .hc.:#~.~2, nu.'~'ng h.~..'-~:, : = ~ t4mit~l- ambulatory health care facility shall have, in effect and available to all supervisory personnel, written copies of a plan for the protection of all persons in the event of fire and for their evacuation to areas of refuge and for evacuation from the building when necessary. All employees shall be periodically instructed and kept informed with respect to their duties under the plan. A copy of the plan shall be readily available at all times in the telephone ~{~erator's position or at the security center.

e provistons of 19-7.1.2 to 19-7.2.$ inclusive shall apply. 19-7.i.2" Fire exit drills in ambulatory health care occupancies shall include the transmission of a fire alarm signal and simulation of emergency fire conditions. Drills shall be conducted quarterly on each shift to familiarize facility personnel (nurses, interns, maintenance engineers, and administrative staff) with signals and emergency action required under varied conditions. When drills are conducted between 9:00 p.m. (2100 hours) and 6:00 a.m. (0600 hours), a coded announcement shall be permitted to be used instead of audible alarms.

Exception: The movement of infirm or bedridden patients to safe areas or to the exterior of the building shall not be required. 19-7.1.$ Employees of ambulatory health care facilities shall be instructed in life safety procedures and devices. 19-7.2 Procedure in Case of Fire. 19.7.2.1" For ambulatory health care occupancies, the proper protection of patients shall require the prompt and effective response of ambulatory health care personnel. The basic response required of staff shall include the removal of all occupants directly involved with the fire emergency, transmission of an appropriate fire alarm signal to warn other building occupants and summor~ staff, confinement of the effects of the fire by closing doors to isolate the fire area, and the execution of those evacuation duties as detailed in the facility's fire safety plan. (See Appendix A for a more detailed suggested emergency plan.) 19-7.2.2 A written facility fire safety plan shall provide for

(a) Use of alarms, (b) Transmission of alarm to fire department, (c) Response to alarms, (d) Isolation of fire, (e) Evacuation of immediate area, (f~ Evacuation of smoke comoartment. (g) Preparation of building for evacuation, and (hi Extinguishment of fire.

19-7.2.3 All f-a~4gty personnel shall be instructed in the use of and response to fire alarms, and, in addition, they shall be instructed in the use of the code phrase to ensure transmission of an alarm under the following conditions:


(b) During a malfunction of the building fire alarm system. Personnel hearing the code announced shall first activate the building fire alarm using the nearest :nahum! ~l:=.-n =m~.~n

and then shall execute immediately their duties as outlined in the fire safety plan. 19-7.3 Maintenance of Exits. Proper maintenance shall be provided to ensure the dependability of the method of evacuation selected. F:. . . . . . . . . . . . . . . . . .

: ~ - - ~ a : ~ . ^ .4 . . . . . . . . . . . . . n . . . . r . - ¢ - , ~ i .............. ~, ........ r ~. c2.3c ~f fire cr ;Lk~cr

19-7.4" Smoking.

182


Smoking regulations shall be adopted and shall include the following minimal provisions:

(a) Smoking shall be prohibited in any room, ward, or compartment where flammable liquids, combustible gases, or oxygen is used or stored and in any other hazardous location. Such areas shall be posted with "NO SMOKING" signs or the international symbol for no smoking.

Exception to (a): In ambulatory health care facilities where smoking is prohibited and signs are prominently placed at all major entrances, secondary signs with no smoking language shall not be required.

(b) Smoking by patients classified as not responsible shall be prohibited.

Exception to (b): Where the patient is under direct supervision. (c) Ashtrays of noncombustible material and safe design shall be

provided in all areas where smoking is permitted. (d) Metal containers with serf-closing cover devices into which

ashtrays can be emptied shall be readily available to all areas where smoking is permitted. 19-7.5 Furntshin~, Bedding, and Decorations. 19-7.5.1" Draperies, curtains, including cubicle curtains, and other loosely hanging fabrics and films serving as furnishings or decorations in ambulatory health care occupandes shall be in accordance with the provisions of 6-6.1. (See 19-3.5.$.)

Exception: Curtains at showers. 19-7.5.2 Newly introduced upholstered furniture within ambulatory health care occupancies shall meet the criteria specified when tested in accordance with the methods cited in 6-6.9(b) and 6-6.3. 19-7.5.~ Newly introduced mattresses within ambulatory health care occupancies shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(c) and 6-6.4. 19-7.5.4 Combustible decorations shall be prohibi ted in any ambulatory health care occupancy unless flame-retardant.

Exception: Combustible decorations of such limited quantifies that a hazard of fire development or spread is not present, such as photographs and paintings. 19-7.5.5 Soiled linen or trash collection receptacles shall not exceed 32 gal (121 L) in capacity. The average density of container capacity in a room or space shall not exceed 0.5 gai per ft ~ (20.4 L per m~). There shall be not more than 32 gal (121 L) capacity within any 64 ft2 (5.9 m ~) area. Mobile soiled linen or trash collection receptacles with capacities greater than 32 gal (121 L) shall be located in a room protected as a hazardous area when not attended.

Exception: Container size and density shall not be limited in hazardous areas. 19-7.6" Engineered Smoke Control Systems. New engineered smoke control systems shall be tested in accordance with established engineering principles and shall meet the performance requirements of such testing prior to acceptance. Following acceptance, all engineered smoke control systems shall be tested periodically in accordance with recognized engineering principles. Test documentat ion shall be maintained on the premises at all times. 19-7.7 Portable Space Heating Devices. Portable space heating devices shall be prohibited in all health care and ambulatory health care facilities.

Exception: Portable space heating devices shall be permitted to be used in nonsleeping staff and employee areas where the heating elements of such devices are limited to not more than 212°F (100°C). 19-7.8 Construction, Repair, and Improvement Operations. 19-7.8.1 Construction, repair, and improvement operations shall comply with 1-3.11. 19-7.8.2 The means of egress in any area undergoing construction, repair, or improvements shall be inspected daily for meeting the requirements of 5-1.9.1 and shall also meet the requirements of NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations.

Make the appropriate deletions from Otapters 12 and 13. Maintain appropriate appendix notes

SUBSTANTIATION: Since NFPA 101 is undergoing a major reorganization this cycle, and two chapters were reserved for ambulatory health care occupancies, it is desirable to separate them out at this time for several reasons. First, why wait? If people are going to go through the trauma of a major reorganization, lets split out the ambulatory health care requirements. Second, it eventually needs to get done. Just attempting to correlate the provisions of Section 12-1 with 12-6, I found several problems that need to be resolved. These problems are not due to the movement, but the move has highlighted them. I have tried to integrate them to the best of my knowledge without changing the

requirements of the code but the requirements are not clear. I do not always agree with the outcome, but the codes does say that 12-1 applies to AHC. Lastly, AHC requires a lot of work in the the next Code cycle. Lets not complicate this with a concurrent move. I have tried to show where each requirement came from in the draft of Chapter 18. For Chapter 19 only the resulting chapter is shown. This is intended to be only an editorial change as discussed in Proposal 101-2. COMMITTEE ACTION: Accept in Prindple.

Create new chapters for Ambulatory Healthcare Occupancies as shown in the material that follows.

Delete material on Ambulatory Healthcare Occupancies from Chapters 12 and 13 as shown in the material that follows.

Transfer the appropriate Appendix notes from Chapters 12 and 13 to the new Chapters.

SECTION 12 5 CHAPTER 18 NEW AMBULATORY HEALTH CARE OCCUPANCIF.S

CH~TEP. 12 ~'?! H'Z?'--TH C.A.P~ OCC'JP?~.'CW~.S SECTION 18-1 (gENERAL REQUIREMENTS

18-1.1 Application. 18-1.1.1 General. 18-1.1.1.1 The requirements of this chapter apply to

(a) New buildings or portions thereof used as ambulatory health care occupandes (see Section 1-4.1); and

(b) Adthtions made to, or used as, an ambulatory health care occupancy (see 1-11.6 and 18-1.1.4); and Exception to (h): Additions classified as occupandes other than ambulatory health care that are properly separated from the ambulatory health care occupancy in accordance with 18-1.2.1 and conform to the requirements for the specific occupancy i~

(d) Existing buildings or portions thereof upon change of occupancy to an ambulatory health care occupancy (see 1-11.12).

. . . . . . . . ~ .

l C " l 1 1 1 0 ~ P I ~ . ' . . k ~ - - ~ . . . . + ~ k l : . l . . ~ I . ' . C ^ . ~ . ¢ ^ ~ . . . . . . ." . . . . . + . £ ^ . +11, .~

Z'f'.;?::LT'~T,L:'.~"-:L".:FL"Z22Z:=:~ .'L~.':22..:'~'F.:."L':ZT. ^"7

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18-1.1.1.2 ~ Ambulatory health care facilities shall comply with the provisions of Chapter 36 and this ~ o e e 6 o ~ , whichever is more s~ing..ent., w~ . . . . . -.: . . . . ¢ c=~.: ̂ - ° , ~ o

F2LT.TP2LL~: ELTS~2::L2fXZ.f':,.Ff'L~\~ . . . . . . . . . . . r . . . . . 18-1.1.1.3 ~ T h i s ~ s ~ i o t ~ establishes life safety requirements, in addition to those required in Chapter ~6, for the design of all ambulatory health care facilities "~hat mcct the r ~ u ' r c m z n ~ cf ~ 18-1.3. 18-1.1.1.4 ~ Buildings or sections of buildings that primarily house patients who, in the opinion of the governing body of the fadlity and the governmental agency having jurisdiction, are

[ capable of judgment and appropriate physical action for self-preservation under emergency conditions shall be permitted to comply with chapters of the Code other than Chapter 18. 18-1.1.1.5 ~ It shall be recognized that, in buildings

providing treatment for certain types of patients or having detention rooms or a security section, it might be necessary to lock doors and bar windows to confine and protect building inhabitants. In such instances, the authority having jurisdiction shall make appropriate modifications to those sections of this Code that would otherwise require means of egress to be kept unlocked. 1 0 1 1 1 O U . . * . I A : . . . . . . . . ~ : . . . . C k . . * . l A : , - - - - . I . , ~ k . . . . . o l A ~ - -

k - - - - I . k . . . . - t ' ~ . ' l : . : - . 1 - . A - - - C . - - . A : ~ 1 Q I ~ . . 1 ~ 1 1 1 ~ . . . . . . ' & * ^ A

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: ~ . \ : ' . Z . " . : 7 . ~'~'::':~2.:~:^.T::.2Z':LZ.~;,'~ ~ . - -FL~ . : ' - - 3 ,T_Z~ : : : L "L~Z2^~ : .

i~E17E~ % ~ % ~ r 2 m ~ of t ~ chapter are ~ e d on the assumption that staff is available in all patient occupied areas to perform certain fire safety functions as required in other paragraphs of this chapter.

183


18-1.1.2" Goals and Objective. The goals and objectives of Sections 1-5 and 1-6 shall be met with due consideration for functional requirements. This is accomplished by limiting the development and spread of a fire emergency to the room of fire origin and reducing the need for occupant evacuation, except from the room of fire origin. 18-1.1.~ Total Concept. All ambulatory health care facilities shall be designed, constructed, maintainedl and operated to minimize the possibility of a fire emergency requiring the evacuation of occupants. Because the safety of ambulatory health care occupants cannot be ensured adequately by dependence on evacuation of the building, their protection from fire shall be provided by appropriate arrangement of facilities, adequate staffing, and development of operating and maintenance procedures composed of the following:.

(a) Desi~., construction, and compartmentation; and (b) Provision for detection, alarm, and extinguishment; and (c) Fire prevention and the planning, training, and drilling in

programs for the isolaMon of fire, transfer of occupants to areas of refuge, or evacuation of the building. 18-1.1.4 Additions, Conversions, Modernization, Renovation, and Construction Operations. 18-1.1.4.1 Additions. Additions shall be separated from any existing structure not conforming to the provisions within Chapter 19 by a fire barrier having at least a 2-hr fire resistance rating and constructed of materials as required for the addition. (See 1-11.2 and 1-11.6) 18-1.1.4.2 Communicating openings in dividing fire barriers required by 18-1.1.4.1 shall occur only in corridors and shall be protected by approved self<losing fire doors. (See also Section 6-2.) 18-1.1.4.$ Doors in barriers required by 18-1.1.4.1 shall normally be kept closed. Exception: Doors shall be permitted to be held open i'f they meet the requirements of 18-2.2.2.6. 18-1.1.4.4 Changes of Occupancy. Cha."=gc: ~f c.cc=:~a:=c}'~hall . . . . 1 . . . . . : * l ~ 1 11 I c~ t * . I - . . . . . C . . . . . . t . ~1 .1~ . . . . . . . . . . . . . .

r . . . . *" . . . . . * . C . . . . . . . . . . . * - . . ~ * : ^ ~

E:~ccF'.!o-n .~.~o. 2: E:=ccp~a: A change from a hospital or nursing home to an ambulatory health care occupancy shall not be considered a change in occupancy or occupancy subclassification.

. 18-1.1.4.5 Renovations, Alterations, and Modernizations. (See 1- I 1 1.7.) Where major renovations, alterations, or modernizations are I made in a nonsprinklered facility, the automatic sprinkler requirements of Chapter 18 shall apply to the smoke compartment

i undergoing the renovation, alteration, or modernization. However, in cases where the building is not protected throughout by an approved, automatic sprinkler system, the requirements of 15-1.6 and 15-2.$.2 shall also apply. Exception No. 2 to 18-$.7.$ shall be permitted only where adjacent smoke compartments are protected throughout by an approved, supervised automatic sprinkler system in accordance with 18-$.5.2. Where minor renovations, alterations, modernizations, or repairs are done in a nonsprinklered facility, the requirements of 18-~.5.1 shall no t apply, but, in such cases, the renovations, alterations, modernizations, or repairs shall not reduce life safety below that which existed before, nor below the requirements of Chapter 15 for nonsprinklered buildings. 18-1.1.4.6 Construction Repair and Improvement Operations. (See 1-11.11) 18-1.2 Mixed Occupancies. (See also 4-1.12.) 18-1.2.1" Sections of ambulatory health care facilities shall be permitted to be classified as other occupancies provided they meet all of the following conditions:

(a) They are not intended to serve ~lllbulatorv health care occupants for purposes of t ~ g - , treatment, or customary access by patients incapable of self-preservation;

(b) They are separated from areas of ~ health care occupancies by construction having a fire resistance rating of at least-~ 1 hr. 1 o 1 0 q : k A~K . . I ~ * . . . . . . g ' ~ : l : * : . . . . A : . ~ I . 1 :~ : . . . . A o i l i l y - -

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con£ t l ~ . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . .

18-1.2.3 All means of egress from ~ health care ] occupancies that traverse non-ambulatory health care spaces shall

conform to requirements of this Code for ambulatory health care occupancies. Exception: It shall be permissible to exit through a horizontal exit into other contiguous occupancies that do not conform with ambulatory health care egress provisions but that do comply with requirements set forth in the appropriate occupancy chapter of this Code, provided the occupancy does not contain high hazard contents. TF.c .!.c.r:.zo~'.z2 exit :k22! c~mp! 7 ~:~.'.k tF.c rc~u ' r=mc:= ~f

18-1.2.4 Egress provisions for areas of ambulatorv health care facilities that correspond to other occupancies shall meet the corresponding requirements of this Code for such occupancies. Where the clinical needs of the occupant necessitate the locking of means of egress, staff shall be present for the supervised release of occupants during all times of use.

78-'l:'2.'~'J~ny~ar';a°~'th-a']~a;aT;t'oT'{:';ments classified higher than that of the ambulatory health care occupancy and located in the same building shall be protected as required in 18-3.2. 18-1.2.6 Non- health care related occupancies classified as containing high hazard contents shall not be permitted in buildings housing ambulatory health care occupancies. 18-1.$* Special Definitions.(THE CHANGES TO THE DEFINITION OF AMBULATORY HEALTH Cat.RE ARE PER p 101-419) Ambulatory Health Care Facility. A building or part thereof ~ff-a-

used to provide services or treatment to four or more patients at the same time that meets the criteria of eltNer- (a) or (b) below.

(a) Those facilities that provide, on an outpatient basis, treatment for patients that would render the Datienl~ incapable of taking action for self-preservation under emergency conditions without assistance from others.

(b) Those facilities that provide, on an outpatient basis, . . . . . . . . . . . . . . :~: . . . . . . . ' anesthesia that would render the patients incanable of takin~ action for self-nreservation under emergency condition without assistance of-other.

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1 8 - ) . 4 C l a s s i f i c a t i o n o f O c c u p a n c y . (See 18-1.3.) 18-1.5 Classification of Hazard of Contents. The classification of hazard of contents shall be as defined in Section 4-2.

i 18-1.6 Minimum Construction Requirements.

counted " ~ : . . . . . ' . 1 . . 1 ~ ^ - - . : . . . . I . . . . I ^~ " ~ . . : * . . 1 : . ~1~ . . . . . .-1 ^ - -~1 : - -~

with .,._ ~.~_-_? ~ : ~ ; . ~ ; ~ r ' 7 : ~ / ~ ; 2 _ ~ ' . ~ . ; ~2 . : ~ . ~ ' . ' - 3 "~ . " . 37 . . ' ~T ~ +I~ ~ . : . . . . I ~ . , ~1 ^C ^ . . : ~ . - i : ~ . k . . . . C ^ k . . : lA :~ - - . k - - l l k ^ * k - - ! . . . . . . •

. . . . . . . . . . . . . . . . . . . . . . r . . . . . . . . . . . . . . ~. . . . . v~ h" . . . . . . . . . . . . . . . ~, l g ) 1 j ~ . c ) U~ I . I . . . . . . . . . . . . . . . ~ ' - . . ~ , . . - 11 I . - I : . - - ; *~ i . ~ * / h - - ~ . . . .

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184

N F P A 101 - - F 9 9 R O C

18-1.6.1 For purposes of 18-1.6, the number of stories shall be counted starting with the primary level of exit discharge and ending with the highest occupiable level. For the purposes of this section, the primary level of exit discharge of a building shall be that floor that is level with or above finished grade of the exterior wall line for 50 percent or more of its perimeter. 18-1.6.2 Buildings of one story in height housing ambulatory health care facilities shall be of any construction type in accordance with

[ NFPA 220, Standard on Types of BuildingConstrnction. (See 6-2.1 .) 18-1.6.$ Buildings of two or more stories in height housing

t ambulatory health care facilities shall be of Type I(445), Type { I(332), Type II(222), Type I I ( l l l ) , Type III(211), Type IV(2HH), | or Type V ( l l l ) construction. (See 6-2.1.) | Exception: Buildings constructed of Type II(000), Type III(200), | or Type V(000), if protected throughout by an approved,

u~.ervised automatic sprinkler system in accordance with Section

18-1.6.4 Any level below the level of exit discharge shall be separated from the level of exit discharge by at least Type I I ( l l l ) , Type III(211), or Type V(111) construction. (See 6-2.1.) Exception: Separation shall not be required for such levels if they are under the control of the ambulatory health care facility and any hazardous spaces are protected in accordance with Section 6-4. 18,1.6.5 Where new ambulatory health care facilities are located in existing buildings, the authority having jurisdiction shall be permitted to accept construction systems of lesser fire resistance than required by 18-6.1.6.2 through 18-6.1.6.4 if it can be demonstrated to the authority's satisfaction that prompt evacuation of the facility can be achieved in case of fire or that the exposing occupancies and materials of construction present no threat of fire

enetration from such occupancy to the ambulatory health care cility or to the collapse of the s t r u c t u r e .

18-1.6.~-g All interior wails and partitions in buildings of Type I or Type II construction shall be of noncombustible or limited-combustible materials. 18-1.6.6 All buildings with more than one level below the level of exit discharge shall have all such lower levels separated from the level of exit discharge by at least Type II(111) construction. 18-1.7 Occupant Load. (See $6-1.7.) 18-2 Means of Egress Requirements.

i 18-2.1 General. Every aisle, passageway, corridor, exit discharge, exit location, and access shall be in accordance with Chapter 5. Exception: As modified by 18-2.2 through 18-2.11. 18-2.2 Means of Egress Components. 18-2.2.1 Components of means of egress shall be limited to the types described in $6-2.2. 18-2.2.2 Special locking arrangements complying with 5-2.1.6 shall be permitted on exterior doors. 18-2.2.$ Any door in an exit passageway, horizontal exit, smoke barrier, stairway enclosure, or hazardous area enclosure shall be permitted to be held open only by an automatic release device that complies with 5-2.1.8. The required manual fire alarm system and the systems required by 5-2.1.8, Exception(c), shall be arranged to initiate the closing action of all such doors by zone or throughout the entire facility. 18-2.2.4 Where doors in a stair enclosure are held open by an automatic device as permitted in 18-6.2.2.3, initiation of a door closing action on any level shall cause all doors at all levels in the stair enclosure to close. 18-2.$ Capacity of Means of Egress. 18-2.3.1 The capacity of any required means of egress shall be determined in accordance with the provisions of 36-2.$ and shall be based on its width as defined in Section 5-3, 18-2.$.2 The minimum width of any corridor or passageway required for exit access shall be 44 in. (112 cm) in clear width. 18-2.3.3 Doors in the means of egress from diagnostic or treatment areas, such as X-ray, surgical, or physical therapy, shall provide a minimum clear width of 32 in. (81 cm). 18-2.4 Number of Exits. 18-2.4.1 At least two exits of the types described in $6-2.2 that are remotely located from each other shall be provided for each floor or fire section of the building. 18-2.4.2 Any room and any suite of rooms of more than 2500 ft 2 (252 m ~) shall have at least two exit access doors remotely located from each other. 18-2.4.$ At least two exits of the types described in $6-2.2 shall be

'accessible from each smoke compartment. Egress shall be [ permitted through adjacent compartments, but shall not require return through the compartment of fire origin. 18-2.5 Arrangement of Means of Egress. (See 36-2.5.) 18-2.6 Travel Distance to Exits.

18-2.6.1 Travel distance shall be measured in accordance with Section 5-6. 18-2.6.2 Travel Distance.

(a) The travel distance between any room door required as an exit access and an exit shall not exceed 100 ft ($0 m); and

(b) The travel distance between any point in a room and an exit shall not exceed 150 ft (45 m). Exception: The maximum travel distance permitted in (a) or (b) above shall be increased by 50 ft (15 m) in buildings protectect throughout by an approved, automatic sprinkler system. 18-2.7 Discharge from Exits. (See $6-2.7.) 18-2.8 Illumination of Means of Egress. Means of egress shall be illuminated in accordance with Section 5-8. 18-2.9 Emergency Lighting and Essential Electrical Systems. 18-2.9.1 Emergency lighting shall be provided in accordance with Section 5-9. 18-2.9.2 Where general anesthesia or life-support equipment is used, each ambulatory health care facility shall be provided with an essential electrical system in accordance with NFPA 99, Standard for Health Care Facilities. Exception No. 1: Where battery-operated equipment is provided and acceptable to the authority having jurisdiction. Exception No. 2: This requirement shall not apply to a facility that uses life-support equipment for emergency purposes only. 18-2.10 Marking of Means of Egress. Means of egress shall have signs in accordance with Section 5-10. 18-2.11 Special Means of Egress Features. (Reserved.) 18-$ Protection. 18-3.1 Protection of Vertical Openings. (See 36-3.1.) 18-3.2 Protection from Hazards. (See 36-$.2.) 18-$.2.1 Laboratories employing quantities of flammable, combustible, or hazardous materials that are considered as severe hazard shall be protected in accordance with NFPA 99, Standard for Health Care Facilities. 18-3.2.2 Anesthetizing locations shall be protected in accordance with NFPA 99, Standard for Health Care Facilities. 18-$.$ Interior Finish. (See 36-$.3.) 18-$.4 Detection, Alarm, and Communication Systems. 18-3.4.1 General. Ambulatory health care facilities shall be provided with fire alarm systems in accordance with Section 7-6, except as modified by 18-3.4.~ through 18-3.4.5. 18-3.4.2 Initiation. Initiation of the required fire alarm systems shall be by manual means in accordance with 7-6.2 and by means of any detection devices or detection systems required. 18-$.4.3 Occupant Notification. Occupant notification shall be accomplished automatically, without delay, upon operation of any fire alarm activating device by means of an internal audible alarm in accordance with 7-6.$. 18-3.4.4 Emergency Forces Notification. Fire department notification shall be accomplished in accordance with 7-6.4. Exception: Smoke detection devices or smoke detection systems equipped with reconfirmation features shall not be required to automatically notify the fire depar tment unless the alarm condition is reconfirmed after a maximum 120-see time period. 18-3.4.5 Emergency Control. Operation of any activating device in the required fire alarm system shall be arranged to accomplish automatically, without delay, any control functions required to be performed by that device. (See 7-6.5.) 18-$.5 Extinguishment Requirements. (See $6-$.5.) 18-$.5.1 Isolated hazardous areas shall be permitted to be protected in accordance with 7-7.1.2. Where more than two sprinklers are installed in a single area, water flow detection shall be provided to sound the building fire alarm or notify by a signal any constantly at tended location, such as PBX, security, or emergency room, whereby necessary corrective action shall be directed. 18-$.5.2 Portable fire extinguishers shall be provided in ambulatory health care facilities in accordance with 7-7.4.1. 18-$.6 Corridors. (See $6-3.6.) 18-3.6.1 Openings. Miscellaneous openings such as mall slots, pharmacy pass-through windows, laboratory pass-through windows,

;and cashier pass-through windows shall be permitted to be installed in vision panels or doors without special protection,

~) ovided the ag~gregate area of openings per room does not exceed in. ~ (135 cm z) and the openings are installed at or below half

the distance from the floor to the room ceiling. Exception: For rooms protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 7-7, the aggregate area of openings per room shall not exceed 80 in. s (520 cm~). 18-3.7 Subdivision of Building Space. 18-3.7.1 Ambulatory health care facilities shall be separated from other tenants and occupancies by walls having at least a 1 -hr fire

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resistance rating. Such walls shall extend from the floor slab below to the floor or roof slab above. Doors shall be constructed of at least 13/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be equipped with positive latches. These doors shall bd self<losing and sha l lbe kept in the closed position except when in use. Any vision panels sha l /be of fixed fire window assemblies in accordance with 6-2.3.2.2. 18-3.7.2 The ambulatory health care facility shall be divided into at least two smoke compartments on patient t reatment floors. Exception: Facilities of less than 5000 fC (465 m ~) and protected by an approved, automatic smoke detection system. Exception: (See 101-454) 18-$.7.$ Any required smoke barrier shall be constructed in accordance with Section 6-$ and shall have a fire resistance rating of at least 1 hr. Exception: Dampers shall not be required in duct penetrations of smoke barriers in fully ducted heating, ventilating, and air conditioning systems for buildings protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 7-7. 18-3.7.4 Vision panels in the smoke barrier shall be of fixed fire window assemblies in accordance with 6-2.$.2.2. 18-3.7.5 At least 15 n e t f t ~ (1.4 net m 2) per ambulatory health care facility occupant shall be provided within the aggregate area of corridors, patient rooms, t reatment rooms, lounges, and other low hazard areas on each side of the smoke compartment for the total number of occupants in adjoining compartments. Smoke barriers shall be provided to limit the size of each smoke compartment to an area not exceedin~ 22,500 ft 2 (2100 mZ), and to limit the travel distance from any point to reach a door in the required smoke barrier to 200 ft (60 m). Exception: The area of an atr ium separated in accordance with 6-2.4.6 shall not be limited in size. 18-3.7.6" Doors in smoke barriers shall be at least 13/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be self<losing. A vision panel shall be required. 18-3.7.7 Doors in smoke barriers shall normally be kept closed, or, if held open, they shall be equipped with automatic devices that will release the doors upon activation of:


i automatic fire detection system. i 18-4 Special Provisions. (See Section $6-4. For operating features requirements see Section 18-7.) 18-5 Building Services. 18-5.1 Utilities. Utilities shall comply with the provisions of Section 7-1. 18-5.2 Heating, Ventilating, and Air Conditioning.

[18-5.2.1 Heating, ventilating, and air conditioning shall comply i with the provisions of Section 7-2 and shall be in accordance with the manufacturer 's specifications. Exception: As modified in 18-6.5.2.2. 18-5.2.2 Any heating device other than a central heating plant shall be designed and installed so that combustible material will not be ignited by it or its appurtenances. If fuel-fired, such heating devices shall be chimney or vent connected, shall take air for combustion directly from the outside, and shall be designed and installed to provide for complete separation of the combustion system from the atmosphere of the occupied area. Any heating device shall have safety features to immediately stop the flow o f fuel and shut down the equipment in case of either excessive temperature or ignition failure. Exception: Approved, suspended unit heaters shall be permitted in locauons other than means of egress and patient treatment areas, provided such heaters are located high enough to be out of the reach of persons using the area, and provided they are equipped with the safety features required above. 18-5.3 Elevators, Escalators, and Conveyors. Elevators, escalators, and conveyors shall comply with the provisions of Section 7-4. 18-5.4 Rubbish Chutes, Incinerators, and Laundry Chutes. Rubbish chutes, incinerators, and laundry chutes shall comply with the

~ rovisions of Section 7-5. ECTION 18-6 Reserved

SECTION 18-7" OPERATING FEATURES 18-7.1 Evacuation and Relocation Plan, and Fire Drills. 18-7.1.1 The administration of every ~ health care c.ccup=:.c7 fagjl ~ shall have, in effect and available to all supervisory personnel, written copies of a plan for the protection of all persons in the event of fire and for their evacuation to areas of refuge and for evacuation from the building when necessary. All

employees shall be .periodically instructed and kept informed with respect to their dunes under the plan. A copy of the plan shall be readily available at all times in the telephone operator's position or at the security center. The provisions of 18-7.1.2 to 18-7.2.3 inclusive shall apply• 18-7.1.2" Fire exit drills in ambulatory health care ~cc'.:'p=.~-¢ z

shall include the transmission of a fire alarm signal and simulation of emergency fire conditions. Drills shall be conducted iquarterly on each shift to familiarize facility personnel (nurses, nterns, maintenance engineers, and administrative staff) with

signals and emergency action required under varied conditions• When drills are conducted between 9:00 p.m. (2100 hours) and 6:00 a.m. (0600 hours), a coded announcement shall be permitted to be used instead of audible alarms. Exception: The movement of infirm or bedridden patients to safe areas or to the exterior of the building shall not be required. 18-7.1.3 Employees of ambulatory, health care ~cc'.=p=.~c'.'e: shall be instructed in life safety procedures and devices. 18-7.2 Procedure in Case of Fire. 18-7.2.1" For ambulatory health care ~cc::F=r.-c~ ~ the proper protection of patients shall require the prompt and effective response of ambulatory health care personnel. The basic response required of staff shall include the removal of all occupants directly involved with the fire emergency, transmission of an appropriate fire alarm signal to warn other building occupants and summon staff, confinement of the effects of the fire by dosing doors to isolate the fire area, and the relocation of patients as detailed in the facility's fire safety plan. (See Appendix A for a more detailed suggested emergency plan.) 18-7.2.2 A written h . ~ I ~ c=-~ ~.cc'-paa~/fire safety plan shall provide for

(a) Use of alarms, (b) Transmission of alarm to fire department, (c) Response to alarms, (d) Isolation of fire, (e) Evacuation of immediate area, (f) Evacuation of smoke compartment, (g) Preparation of floors and building for evacuation, and (h) Exunguishment of fire.

18-7.2.3 All ~c:2"~ ~. ~..rc ~.cc::p:.-:~" personnel shall be instructed in the use of and response to fire alarms, and, in addition, they shall be instructed in the use of the code phrase to ensure transmission of an alarm under the following conditions:


(b) During a malfunction of the building fire alarm system. Personnel hearing the code announced shall first activate the building fire alarm using the nearest fire alarm box and then shall execute immediately their duties as outlined in the fire safety plan. 18-7.$ Maintenance of Exits. Proper maintenance shall be provided to ensure the dependability of the method of evacuation selected . . . . . . . . . . . . . r . . . . . . Ambulatory healthcare occuoancies that find it necessary to lock exits shall at all times maintain an adequate staff qualified to release locks and direct occupants from the immediate danger area to a place of safety in case of fire or other emergency. 18-7.4* Smoking. Smoking regulations shall be adopted and shall include the following minimal provisions:

(a) Smoking shall be prohibited in any room, ward, or compartment where flammable liquids, combustible gases, or oxygen is used or stored and in any other hazardous location. Such areas shall be posted with "NO SMOK1NG ~ signs or the international symbol for no smoking. Exception to (a): In ~kca!~h .c~c ¢cc::p.~:clc: Where smoking is prohibited and signs are prominently placed at all major entrances, secondary signs with no smoking language shall not be required.

(b) Smoking by patients classified as not responsible shall be prohibited. Exception to (b): Where the p.atient is under direct supervision.

(c) Ashtrays of noncombusuble material and safe design shall be p rov ided in all areas where smoking is permitted. I (d) Metal containers with self<losin~ cover devices into which [ ashtrays can be emptied shall be readily available to all areas where ] smoking is permitted. [ 18-7.5 Furnishin~s, Bedding, and Decorations. I 18-7.5.1" Draperies, curtains, including cubicle curtains, and other [ loosely hanging fabrics and films serving as furnishings or

decorations in ambulatory health care occupancies shall be in ] accordance with the provisions of 6-6.1. (See 18-3.5.3.) ] Exception: Curtains at showers.

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18-7.5.2 Newly introduced upholstered furniture ;;-~'--- .".z-_"_h ~ , r : =zz::p:.:.: '=: shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(b) and 6-6.$. 18-7.5.$ Newly introduced mattresses - : -~:~ h=-..1*A ~..--c . . . . . . . . . . . . . v--~.~.:̂ - shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(c) and 6-6.4. 18-7.5.4 Combustible decorations shall be prohibited "=:- z.n 7 hczJ~h .z~-c c z ~ , : p ~ z ) " unless flame-retardant. Exception: Combustible decorations of such limited quantities that a hazard of fire development or spread is not present, such as photographs and paintings. 18-7.5.-5 Soiled linen or trash collection receptacles shall not exceed $2 gai (121 L) in capacity. The average density of container capacity in a room or space shall not exceed 0.5 gal per ft s (20.4 L per m~). There shall be not more than $2 gal (1~1 L) capacity within any 64 ft ~ (5.9 m ~) area. Mobile soiled linen or trash collection receptacles with capacities greater than $2 gal (121 L) shall be located in a room protected as a hazardous area when not attended. Exception: Container size and density shall not be limited in hazardous areas. 18-7.6 Maintenance and Testing. (See 1-11.15) 18-7.7* Engineered Smoke Control Systems. New engineered smoke control .systems shall be tested in accordance with established engineering principles and shall meet the performance requirements of such testing prior to acceptance. Following acceptance, all engineered smoke control systems shall be tested periodically in accordance with recognized engineering principles. Test documentadon shall be maintained on the premises at all times. 18-7.8 Portable Space Heating Devices. Portable space heating devices shall be prohibited "n a!l h c a ! ~ c~-c

Exception: Portable space heating devices shall be permitted to be used in nonsleeping staff and employee areas where the heating elements of such devices are limited to not more than 212°F (100°C). 18-7.9 Construction, Repair, and Improvement Operations. 18-7.9.1 Construction, repair, and improvement operations shall comply with 1-11.11. 18-7.9.2 The means of egress in any area undergoing construction, repair, or improvements shall be inspected daily for meeting the requirements of 5-1.9.1 and shall also meet the requirements of NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. CHAPTER 19 EXISTING AMBULATORY HEALTH CARE OCCUPANCIES SECTION 19-1 GENERAL REQUIREMENTS 19-1.1 Application. 19-1.1.1 General. 19.1.1.1.1 The rec)uirements of this chapter apply to existing buildings or poruons thereof currently occupied as an ambulatory health care occupancy 19-1.1.4) 19.1.1.1.2 Ambulatory health care fadlities shall comply with the provisions of Chapter 37 and this ~ whichever is more s t r i n g e n t . . . . . t , . . . . . . . . . . . . . . . . . . . . - . . . . . ~ . . . . . . . . . . n o .

19.1.1.1.$ This ~ establishes life safety requirements, in addition to those required in Chapter $7, for the design of all ambulatory health care facilities as described in 19-1.$. 19-1.1.1.4 Buildings or sections of buildings that primarily house patients who, in the opinion of the governing body of the facility and the governmental agency having jurisdiction, are capable o f judgment and appropriate physical action for self-preservation under emergency conditions shall be permitted to comply with chapters of the Code other than Chapter 19. 19-1.1.1.5 It shall be recognized that, in buildings housing- nroviding treatment for certain types of patients or having detention rooms or a security section, it might be necessary to lock doors and bar windows to confine and protect building inhabitants. In such instances, the authority having jurisdiction shall make appropriate modifications to those sections of this Code that would otherwise require means of egress to be kept unlocked. 19-1.1.1.6 The requirements of this chapter are based on the assumption that staff is available in all patient occupied areas to perform certain fire safety functions as required in other paragraphs of this chapter.

. 19-1.1.2 Goals and Objective. The goals and objectives of Sections 1-5 and 1-6 shall be met with due consideration for functional requirements. This is accomplished by limiting the development and spread of a fire emergency to the room of fire origin and

reducing the need for occupant evacuation, except from the room of fire origin. 19-1.1.$ Total Concept. All ambulatory_ health care facilities shall be designed, constructed, maintained, and operated to minimize the possibility of a fire emergency requiring the evacuation of occupants. Because the safety of ambulatory health care occupants cannot be ensured adequately by dependence on evacuation of the building, their protection from fire shall be provided by appropriate arrangement of facilities, adequate staffing, and development of operating and maintenance procedures composed of the following:

(a) Desi~., construction, and comparunentation; and (b) Prowsion for detection, alarm, and extinguishment; and (c) Fire prevention and the planning, training, and drilling in

programs for the isolation of fire, tr-ansfer of occupants to areas of refuge, or evacuation of the building. 19-1.1.4 Additions, Conversions, Modernization, Renovation, and Construction ..Operations. 19-1.1.4.1 Addiuons. Additions shall be separated from any existing structure not conforming to the provisions within Chapter 19 by a fire barrier having at least a 2-hr fire resistance rating and constructed of materials as required for the addition. (See 1-11.2 and 1-11.6) 19-1.1.4.2 Communicating openings in dividing fire barriers required by 19-1.1.4.1 shall occur only in corridors and shall be protected by approved self-closing fire doors. (See aLso Section 6-2.) 19-1.1•4.$ Doors in barriers required by 19-1.1.4.1 shall normally be kept closed. Exception: Doors shall be permitted to be held open if they meet the requirements of 19-2.2.2.6. 19-1.1.4.4 Changes of Occupancy. A change from a hospital or nursing home to an ambulatory health care occupancy shall not be considered a change in occupancy. 19-1.1•4.5" Renovations, Alterations, and Modernizations. (See 1-11.7. and ~ (DELETE THE REST OF THE PAR.) 19-1.1.4.6 Construction Repair and Improvement Operations. (See 1-11.11) 19-1.2 Mixed Occupancies. (See also 4-1.12.) 19-1.2.1" Sections of ambulatory health care facilities shall be permitted to be classified as other occupancies provided they meet all of the following conditions: (a) They are not intended to serve ambulatory health care occupants for purposes of treatment, or customary access by patients incapable of serf-preservation; (b) They are separated from areas of ;gnhlllgtgKg health care occupancies by construction having a fire resistance rating of at least-g I hr. 19.1.2.$ All means of egress from ambulatory health care occupancies that traverse non-ambulatory health care spaces shall conform to requirements of this Code for ambulatory health care occupancies. Exception: It shall be permissible to exit through a horizontal exit into other contiguous occupancies that do not conform with ambulatory health care egress provisions but that do comply with requirements set forth in the appropriate occupancy chapter of this Code, provided the occupancy does not contain high hazard c o n t e n ~ . 19.1.2.4 Egress provisions for areas of ambulatory health care facilities that correspond to other occupancies shall meet the corresponding requirements of this Code for such occupancies. Where the clinical needs of the occupant necessitate the locking of means of egress, staffshall be present for the supervised release of occupants during all times of use. 19-1.2.5 Any area with a hazard of contents classified higher than that of the ambulatory health care occupancy and located in the same building shall be protected as required in 19-$.2. 19-1.2.6 Non- health care related occupancies classified as containing high hazard contents shall not be permitted in buildings housing ambulatory health care occupancies. 19-1.$* Special Definitions• (AHC DEFINITION REVISED BY P 101-419 ) Ambulatory Health Care Facility. A building or part ~ used to

provide services or treatment to four or more patients at the same time that meets the criteria of(a) or (b) below.

(a) Those facilities that provide, on an outpatient basis, treatment for patients that would render the patients incapable of taking action for self-preservation under emergency conditions without assistance from others.

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(b) Those facilities that provide, on an outpatient basis, anesthesia that would render the natients incanable of takin~ action for self-preservation under emergency condition without assistance of other. 19-1.4 Classification of Occupancy. (See 19-1.$.) 19-1.5 Classification of Hazard of Contents. The classification of hazard of contents shall be as defined in Section 4-2. 19-1.6 Minimum Construction Requirements. 19-1.6.1 For purposes of 19-1.6, the number of stories shall be counted starting with the primary level of exit discharge and ending with the highest occupiahle level. For the purposes of this section, the primary level of exit discharge of a building shall be that floor that is level with or above finished grade of the exterior wall line for 50 percent or more of its perimeter. 19-1.6.2 Buildings of one story in height housing ambulatory health care facilities shall be of any construction type in accordance with NFPA 220, Standard on Types of Building Gonstruction. (See 6-2.1.) 19-1.6.3 Buildings of two or more stories in height housing ambulatory health care fadlities shall be of Type I(443), Type I($32), Type II(222), Type I I ( l l l ) , Type III(211), Type IV(2HH), or Type V ( l l l ) construction. (See 6-2.1.) Exception: Buildings constructed of Type II(000), Type Ill(200), or Type V(OOO), if protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 7-7. 19-1.6.4 Any level below the level of exit discharge shall be separated from the level of exit discharge by at least Type I I ( l l l ) , Type III(211), or Type V ( l l l ) construction. (See 6-2.1.) Exception: Separation shall not be required for such levels if they are under the control of the ambulatory health care facility and any hazardous spaces are protected in accordance with Section 6-4. 19-1.6.5 In existing buildings, the authority having jurisdiction shall be permitted to accept construction systems of lesser fire resistance than required by 19-6.1.6.2 through 19-6.1.6.4 if it can be demonstrated to the authority's satisfaction that prompt evacuation of the facility can be achieved in case of fire or that the exposing occupancies and materials of construction present no threat of fire Faenetration from such occupancy to the ambulatory health care

cility or to the collapse of the structure. 19-1.6.6 All interior walls and partitions in buildings of Type ] or Type II construction shall be of noncombustible or limited-combustible materials. 19-1.6.7 All buildings with more than one level below the level of exit discharge shall have all such lower levels separated from the level of exit discharge by at least Type I I ( l l l ) construction. 19-1.7 Occupant Load. (See 36-1.7.)

19-2 Means of Egress Requirements. 19-2.1 General. Every aisle, passageway, corridor, exit discharge, exit location, and access shall be in accordance with O~apter 5. Exception: As modified by 19-2.2 through 19-2.11. 19-2.2 Means of Egress Components. 19-2.2.1 Components of means of egress shall be limited to the lt~es described in $6-2.2.

2.2.2 Special locking arrangements complying with 5-2.1.6 shall be permitted on exterior doors. 19-2.2.$ Any door in an exit passageway, horizontal exit, smoke barrier, stairway enclosure, or hazardous area enclosure shall be permitted to be held open only by an automatic release device that complies with 5-2.1.8. The required manual fire alarm system and the systems required by 5-2.1.8, Exception(c), shall be ~ g e d to initiate the closing action of all such doors by zone or throughout the entire facility. 19-2.2.4 Where doors in a stair enclosure are held open by an automatic device as permitted in 19-6.2.2.3, initiation of a door closing action on any level shall cause all doors at all levels in the stair enclosure to dose. 19-2.3 Capacity of Means of Egress. 19-2.$.1 The capacity of any required means of egress shall be determined in accordance with the provisions of $6-2.3 and shall he based on its width as defined in Secdon 5-3. 19-2.3.2 The minimum width of any corridor or passageway required for exit access shall be 44 in. (112 cm) in clear width. 19-2.3.3 Doors in the means of egress from diagnostic or t reatment areas, such as X-ray, surgical, or physical therapy, shall provide a minimum clear width of 32 in. (81 cm). 19-2.4 Number of Exits. Exception: existing M-in. (86-cm) doors.

19-2.4.1 At least two exits of the types described in $6-2.2 that are remotely located from each other shall be provided for each floor or fire section of the building. 19-2.4.2 Any room and any suite of rooms of more than 2500 ft ~ (232 m ~) shall have at least two exit access doors remotely located from each other 19-2.4.$ At least two exits of the types described in $6-2.2 shall be accessible from each smoke compartment. Egress shall be permitted through adjacent compartments, but shall not require r e m m through the compartment of fire origin. 19-2.5 Arrangement of Means of Egress. (See 36-2.5.) 19-2.6 Trave/Distance to Exits. 19-2.6.1 Travel distance shall be measured in accordance with Section 5-6. 19-2.6.2 Travel Distance.


(b) The travel distance between any point in a room and an exit shall not exceed 150 ft (45 m). Exception: The maximum travel distance permitted in (a) or (b) above shall be increased by 50 ft (15 m) in.buildings protected throughout by an approved, automatic sprinkler system. 19-2.7 Discharge from Exits. (See 36-2.7.) 19-2.8 Illumination of Means of Egress. Means of egress shall be illuminated in accordance with Section 5-8. 1 9-2.9 Emergency Lighting and Essential Electrical Systems. 19-2.9.1 Emergency lighting shall be provided in accordance with Section 5-9. 19-2.9.2 Where general anesthesia or life-support equipment is used, each ambulatory health care facility shall be provided with an essential electrical system in accordance with NFPA 99, Standard for Health Care Facilities. Exception No. 1: Where battery-operated equipment is provided and acceptable to the authority having jurisdiction. Exception No. 2: This requirement shall not apply to a facility that uses life-support equipment for emergency purposes only. 19-2.10 Marking of Means of Egress. Means of egress shall have signs in accordance with Section 5-10. 19-2.11 Special Means of Egress Features. (Reserved.) 19-3 Protection. 19-$.1 Protection of Vertical Openings. (See 36-$.1.) 19-$.2 Protection from Hazards. (See $6-$.2.) 19-5.2.1 Laboratories employing quantities of flammable, combustible, or hazardous materials that are considered as severe hazard shall be protected in accordance with NFPA 99, Standard for Health Care Facilities. 19-3.2.2 Anesthetizing locations shall be protected in accordance with NFPA 99, Standard for Health Care Facilities. 19-3.3 Interior Finish. (See $6-3.$.) 19-$.4 Detection, Alarm, and Communication Systems. 19-$.4.1 General. Ambulatory health care facilities shall be provided with fire alarm systems in accordance with Section 7-6, except as modified by 19-5.4.2 through 19-$.4.5. 19-$.4.2 Initiation. Initiation of the required fire alarm systems shall be by manual means in accordance with 7-6.2 and by means of any detection devices or detection systems required. 19-5.4.$ Occupant Notification. Occupant notification shall be accomplished automatically, without delay, upon operation of any fire alarm activating device by means of an internal audible alarm in accordance with 7-6.3. 19-$.4.4 Emergency Forces Notification. Fire department notification shall be accomplished in accordance with 7-6.4. Exception: Smoke detection devices or smoke detection systems equipped with reconfirmation features shall not be required to automatically notify the fire depar tment unless the alarm condition is reconfirmed after a maximum 120-see time period. 19-3.4.5 Emergency Control. Operation of any activating device in the required fire alarm system shall be arranged to accomplish automatically, without delay, any control functions required to be performed by that device. (See 7-6.5.) 19-5.5 Extinguishment Requirements. (See $6-$.5.) 19-3.5.1 Isolated hazardous areas shall be permitted to be protected in accordance with 7-7.1.2. For new installations in existin~ ambulatory health care facilities, where more than two sprinklers are installed in a single area, water flow detection shall be provided to sound the building fire alarm or notify by a signal any constantly at tended location, such as PBX, security, or emergency room, whereby necessary corrective action shall be directed. 19-$.5.2 Portable fire extinguishers shall be provided in ambulatory health care facilities in accordance with 7-7.4.1. 19-3.6 Corridors. (No requirements) 19-$.7 Subdivision of Building Space.

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19-3.7.1 Ambulatory health care facilities shall be separated from other tenants and occupancies by walls having at least a 1 -hr fire resistance rating. Such walls shall extend from the floor slab below to the floor or roof slab above. Doors shall be constructed of at least 15/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be equipped with posidve latches. These doors shall be self-closing and shall be kept in the closed position except when in use. Any vision panels shall be of fixed fire window assemblies in accordance with 6-2.$.2.2. 19-5.7.2 The ambulatory health care facility shall be divided into at least two smoke compartments. Exception: Facilities of less than 5000 ft 2 (465 m ~) and protected by an approved, automatic smoke detection system, Exception: (See 101-498) 19-3.7.$ Any required smoke barrier shall be constructed in accordance with Section 6-$ and shall have a fire resistance rating of at least 1 hr. Exception: Dampers shall not be required in duct penetrations of smoke harriers in fully ducted heating, ventilating, and air conditioning systems for buildings protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 7-7. 19-$.7.4 Vision panels in the smoke barrier shall be of fixed fire window assemblies in accordance with 6-2.$.2.2. 19-3.7.5 (reserved) 19-$.7.6" Doors in smoke barriers shall be at least 15/4-in. (4.4-cm) thick, solid bonded wood core or the equivalent and shall be self-closing. A vision panel shall be required. 19-$.7.7 Doors in smoke barriers shall normally be kept closed, or, if held open, they shall be equipped with automatic devices that will release the doors upon activation of: (a) The fire alarm system, and either (b) A local smoke detector, or (c) A complete automatic fire extinguishing system or complete automatic fire detection system. 19-4 Special Provisions. (See Section $6-4. For operating features requirements see Section 19-7.) 19-5 Building Services. 19-5.1 Utilities. Utilities shall comply with the provisions of Section 7-1.

I Exception: Existing installations shall be permitted to be continued in service provided the systems do not present a serious hazard to life. 19-5.2 Heating, Ventilating, and Air Conditioning. 19-5.2.1 Heating, ventilating, and air conditioning shall comply with the provisions of Section 7-2 and shall be in accordance with the manufacturer's specifications. +

Exception: As modified in 19-6.5.2.2. 19-5.2.2 Any heating device other than a central heating plant shall be designed and installed so that combustible material will not be ignited by it or its appurtenances. If fuel:fired, such heat ing devices shall be chimney or vent connected, shall take air for combustion directly from the outside, and shall be designed and installed to provide for complete separation of the combustion system from the atmosphere of the occupied area. Any heating device shall have safety features to immediately stop the flow o f fuel and shut down the equipment in case of either excessive temperature or ignition failure. Exception: Approved, suspended unit heaters shall be permitted in locations other than means of egress and patient treatment areas, provided such heaters are located high enough to be out of the reach of persons using the area, and provided they are equipped with the safety features required above. 19-5.3 Elevators, Escalators, and Conveyors. Elevators, escalators, and conveyors shall comply with the provisions of Section 7-4. 19-5.4 Rubbish Chutes, Incinerators, and Laundry Chutes. Rubbish chutes, incinerators, and laundry chutes shall comply with the provisions of Section 7-5. SECTION 19-6 Reserved SECTION 19-7" OPERATING FEATURES 19-7.1 Evacuation and Relocation Plan, and Fire Drills. 19-7.1.1 The administration of every a~ahlllgto.~ health care ~ . c c : : p : : : } ' ~ shall have, in effect and available to all supervisory personnel, written copies of a plan for the protection of all persons in the event of fire and for their evacuation to areas of refuge and for evacuation from the building when necessary. All employees shall be periodically instructed and kept informed with respect to their duues under the plan. A copy of the plan shall be readily available at all times in the telephone operator's position or • at the security center. The provisions of 19-7.1.2 to 19-7.2.3 inclusive shall apply.

19-7.1.2" Fire exit drills in ambulatory health care ^ - - : F ̂ - - ' - - shall include the transmission of a fire alarm signal and

simulation of emergency fire conditions. Drills shall be conducted quarterly on each shift to familiarize facility personnel (nurses, interns, maintenance engineers, and administrative staff) with

als and emergency action required under varied conditions. n drills are conducted between 9:00 p.m. (2100 hours) and

6:00 a.m. (0600 hours), a coded announcement shall be permitted to be used instead of audible alarms. Exception: The movement of infirm or bedridden patients to safe areas or to the exterior of the building shall not be required. 19-7.1.$ Employees of ambulatory health care czc:=F:_-=c':: ~ d f i 6 ~ shall be instructed in life safety procedures and devices. 19-7.2 Procedure in Case of Fire. 19-7.2.1" For ambulatory health care : . c : ' : p : : - : : ~ the proper protection of patients shall require the prompt and effective response of ambulatory health care personnel. The basic response required of staff shall include the removal of all occupants directly involved with the fire emergency, transmission of an appropriate fire alarm signal to warn other building occupants and summon staff, confinement of the effects of the fire by closing doors to isolate the fire area, and the relocation of patients as detailed in the facility's fire safety plan. (See Appendix A for a more detailed suggested emergency plan.) 19-7.2.2 A written h~.~.!'._ h. ~._~-~ ~C~ap~a~ " fire safety plan shall provide for

(a) Use of alarms, (h) Transmission of alarm to fire department, (c) Response to alarms, (d) Isolation of fire, (e) Evacuation of immediate area, (f) Evacuation of smoke compartment, (g) Preparation of floors and building for evacuation, and (h) Exunguishment of fire.

19-7.2.3 All .h.~:2~ ~. .~.-~ ~.cc::F:~. ~" personnel shall be instructed in the use of and response to fire alarms, and, in addition, they shall be instructed in the use of the code phrase to ensure transmission of an alarm under the following conditions:


(h) During a malfunction of the building fire alarm system. Personnel hearing the code announced shall first activate the building fire alarm using the nearest fire alarm box and then shall execute immediately their duties as outlined in the fire safety plan. 19-7.3 Maintenance of Exits. Proper maintenance shall be provided to ensure the dependability of the method of evacuation selected. Ambulatory healthcare occupancies that find it necessary to lock exits shall at all times maintain an adequate staff qualified to release locks and direct occupants from the immediate danger area to a place of safety in case of fire or other emergency. 19-7.4" Smoking. Smoking regulations shall be adopted and shall include the following minimal provisions:

(a) Smoking shall be prohibited in any room, ward, or compartment where flammable liquids, combustible gases, or oxygen is used or stored and in any other hazardous location. Such areas shall be posted with "NO SMOKING" signs or the international symbol for no smoking. ~cep t ion to (a): In .k.c:2~. ~. ::--c :.c~-.:F:.:c'c; Where smoking is )rohibited and signs are prominently placed at all major entrances,

secondary signs with no smoking language shall not he required. (b) Smoking by patients classified as not responsible shall be

prohibited. Exception to (b): Where the p.atient is under direct supervision.

(c) Ashtrays of noncombusuble material and safe design shall be provided in all areas where smoking is permitted.

(d) Metal containers with self-closing, cover devices into which ashtrays can be emptied shall be readily available to all areas where smoking is permitted. 19-7.5 Furnishing, Bedding, and Decorations. 19-7.5.1" Draperies, curtains, including cubicle curtains, and other loosely hanging fabrics and films serving as furnishings or decorations in ambulatory health care occupancies shall be in accordance with the prov+sions of 6-6.1. (See 19-$.5.$.) Exception: Curtains at showers. 19-7.5.2 Newly introduced upholstered furniture :-'~k2a =~.::2~ k. :~-= ~:=p:.==:.=: shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(b) and 6-6.$. 19-7.5.$ Newly introduced mattresses ;~-~'= ~ : : I ~ -~.-e . . . . . . . . . . . . . t- . . . . . . . : ~ shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(c) and 6-6.4.

189


19-7.5.4 Combustible decorations shall be prohibited in m~ 7 ~c~2".. ~, c~.-c cc=apa=c 7 unless flame-retardant. Exception: Combustible decorations of such limited quantities that a hazard of fire development or spread is not present, such as photographs and paintings. 19-7.5.5 Soiled l inen or trash collection receptacles shall no t exceed 82 gal (121 L) in capacity. The average density of container capadty in a room or space shall not exceed 0.5 gal per ft ~ (20.4 L per m~). There shall be not more than 32 gal (1~1 L) capacity within any 64ft ~ (5.9 m ~) area. Mobile soiled linen or trash collection receptacles with capacities greater than $2 gal (121 L) shall be located in a room protected as a hazardous area when not attended. Exception: Container size and density shall not be limited in hazardous areas. 19-7.6 Maintenance and Testing. (See 1-11.13) 19-7.7" Engineered Smoke Control Systems. New engineered smoke control systems shall be tested in accordance with established engineering principles and shall meet the performance requirements of such testing prior to acceptance. Following acceptance, all engineered smoke control systems shall be tested periodically in accordance with recognized engineering principles. Test documentat ion shall be maintained on the premises at all times. 19-7.8 Portable Space Heating Devices. Portable space heating devices shall be prohibited ~n :2' ~c:2".h care

Exception: Portable space heating devices shall be permitted to be used in nonsleeping staff and employee areas where the heating elements of such devices are limited to not more than 212°F (I00°C). 19-7.9 Construction, Repair, and Improvement Operations. 19-7.9.1 Construction, repair, and improvement operations shall comply with 1-11.11. 19-7.9.2 The means of egress in any area undergoing construction, repair, or improvements shall be inspected daily for meeting the requirements of 5-1.9.1 and shall also meet the requirements of NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations. Also revise Chapter 12.1.1 as follows: SECTION 12-1 GENERAL REQUIREMENTS 12-1.1 Application. 12-1.1.1 General. 12-1.1.1.1 The requirements of this chapter apply to

(a) New buildings or portions thereof used as health care occupancies (see 1-4.1); and

(b) Additions made to, or used as, a health care occupancy (see 1-11.6 and 12-1.1.4); and Exception to (b): Additions classified as occupancies other than health care that are properly separated from the health care occupancy in accordance with 19-1.2.1 and conform to the requirements for the specific occupancy in accordance with Chapters 8 through 11 and Chapters 14 through $1, as appropriate.

(c) Alterations, modernizations, or renovations of existing health care occupancies (see 1-11.7 and 12-1.1.4); and

(d) Existing buildings or portions thereof upon change of occupancy to a health care occupancy (see 1-11.2). Exception:* Facilities where the authority having jurisdiction has determined equivalent safety has been provided in accordance with Secdon 1-9. 12-1.1.1.2 This chapter establishes life safety requirements for the design of all new hospitals, nursing homes, and limited care facilities. Where requirements vary, the specific subclass of health care occupancy is named in the paragraph pertaining thereto. ~cc~c.n . . ~ Chapter XY establishes life safety requirements for all new ambulatory health care facilities. Section 12-7 establishes operating features for all health care occupancies. | ~-1,1.1.3 }tealth care facilities regulated by this Chapter provide sleeoing accommodations for their occuoants and are occunied by nersonswho are mosdv inca.able of set#nreservation because of age. .hvsical or mentaJ disal~ilitv, or because of security meascres not under the o~;cupants' control. 12-1.1.1.4Buildings or sections of buildings that primarily house patients who, in the opinion of the governing body of the facility

!and the governmental agency having jurisdiction, are capable of j u d g m e n t and appropriate physical action for self-preservation under emergency conditions shall be permitted to comply with chapters of the Code other than Chapter 12.

I 12-1.1.1.5 It shall be recognized that, in buildings housing certain types of patients or having detention rooms or a security section, it m~ght be necessary to lock doors and bar windows to confine and protect building inhabitants. In such instances, the authority having

jurisdiction shall make appropriate modifications to those sections of this Code that would otherwise require means of egress to be kept unlocked. 12-1.1.1.6 Buildings or sections of buildings that house older persons and that provide activities that foster continued independence but do not include services distinctive to health care facilities (as defined in 12-1.$) shall be permitted to comply with the requirements of other sections of this Code, such as Chapters

! 18 o i 22. 12-1.1.1.7 ExecS: for :mbul==c D" ~eaP..h c~-c fz.cili'2~., Ffacilities that do not provide housing on a 24-hr basis for their occupants

sha l l be classified as other occupancies and shall be covered by other chapters of this Code.

] 12-1.1.1.8*The requirements of this chapter are based on the assumption that staff is available in all patient occupied areas to perform certain fire safety functions as required in other paragraphs of this chapter. Revise 12-1.$ as follows:

112-1 .5" Special Definitions. Ambulatory Health Care Facilities. A 5ui!dlng c.: F ~ of = bu i l~ng

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,:22Y_' ::'V~'Y

pafic~t= "n==p=l=!: ~f *:&'ng =c~or. f=r :c~ ~rc:cr'.~c.:~ ua~c :

See XY-1.3 (New Chanter for New Ambulatory Health Care Occunancies~ Hospital. A building or part thereof used on a 24-hr basis for the medical, psychiatric, obstetrical, or surgical care of four or more inpatients. The term hospital, wherever used in this Code, shall include general hospitals, psychiatric hospitals, and specialty hospitals. Limited Care Facility. A building or part of a building used on a 24-hr basis for the housin~ of four or more persons who are incapable of self-preservatmn because of age, physical limitations due to accident or illness, or mental limitations such as mental retardat ion/developmental disability, mental illness, or chemical dependency. Nursing Home. A building or part of a building used on a 24-hr basis for the housing and nursing care of four or more persons who, because of mental or physical incapacity, might be unable to provide for their own needs and safety without the assistance of another person. The term "nursing home," wherever used in this Code, shall include nursing and convalescent homes, skilled nursing facilities, intermediate care facilities, and infirmaries in homes for the aged. Delete Section 12-6. Revise 15-1.1 as follows: 15-1.1 Application. 15-1.1.1 General. " 15-1.1.1.1 The requirements of this chapter apply to existing buildings or portions thereof currently occupied as health care occupancies. (See also 12-1.1.1.1.) Exception:* Facilities where the authority having jurisdiction has determined equivalent safety has been provided in accordance with Section 1-9. 15-1.1.1.2 This chapter establishes life safety requirements for all existing hospitals, nursing homes, and limited care facilities. Where requirements vary, the specific subclass of health care occupancy is named in the paragraph pertaining thereto. Scctlcn !2 5 GhaRt~ XY establishes life safety requirements for all existing ambulatory health care facilities. Section 15-7 establishes operating features requirements for all health care occupancies. 15-1.1.1.~ Health care facilities ret, ulated b¢ this Chanter ,rovide s lee, ing accommodations for their occuoants and are oc-cu,ied by oersons who are mostly inca , able of self preservation because of age. ,hvsical or mentai disal~ilitv, or because of security measures I19~ ~jnder the oqcupants' control. 1 5-1.1.1.4 Buildings or sections of buildings thatpr imari ly house patients who, in the opinion of the governing body of the facility and the governmental agency having jurisdiction, are capable of judgment and appropriate physical action for self-preservation under emergency conditions shall be permitted to comply with chapters of the Code other than Chapter 13. 1 5-1.1.1.5 It shall be recognized that, in buildings housing certain types of patients or having detention rooms or a security section, it mzght be necessary to lock doors and bar windows to confine and protect building inhabitants. In such instances, the authority having jurisdiction shall make appropriate modifications to those secdons

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N F P A 101 ~ F 9 9 R O C

I of this Code that would otherwise require means of egress to be kept unlocked. 13-1.1.1.6 Buildings or sections of buildings that house older

I persons and that provide activities that foster continued independence but do not include services distinctive to health care facilities (as defined in 13-1.3) might be subject to the requirements of other sections of this Code, such as Chapters 19 or 23. 13-1.1.1.7 . . . . . v . . . . . . . . . . . . . . s . . . . . . . e f= . . . . . . . . Ffacilities that do not provide housing on a 24-hr basis for their occupants shall be classified as other occupancies and shall be covered by other chapters of this Code. 13-1.1.1.8" The requirements of this chapter are based on the assumption that staff is available in all patient occupied areas to perform certain fire safety functions as required in other paragraphs of this chapter. Revise 13-1.3 as follows: 13-1.3" Special Definitions. Ambulatory Health Care Facilities. A 5=!!cling or Fart of a b'- '!~'ng • ,.::,c~ to prosaic =.c'TAzc: ~r =r~=a..z=: to f~.ur cr m=:c p=:]en= at

See ~ - 1 . 3 (New Chapter for existing ambulatory health care occupancies Hospital. A building or part thereof used on a 24-hr basis for the medical, psychiatric, obstetrical, or surgical care of four or more inpatients. The term hospital, wherever used in this Code, shall include general hospitals, psychiatric hospitals, and specialty hospitals. Limited Care Facility. A building or part of a building used on a 24-hr basis for the housing of four or more persons who are incapable of self-preservation because of age, physical limitations due to accident or illness, or mental limitations such as mental retardation/developmental disability, mental illness, or chemical dependency. Nursing Home. A building or part of a building used on a 24-hr basis for the housing and nursing care of four or more persons who, because of mental or physical incapacity, might be unable to provide for their own needs and safety without the assistance of another person. The term "nursing home," wherever used in this Code, shall include nursin.~ and convalescent homes, skilled nursing facilities, intermediate care facilities, and infirmaries in homes for the aged. Delete Section 13-6. COMMITTEE STATEMENT: The Committee Action accomplishes what the submitter requested. However, it retains some of the provisions that the submitter suggested be deleted, but which are needed for completeness. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 344 - (12-6.1.1.1, 13-6.1.1.1): Accept in Principle SUBMITFER: Mayer D. Zimmerman, U.S. Dept. of Health and Human Services COMMENT ON PROPOSAL NO: 101-450 RECOMMENDATION: In response to my submittal, the Committee added the sentence "Section 12-7 establishes operating features requirements for all health care occupancies". In their statement the Committee concludes by saying "This should meet the submitter's intent".

It does not. My intent was to clarify current language to make it abundantly clear that operating features apply to AHC's to the same degree that they apply to hospitals and nursing homes. That is why I specifically recommended that the words "Sections 12-7/13-7 shall apply to ambulatoryhealth care facilities". SUBSTANTIATION: The absence of a very specific reference to AHC's in 12-6.1.1.1/13-6.1.1.1 (or even 12-1.1.1.2/13-1.1.12) has often been the subject of misinterpretation in the past and presents a need for specific language. I urge the committee to replace the generic language of their response with the specific language of my recommendation.

COMMITrEE ACTION: Accept in Principle. See Comment 101-543 (Log #336).

COMMr[TEE STATEMENT: The referenced comment creates new chapters for Ambulatory Healthcare Occupancies. This clarifies the intent and should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMIqiq'EE ACTION:



101- 345 - (12-6.3.7): Accept in Principle SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-455 RECOMMENDATION: Add a new Exception to 12-1.2.2 and 12- 1.2.3 as follows:

"As reouired in 12-6,3,7,1," Add a new Exception to 13-1.2.2 and 13-1.2.3 as follows: "As reuuired in 13-6.3.7.1."

SUBST.$d~ITIATION: Currently, paragraphs 12-1.2.2, 12-1.2.3, 13-1.2.2, and 13-1.2.3 permit facilities to be classified as other occupancy types only ff they are separated from health care occupanoes by construction having a fire resistance rating of at least 2 hours. However, paragraphs 12-6.3.7.1 and 15-6.3.7.1 permit ambulatory health care facilities to be separated from other tenants and occunancies by walls having at least a 1-hr fire resistance rating. Since ambulatory health care facilities are classified as Health Care Occupanoes, paragraphs 12-1.2.2, 12-1.2.3, 13-1.2.2, and 13-1.2.3 would always require 2-hr fire rated construction to separate occupancies within an ambulatory health care facility. This proposal seeks to coordinate the intent of 12-6.3.7.1 and 13-6.3.7.1 with 12-1.2. and 15-1.2 respectively, and to eliminate overly restrictive requirements for the intended levels of protection for this occupancy type. COMMITTEE ACTION: Accept in Principle.

See Comment 101-$43 (Log #336). COMMITI'EE STATEMENT: The action on the referenced comment creates separate chapters for Ambulatory Healthcare Occupancies. Thus, there will be no conflict remaining within Chapters 12 and 13. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 346 - (i2-6.3.7.2 Exception No. 2): Reject SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-454 RECOMMENDATION: Eliminate the new Exception No. 2. SUBSTANTIATION: There is no technical justification included within the Committee Substantiation to make this new exception for the construction of smoke barriers in facilities of a particular size. The purpose of the smoke barrier is to permit the relocation of patients within the health care occupancy, and not to require them to be relocated out of the facility as the substantiation suggests.

In addition, sprinkler protection in older office buildings is not commonplace, and facilities in buildings housing other occupancy

eS without sprinkler protection may be subject to exposure cts, especially smoke, from fires in adjoining spaces which,

although separated by fire rated construction, may not be protected by automatic sprinklers or have the occupancy separation constructed as a smoke barrier.

While sprinklers will serve to reduce the effect of a fire and permit longer periods of time which may be available for patient evacuation, they do not adequately provide a smoke-controlled environment to which patients may be relocated during a fire emergency within the building. COMMITTEE ACTION: Reject. COMMITI'EE STATEMENT: The Committee Action on Proposal 101-454 is justified. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITI'EE ACTION:


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EXPLANATION OF NEGATIVE: BUSH: The Committee has offered no newjnstification for this

new exception for the construction of smoke barriers in facilities of a particular size. The separation of facilities to limit the spread of smoke and to provide for smoke compartments serving as areas of refuge for patients within acceptable travel distances and of acceptable sizes has no apparent correlation to the installation of automatic sprinkler protection as stated in the writer's substantiation for the original comment.

ZIMMERMAN: I must agree with Mr. Bush. The purpose of a smoke barrier in an ambulatory health care facility is to divide the facility into two parts so that one is an area of refuge from the other. Either compartment could serve as an area of relocation rather than necessitating a total evacuation. Please keep in mind that health care occupancies provide "protection in place" rather than "evacuation" as a fire protection philosophy. By eliminating this exception we are saying that evacuation is our only method-we do not want to protect in place. That is contrary to the philosophy of the occupancy. We should restore this item and require the compartmentation regardless of size.


101- 347 - (12-6.3.7.2, 136.3.7.2): Accept in Principle SUBMrrTER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101455 RECOMMENDATION: Add a new exception, but modify the proposed new text as follows;

Exception No. 2: A wall separating the ambulatory health care facility from an adjoining occupancy, may be used provided the wall meets all requirements of 12/13-6.3.7, the ambulatory health care facility is less than 22,500 sq ft and the adjoining occupancy is under the administrative control of the ambulatory health care facility. SUBSTANTIATION: The revised text addresses the committee's concern that the adjoining space.might be locked. The equipment issue is not valid since the same issue could he raised in a hospital when a patient zone evacuates horizontally into an administrative zone. With regard to the authority having jurisdiction, if the administrative control of the adjoining space lies with the AHC facility the authority having jurisdiction would then have jurisdiction. COMMITTEE ACTION: Accept in Principle.

Add an Exception to 12-6.3.7.2 and 13-6.3.7.2 to read: Exception No. 2: An area in an adjoining occupancy shall be

permitted to serve as a smoke compartment for the ambulatory healthcare facility if:

(a) The separating wall and both compartments meet the requirements of 12/13-6.3.7, and

(b) The ambulatory heaithcare facility is less than 22,500 sq. fL, and

(c) Access from the ambulatory healthcare facility to the other occupancy is unrestricted. COMMITTEE STATEMENT: The Committee Action revises the submitter's wording to clarify intent. This should meet the submitter's intent. NUMBER OF CoMMrlTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 348- (12-7.2.2, 15-7.2.2): Reject SUBMITYER= Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-460 RECOMMENDATION: Revise text:

"12-7.2.2/13-7.2.2 A written facility fire safety plan shall provide for.

(a) Use of alarms, (b) Transmission of alarm to fire deparunent, to include an

emenzencv televhone call when an active fire is in progress, ...". SUBSTAHTIA'rION: Every fire fighter I talk with, and my own experience, and monitoring fire department dispatch; all say a phone call reporting fire is responded to differently than an automatic alarm. I will present additional data to committee at the meeting.

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The wording as shown in the ROP is adequate. The submitter has not provided adequate substantiation for adding the new requirement. The submitter's suggested wording might actually result in an unwanted action where the initial transmission of the alarm would be ignored while the emergency forces personnel wait for the subsequentphone call. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITIT, E ACTION:



101- 349 - (12-7.2.2, 13-7.2.2): Accept in Principle SUBMITrER: Eugene A. Cable, U.S. Deparunent of Veterans Affairs COMMENT ON PROPOSAL NO: 101460 RECOMMENDATION: Revise 12-7.2.2 and 13-7.2.2 to read: SUBSTANTIATION: Committee action did not include this as applying to 13-7.2.2. Committee oversight - intent was to change 13-7.2.2 as well. COMMITTEE ACTION: Accept in Prindple.

See the Committee Action for proposal 101460 on page 211 of the ROP. The proposed text for 12-7.2.2 and 13-7.2.2 appear within the committee action. Thus no additional change is necessary. COMMITTEE STATEMENT: This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 17 NOT RETURNED: I Crowlcy


101- 350 - (12-7.4(a) and 13-7.4(a) Exception): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-465 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-HEA, as a group, consider the proposal. This is because the committee action of "Reject" that was balloted through the committee was developed by the Chair after SAF-HEA held its final ROP-preparation meeting. The proposal had "slipped through the cracks" and had not been forwarded to the committee as part of its meeting agenda. It "resurfaced" after the committee had met. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Prindple.

[ Reaffirm the rejection of Proposal 101-465. COMMITrEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS F~LIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16 NEGATIVE: 1 NOT RETURNED: 1 Crowiey

EXPLANATION OF NEGATIVE: ZIMMERMAN: I cannot agree with the Committee's original

JhUStifiration-regardless of whether it "slipped through the cracks" or ow it was voted upon. I am not commenting on the procedure

used to come up with a rejection. I am commenting on the spedfics of the issue. The use of a "secondary sign" -in the words of the committee statement-is indeed jnstified in areas where oxygen is stored or in use. The possible presence of an oxygen enriched atmosphere does NOT make this sign ~secondacy."

NFPA 99, 1999, does indeed contain the requirement that NO SMOKING signs be provided in areas where oxygen is stored, re .~'.~.dless of whether it is located within a NO SMOKING budding, with or without a sign on the door. During NFPA 101 committee deliberations on this item, I stated that if NFPA 99 chose to re-require the signs, NFPA 101 should do so as well. The response by a member of the committee was that this is not an issue of consistency, just that NFPA 99 is more stringent than NFPA 101. The nature of the hazard provided by not making every effort to prohibit smoking in a possible oxygen-enriched atmosphere, makes the NO SMOKING sign a primary sign. I urge the committee to go along with NFPA 99 and restore the requirement for a NO SMOKING sign-regardless of whether it is verbal or pictorial.

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N F P A 101 - - F 9 9 R O C


101- 351 - (15-2.$.2 Exception): Reject SUBMITTER: Thomas W. Jaeger /Thomas W. Gardner, American Health Care Assn. (AHGA) COMMENT ON PROPOSAL NO: 101-214 RECOMMENDATION: Change to 0.3 in. and 0.2 in. in the Exception to paragraph 15-2.3.2 to 0.2 in. and 0.15 in. SUBSTANTIATION: Although proposal 101-214 was submitted for Table 5-3.3.1 and accepted, it conflicts with the Exception to paragraph 13-2.$.2. The purpose of this change is to eliminate the conflict. COMMrI'TEE ACTION: Reject. COMMITTEE STATEMENT: The change is not needed because the SAF-MEA Committee took an action not to change Table 5- $.$.1 to reduce the capacity factors for sprinklered buildings. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 352 - (13-2.$.5): Accept S U B M I T I T ~ James IL Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101476

I RECOMMENDATION: Revise proposed exception to read: Exception No. 2: Existing 28-inch (71-cm) corridor doors in

facilities where the fire plans do not require evacuation by b e d , ~ gurney or wheelchair. SUBSTANTIATION: Wheelchairs will not fit through a 28 in. door• This door will provide less than 26 in. of dear width. COMMITTEE ACTION: Accept• NUMBER OF COMMITI"EE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 17 NOT RETURNED: I Crowley


101- 353 - (13-3.2.1): Hold SUBMITTER: Peter A. Larrimer, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101.479 RECOMMENDATION: Add the following text after the fourth sentence:

"The door shall not require positive latching where the closer holds the door fully closed when a force of 5 Ibf is applied at the latch edge of the door." SUBSTANTIATION: The newly formed Healthcare Interpretations Task Force has provided the above interpretation (Inside ASHE Winter 1998 No. 98-6). They used paragraph 15-3.6.3.2 for their guidance even though that paragraph addresses corridor doors only. This change will clarify that hazardous doors with closers exerting 5 Ibf is acceptable regardless of where they are located, i.e., they don ' t have to be corridor doors. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The submitter's language introduces new material that has not had public review. It is not related to the subject addressed by Proposal 101.479. Therefore, it must be held

~l~ cessing during the next revision o/de. ER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 17 NOT RETURNED: 1 Crowley


101- 354 - (15-3.3.2): Reject SUBMITTER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-481 RECOMMENDATION: Accept the original proposal as submitted. SUBSTANTIATION: See Comment 101-$55 (Log #$$8) on Proposal 101-482. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter's recommendation would make the provisions applicable to new materials and existing buildings stricter than those for new healthcare occupancies as addressed by Chapter 12. This is not the committee's intent.

NUMBER OF COMMrI ' rEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:


18


101- 355 - (13-3.3.2(a) Exception): Accept in Principle SUBMITrER: Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101482 RECOMMENDATION: Do not delete this Exception. SUBSTANTIATION: No technical justification has be given for now allowing class C interior finish in areas other than currently permitted by the 1997 edition of the Code. Clearly the committee at the time, intended to limit the use of class C interior finish to rooms separated from corridors in fully sprinldered zones or they would not have written the exception as they did. Your action is a MAJOR departure from that line of thinking. Your action will permit an unlimited amount of Class C interior finish even throughout egress corridors. The National Forest Products Assoc. has a listing of interior finishes for most wood products. The members of the committee may be surprised to know that more than 90% of the listed wood products, including untreated cedar i shakes, particleboard and luan all meet a Class C interior finish rating for flame spread. Please reconsider your action. COMMITTEE ACTION: Accept in Principle.

Do not delete the Exception to 15-$.$.2(a) but reword it to read: Exception to (a): In rooms protected by an approved, supervised

automatic sprinkler system, Class C interior finish, shall be permitted to be continued to be used on walls and ceilings within rooms separated from the exit access corridor in accordance with 15-3.6. COMMITTEE STATEMENT: The exception has been retained but reworded to clarify that it is the intent that as long as the room is

~[~ rinklered, then the allowance can be taken. This should meet e submitter's intent.

NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18

VOTE ON COMMITIT_~ ACTION: AFFIRMATIVE: 17 NOT RETURNED: 1 Crowley


101- 356 - (15-3.4.2): Hold SUBMITrER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-483 RECOMMENDATION: Revise to read: 15-$.4.2" Initiation. Initiation of the required fire alarm systems

shall be by manual means in accordance with 7-6.2 and by means of any required detection devices or detection systems.

Exception No. 1: Fire alarm pull stations in patient sleeping areas shall not be required at exits if located at all nurses' control stations or other continuously attended staff location, provided such pull stations are visible and continuously accessible and that travel distances required by 7-6.2.4 are not exceeded.

Exception No. 2: Fixed extinguishing systems protecting commerdal cooking equipment in kitchens that are protected by a complete automatic sprinkler system shall not be required to initiate the fire alarm system.

15-7.5.2 Newly introduced upholstered furniture within health care occupancies shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(b) and 6-6.$.

Exception: Upholstered furniture belonging to the patient in sleeping rooms of nursing homes, provided that a smoke detector Is installed m such rooms . . . . . . . ; r . . . . . . . . . . . ,, . . . . . . . . . . . . . . . , 4 ^ ~ ^ . t ^ - - . k - - I I k . . . . :*~^~

15-7.5.$ Newly introduced mattresses within health care occfipancies shall meet the criteria specified when tested in accordance with the methods cited in 6-6.2(c) and 6-6.4.

Exception: Mattresses belonging to the patient in sleeping rooms of nursing homes, provided that a smoke detector is installed in such rooms. ~ : t tc W p~w::c~ : '=g!: :~'-.~= ::-...c':: ~: tcz:~: : :h-2!

S L I ~ S ¥ ~ ¥ f A T I O N : Health care occupants have, in large part, varied degrees of physical disability, and their removal to the

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outside or even disturbance by moving is inexpedient or impractical in many cases. Similarly, recognizing that there may be an operating necessity for the restraint of the mentally ill, often by use of barred windows and locked doors. Fundamentally, early discovery and extinguishment of incipient fires, and prompt notification must be relied on to reduce the occasion for evacuation of buildings of this class to a minimum. Only a monitored, complete smoke detection system will assure the optimum safety of the unfortunate occupants. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The changes proposed introduce material that has not had public review. As such, they must be held forprocessing during the next revision cycle. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 557- (13-5.5.1): Reject SUBMITTER: Mayer D. Zimmerman, U.S. Dept. of Health and Human Services COMMENT ON PROPOSAL NO: 101485 RECOMMENDATION: The submitter recommends a retroactive sprinkler requirement for existing health care facilities. In its rejection, the Committee states in part, that the fire record in health care facilities has been good. It is interesting to note that there have been NO multiple death fires in fully Sl~rinklered health care facilities, every-since 1896. A valid argument m favor of the retroactive imposition of sprinklers for all health care facilities is that there is a retroactive sprinkler requirements in other occupancies, e.g., certain hotels and dormitories. SUBSTANTIATION: It's interesting to know that the Life Safety Code provides me with a greater level of protection as a hotel guest than as a hospital inpatient.

The committee also states that "health care occupancies have trained staff available." We cannot rely on the presence of staff at any time, in any place in a facility. Staff is often "unavailable" due to a myriad of reasons (telephone call, bathroom visit, needed on another unit, etc.).

A level of safety in a protection-in-place occupancy which does not l~ovide for automatic extinguishment is, in my opinion, an insultlcient level of protection for this occupancy.

In order to be reliable and accomplish their intended purpose with a great degree of certainty, fire protection features should be automatic rather than manual. An example of this philosophy presented in our chapter (and others), is the requirement for emergency forces notification by means which are "automatic, without delay" along with the prohibition of a pre-signal system as part of the fire alarm requirements. Emergency forces notification is mandated by required automatic operation, without human intervention, so should health care extinguishment. COMMITrEE ACTION: Reject. COMMITrEE STATEMENT: The submitter has not provided recommended text. The submitter's substantiation is inadequate to

justify requiring sprinklers. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ZIMMERMAN: I cannot agree with the Committee Action nor its

substantiation. The substantiation is that 1) I have not provided text. I apologize for that oversight. The text is clearly stated in Log #340, as follows:

"All health care facilities shall be protected throughout by an approved supervised automatic sprinkler system." 9) "The submitter's substantiation is inadequate to justify requiring sprinklers." I am sorry the Committee feels that way. I reiterate my previous statement: " l 'he level of safety in a protection-in-place occupancy which does not provide for automatic extinguishment is inadequate." We all know that there has never been a multi})le death fire in a fully sprinklered building of any occupancy smce the NFPA started keeping records in 1896. We took a big step forward by requiring mandatory sprinklers for new buildings in the 1991 edition of the Life Safety Code. If we are indeed serious about protecting the safety of patients and residents in ALL health care

facilities, we will require sprinklers throughout ALL health care facilities; new, existing, high rise, etc. The time has come...".


101- 358 - (13-3.5.1): Reject SUBMITrER= Peter W. Szerlag, Arlington, MA COMMENT ON PROPOSAL NO: 101-485 RECOMMENDATION: All health care facilities shall be protected throughout by an approved, supervised automatic sprinkler system. SUBSTANTIATION: This requirement does not requiregold plated sprinklers, nor gold plated piping, nor gold plated fire extingmshers. It just requires plain old firefighting sprinklers. How about just installing sprinklers comprised of half gallon pressurized water containers f i t tedwith rapid acting sprinkler heads that can fill a space with a water mist or a jelling fire retardant? COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has not justified the proposed change. Chapter 13 already requires that renovations be sprinklered, so sprinklers are being installed. This is adequate in wew of the good fire record in healthcare occupancies. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ZIMMERMAN: The text is clearly stated in this comment, as

follows: "All health care facilities shall be protected throughout by an

approved supervised automatic sprinkler system." I reiterate my previous statement in Comment 101-557 (Log #157)

the level of safety in a protection-in-place occupancy which does not provide for automatic extinguishment is inadequate." We all know that there has never been a multiple death fire in a fully sprinklered building of any occupancy since the NFPA started keeping records in 1896. We took a big step forward by requiring mandatory sprinklers for new buildings in the 1991 edition of the Life Safety Code. If we are indeed serious about protecting the safety of patients and residents in ALL health care facilities, we will require sprinklers throughout ALL health care facilities: new, existing, high rise, etc~ The time has come...".


101-359- (13-3.5.1 Exception (New), 13-3.5.2(b), 13-3.5.3(b)): Hold SUBMITTER: Thomas W. Jaeger /Thomas W. Gardner, American Health Care Assn. (AHCA) COMMENT ON PROPOSAL NO: 101-299 RECOMMENDATION: Add a new Exception to read:

Exception No. 2: In existing buildings, only the main sprinkler control valve shall be required to be electrically supervised.

Appendix A-13-5.1 Exception No. 2 Other sprinkler components are required to be supervised by the appropriate installation standards. For example, NFPA 13 permits chains and locks for supervising control valves; NFPA 20 permits the locking of the door to a pump room, etc.

Delete part (b) from paragraphs 13-$.5.2 and 15-$.5.5. SUBSTANTIATION: Proposal 101-299 was originally submitted to the Technical Committee on Building Service and Hre Protection Equipment. Based on the Committee Statement for rejection, it .~pePears to be more appropriate to submit the comment to the

chnical Committee for Heal th Care Occupancies. For many years and edition of the Life Safety Code, the Code only

required electrical supervision of the main sprinkler control valve and allowed supervision of other sprinkler control valves and other components of the suppression system as permitted in the applicable installation standard. For example, by chains and padlocks, lock on pump room doors, etc.

This exception only applies to existing systems. There are thousands of systems in existing buildings which are safely and adequately supervised but not electrically supervised.

The American Health Care Association recently conducted a study which showed that many existing nursing homes complying with the previous editions of the LSC would not comply with the complete electronic supervision requirement. The study further

194


showed that to retroactively provide such supervision in existing nursing homes would cost $7,900,000.

The cost impact of retroactive requirements such as complete electronic supervision have, in thepast , been used a part of the substantiation as to why Medicare/Medicaid Regulauons should not adopt more recent editions of the Life Safety Code for existing health care facilities.

Obviously, existing facilities with other physical means of system supervision have been safely operating for many years without any negative impact on the level of safety provided for the building occupants. From an operational standpoint, the staffed nature of nursing facilities combined with the limited access by the public, results in an extremely small chance that unauthorized persons would have access to such :sprinkler system components. Therefore, physical supervlsmn has been successful. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: Although the subject was raised during the ROP and handled by the SAF-BSF Committee, it is new to the SAF-HEA Committee. The regulations governing committee projects permit comments to be held if the subject cannot receive adequate attention during the time allowed for ROGpreparation. Thus, the comment will be held for processing during the next revision cycle. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- $60 - (13-$.5.2): Reject SUBMITI'ER: Mayer D. Zimmerman, U.S. Dept. of Health and Human Services COMMENT ON PROPOSAL NO: 101-486 RECOMMENDATION: The submitter recommends a high-rise sprinkler requirements for exist health care facilities. In its rejection, the Committee states in part, that building construction requirements and smoke barriers are required for compartmention. It is interesting to note that there have been NO multiple death fires in fully sprinklered health care facilities, ever- since 1896. Compartmentation may provide confinement of smoke and fire, but it does not provide extinguishment of the fire.

A valid argument in favor of the retroactive imposition of sprinklers for high-rise health care facilities is that there is a retroactive sprinkler requirements in other occupancies, such as hotels and dormitories. SUBSTANTIATION: It's interesting to know that the Life Safety Code provides me with a greater level of protection as a hotel guest than as a hospital inpatient.

The committee also states that "health care occupancies have trained staff available." We cannot rely on the presence of staff at any time, in any place in a facility. Staff is often "unavailable ~ due to a myriad of reasons (telephone call, bathroom visit, needed on another unit, e ta) .

In order to be reliable and accomplish their intended purpose with a great degree of certainty, fire protection features should be automatic rather than manual. An example of this philosophy presented in our chapter (and others), is the requirement t o r . emergency forces notification by means which are "automatic, without delay" along with the prohibition of a pre-signal system as part of the fire fire alarm requirements. Existing high rise hotels rely on required automatic extinguishment, should health care. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See the Committee Statement for the rejection of Proposal 101-486. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16 NEGATIVE: 1 NOT RETURNED: 1 Crowiey

EXPLANATION OF NEGATIVE: ZIMMERMAN: The text is clearly stated in Comment 101-358

(Log #$40), as follows: "All health care facilities shall be protected throughout by an

approved supervised automatic spnnkler system. ~ "I reiterate my statement in Comment 101-357 (Log #137). The

level of safety in a protection-in-place occupancy which does not provide for automatic extinguishment is inadequate. We all know that there has never been a multiple death f i re in a fully sprinklered building of any occupancy since the NFPA started keeping records

in 1896. We took a big step forward by re qluiring mandatory sprinklers for new buildings in the 1991 edition of the Life Safety Code. If we are indeed serious about protecting the safety of patients and residents in ALL health care facilities, we will require sprinklers throughout ALL health care facilities: new, existing, high rise, etc. The time has come... ~.


I01- 361 - (13-3.5.2 and Exception): Reject SUBMrI 'rER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-487 RECOMMENDATION: The committee should reconsider Proposal 101-487.

13-$.5.2 All high-rise health care facilities shall be protected throughout by an approved supervised, automatic sprinkler system installed in accordance with Section 7-7, adoption of ttli5 Code edition.

Acid Exception per original proposal. SUBSTANTIATION: The committee's statement to Proposal 101- 487 exactly supports the exception originally submitted. If the building and staff situation meet the committee's statement, then the sprinkler retrofit would not be required. But, if an engineering analysis does not bear out - building by building - that these other health care features are equivalent to sprinkler protection then the sprinkler retrofit is justified.

I again submit to the committee that there are relatively few high- rise health care buildings that are not already sprinkler protected. Therefore the impact would be small on the health care community overall. The seven year time frame would give ample time to comply. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: See the Committee Statement for the rejection of Proposal 101-486. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITYEE ACTION:



101- $62- (13-3.6.$.2): Hold SUBMITTER: James I~ Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-491 RECOMMENDATION: Revise 13-$.6.$.2 as follows:

13-$.6.$.2" Doors shall be provided with means suitable for keeping the door closed that is acceptable to the authority having junsdlcuon . . . . . . . . . . . . . . . . . . . . . . ~ , . . . . . . . . . t . . ~ . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . . . [ . . . . . . . . . . . . . . . . . . . . . . . . . . . .

0 1 o . - - . . . . . . . . . . . . . . . . . . . . . .

~:ceFS:= No. I: Existing roller latches demonstrated to keep the door closed against a force of 5 lbf (22 N) applied at the latch edge of the door shall be permitted to be kept in service if . . . . . . . r ~.1^ .^

Exception gloW: Coors to toilet rooms, bathrooms, shower rooms, sink closets, and similar auxiliary spaces that do not contain flammable or combustible materials. SUBSTANTIATION: Although I disagree with the deletion of authority having jurisdiction approval in the former exception, I recognize the political necessity. The authority having jurisdiction was referenced in the exception because many states had prohibited roller latches before NFPA 101 did. However, this has been in the Code approximately 10 years and any authority having jurisdiction that didn ' t want the lathes should have had them removed by now. This comment rewrites the whole provision because the simple deletion of authority havin[g jurisdiction approval in the exception results in a very contusing provision. As rewritten the Code is dearer and accepts the AHCA proposal. COMMITI"EE ACTION: Hold. COMMYITEE STATEMENT: The submitter has made a change that is more than editorial. The revision would apply the 5 lb. force only to roller latches. No other devices will need to meet the 5 lb. force requirement. This introduces new material that has not had public review. As such, it must be held for processing during the next revision cycle. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18

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VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 17 NOT RETURNED: 1 Crowley


101- 365 - (15-5.6.$.2 Exception No. 1): Reject SUBM1TTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101491 RECOMMENDATION: Retain the exisdng wording to Exception No. 1:

"...if acceutable to the authority havin~r Jurisdiction..." SUBSTANTIATION: The deletion oft.hese words only adds confusion to the effective application and enforcement of the Code. Paragraph 1-$.$ of the Life Safety Code currendy permits the authority having jurisdiction to determine the adequacy of means of egress and other measures for life safety from fire. By deleting this existing wording in the occupancy chapter, users o f the Code may be unaware of these provisions written in Chapter 1, or be gt~iven an incorrect impression that these provisions do not appl~" in

is case. Since there has been no Exception to 1-3.$, these acuons mean no change to the provisions of Exception No. 1 to 15-3.6.5.2 other than making them more difficult to locate.

It should also be understood that this provision does not mandate the replacement of all roller latches as the substantiation suggests, however, it allows the authority to determine the adequacy of existing levels of protection and to apply appropriate alternate provisions in order to maintain safety. The authority having jurisdiction always retains the right to determine the adequacy of life safe ty . . COMMrFrEE ACTION: Reject. COMMITrEE STATEMENT: See the substantiation in Proposal 101491. The submitter has not provided justification to treat roller latches differently with respect to the requirement for special authority having jurisdiction permission. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BUSH: This action should be tied into the hold action for

Comment 101-$62 (Log #328). While the Committee Statement states that the submitter has not provided justification to treat roller latches differendy with respect to the requirement for special authority having jurisdiction permission, part of Mr. Lathrop's substantiation for Comment i01-362 (Log #$28) does indeed indicate that there is justification, albeit historical, to this difference in consideration. In addition, the deletion of this phrase creates confusion to Paragraph 1-$.$ which permits the authority having jurisdiction to determine the adequacy of all provisions of the Code.

ZIMMERMAN: I agree with Mr. Bush. There is no reason to remove the phrase subject to the approval of the authority having jurisdiction. The authority having jurisdiction retains the fight to determine what is adequate under Section 1-$.$ of the Life Safety Code. This provision allows the surveyor looking at a particular door the leeway to determine on a case-by-case basis whether adequate safety is provided.


101- $64- (13-$.8.1): Reject SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101492 RECOMMENDATION: Retain the existing second sentence, and Exception Nos. 1 and No. 4 of 15-3.8.1. SUBSTANTIATION: This sill height of exterior openings in unsprinklered patient rooms has been, and remains, an extremely important factor in the overall safety of building occupants. Without the provision for sill heights, window openings of any size and location could be utilized to satisfy this requirement. Such openings which are small in size or otherwise inaccessible due to sill heights which are high above the floor are useless for life safety reasons. The substantiation for this proposal speaks only to nursing homes, and not to all health care facilities that are impacted by this requirement. The substantiation is incorrect in

that new hospitals and nursing homes built in compliance with the 1973 edition of the Life Safety Code were required to have outside windows or doors in institutional sleeping rooms with a sill height not exceeding 36 in. above the floor. In addition, provision for such outside openings in all other earlier editions of the Code, including those in existing buildings, required that they be arranged and located to permit the venting of products of combustion and to permit any occupant to have access to fresh air in case of emergency. Certainly, inaccessible openings could not have complied with these requirements.

If existing non-complying windows are already in use having been designed and accepted under these previous Code requirements, their continued use, or other acceptable alternate provisions, would not require expensive building renovation. To eliminate this life saving tool, which has proven effective to the safety of buildin!g occupants and to responding emergency personnel, simply in the interests of economics is a mistake. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has not provided adequate substantiation to regulate windowsill height for fire safety reasons. The cosdy retrofit and renovation that this requirement causes is not substantiated. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMrITEE ACTION:


EXPLANATION OF NEGATIVE: BUSH: The intent of this comment was not to necessarily re.cjuire

that existing acceptable window sill heights be universally modified, but rather to retain a standard for which sill heights should be maintained. Where a reasonable degree of safety is provided, and the modification of that condition would be impractical in the opinion of the authority having jurisdiction, Paragraph 1-$.4 of the Code would permit the existing condition to continue. However, by elimination of this wording as proposed, it would appear that replacement windows installed in existing health care facilities could be installed at any sill height. Window replacement in existing openings should not prove to be the financial burden as the substantiation for this proposal suggests.

Rather than delete all of the wording as proposed, the committee should consider an exception for existing approved window installations, which would seem to satisfy the original submitter's intent. The proposal for the deletion of all references to sill heights, which eliminates a proven life saving tool as noted in the writer's original comment substantiation, is not justified by the committee statement.


101- $65 ~ (15-4.2): Reject SUBMITI'ER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-495 RECOMMENDATION: Accept proposal 101493. SUBSTANTIATION: As unsprinklered high-rise buildings around the world continue to b u m down, more and more communities are realizing that these buildings represent special fire problems and are forcing the retrofit of sprinkler systems. No combination of construction, staff and fire fighters can save the occupants and the building. It took large loss fires in Type 1 Fire Resistive construction buildings in Philadelphia, Los Angeles, New York, Boston, and Baltimore to get legislation moving.

Do we think that a hospital is special because of the staff?. Are the staffing levels remaining high enough to evacuate a high-rise hospital in time? COMMITFEE ACTION: Reject. COMMITrEE STATEMENT: See the Committee Statement for the rejection of Proposal 101-486. Also see Comment 101-$60 (Log #154). The submitter's substantiation does not address healthcare occupancies. NUMBER OF COMMrlTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITIT~E ACTION:


EXPLANATION OF NEGATIVE: ZIMMERMAN: I cannot accept the argument that protection to

patients in existing high rise health care facilities is provided by construction or by staffing level. The fact remains that our colleagues on the Residential Committee require sprinklers for

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existing high rise hotels. Do we intend that guests in hotels be provided with more safety than patients in hospitals and nursing homes? I would hope that the level of safety provided in each occupancy is equivalent.


101- 366 - (15-6.3.7.2 Exception No. 2): Reject SUBMITIT.R: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-498 RECOMMENDATION: Eliminate the new Exception No. 2. SUBSTANTIATION: There is no technical justification included within the Committee Statement to make this new Exception for the construction of smoke barriers in facilities of a particular size. The purpose of the smoke barrier is to permit the relocation of patients within the health care occupancy, and not to require them to be relocated out of the facility as the statement suggests.

In addition, sprinkler protection in older office buildings is not commonplace, and facilities in buildings housing other occupancy etY~eeS without sprinkler protection may he subject to exposure

cts, especially smoke, from fires in adjoining spaces which, although separated by fire rated construction, may not be protected by automatic sprinklers or have the occupancy separation constructed as a smoke barrier.

While sprinklers will serve to reduce the effects of a fire and permit longer periods of time which may be available for patient evacuation, they do not adequately provide a smoke-controlled environment to which patients may be relocated during a fire emergency within the building. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee Action on Proposal 101-498 is justified. NUMBER OF COMMrlTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BUSH: The Committee has offered no new justification for this

new exception for the construction of smoke barriers in facilities of a particular size. The separation of facilities to limit the spread of smoke and to provide for smoke compartments serving as areas of refuge for patients within acceptable travel distances and of acceptable sizes has no apparent correlation to the installation of automatic sprinkler protection as stated in the writer's substantiation for the original comment.


101- 367 - (Table 14-3.2.1): Reject SUBMITrER: William E. KoffelJr., Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-500 RECOMMENDATION: Replace "smoke resistant" with "smoke partitions" in five locations in the table, SUBSTANTIATION: Chapter 6 will now contain a section defining a construction assembly referred to as a smoke partition. Since this table is being revised and affects new construction, the newly defined assembly should be used. It is recognized that other locations in the chapter also use the term smoke resistant but they have not been proposed for change (e.g., Table 14-3.8.1). COMMITTEE ACTION: Reject. COMMI]q'EE STATEMENT: Per Proposal 101-518, a new Note 5 is being added to Table 14-3.8.1 to clarify that the use of the term "Smoke Resistant (SR)" does not invoke the provisions of new 6-2.4 on smoke partitions. The SAF-DET committee purposely chose not to reference new 6-2.4. It would be premature to reverse this action at the ROC-preparation stage. Such change will require careful correlative action to explain which notes to Table 14-3.8.1 are meant to override the provisions of 6-2.4 (e.g., can the self- closing device required by 6-2.4 be omitted; how does one deal with passthroughs given that 6-2.4 requires the equivalent of a door meeting the clearance requirements of NFPA 80). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 20 VOTE ON COMMITTEE ACTION:



101- 368 - (14-3.3.2): Reject SUBMITTER: Harold E. Nelson, Hughes Assoc., Inc. COMMENT ON PROPOSAL NO: 101-500 RECOMMENDATION: In paragraph 14-3.3.2 delete the proposed new final sentence" ~I'he provisions of 6-5.9.1 shall not apply'. SUBSTANTIATION: The application of water from a sprinkler system is more effective in preventing fire propagation and reducing heat release from a surface than lowering the flame spread rating. This allowance should not be removed. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: See ROP page 226 which contains the substantiation for Proposal 101-500. In item 8, the committee explains that 14-3.3.2 has already beeen revised to include an allowance for Class B interior wall and ceiling finish materials based on the presence of the automatic sprinklers required for new detention occupancies. Thus, the provisions of 6-5.9.1 have already been built into the requirement and a duplicative use needs to be prohibited. As explained in note 8 of the ROP this correctly keeps the user from "double dipping" and mistakenly using Class C material. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 20 VOTE ON COMMITTEE ACTION:



101- 369 - (14-3.3.3): Reject SUBMITTER: Harold E. Nelson, Hughes Assoc., Inc. COMMENT ON PROPOSAL NO: 101-500 RECOMMENDATION: In ~ p h 14-3.3.3 delete the proposed new final sentence: "The provmons of 6-5.9.2 shall not apply ~. SUBSTANTIATION: The application of water from a sprinkler system is more effective in preventing fire propagation and reducing heat release from a floor finish than lowering the floor finish class. This allowance should not be removed. COMMITTEE ACTION: Reject. COMMITI'EE STATEMENT: See ROP page 226 which contains the substantiation for Proposal 101-500. In i tem 8, the committee explains that 14-3.3.3 has already beeen revised to include an allowance for Class II interior floor finish materials based on the presence of the automatic sprinklers required for new detention occupancies. Thus, the provisions of 6-5.9.1 have akeady been built into the requirement and a duplicative use needs to be prohibited. As explained in note 8 of the ROP this correctly keeps the user from "double dipping" and mistakenly exempting the floor material from any regulation. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTF; 20 VOTE ON COMMITIT~ ACTION:



101- 370 - (14-7.4.3): Hold SUBMITrER: Marcelo M. Hirschler, GBH lnt'l, Inc. COMMENT ON PROPOSAL NO: 101-520 RECOMMENDATION: Revise text:

14-7.4.3 Newly introduced mattresses within detention and correctional occupancies shall be tested in accordance with the provisions of 6-6.2(b) and 6-6~0 when tested bY the roll-un test described in this code. the mattress weight loss durin~ the test shall not exceed 15 oercent of the initial mat~'ess weight.

Test Procedure. A. Weigh ~ double sheets of black vr int newspaper (no tabloid

size~ and record the weittht, to an accuracy of no less than 1.0 ~. Weight the conditioned mattress, or mattress insert, and record the weight, to an accuracy of no less than 50 ~. Test within $0 rain of weighting t l~ mattress.

B. Use a pipe anproximatelv 0.6-1.0 m (24-$8 in.I long and 230- 250 mm fg.10 inA in internal diameter, for rollin~ the mattress. Retain the mattress in olace bv usinfr steel noultrv-nettin~ or a minimum of three steel wire flea anti creating" a =chinme~, effect". Remove the pipe after the mattress rol | has I~en sec;~ll'ecl, position

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the mat t ress roll such tha t it is both: (11 secure fTom fall ing a n d (2) til ted to one side at an angle o f 75-80 ° to the floor. This is achievable: la~ by n r o n o i n g u n the mat t ress roll on one side. with two 70-80 m m (3 in.) steel angle i rons or two bricks, with 70-100 m m seDaration between them. a n d secur ing the mat t ress roll f r om tinDind over d u r i n g test ing by a t t ach ing $ wires to the steel net t ing. with t he wires s u s n e n d e d f rom u n h i g h (for examn l e f rom the ceiling) or (b) bv l ean ing the mat t ress agains t a n o n combust ib le ,uono-rt a t the r eou i red angle. T h e ang led confitruration is n e e d e d goal low air to en te r a t the b o t t o m of tl~e ch imney f o r m e d by t he mat t ress roll. C rum nl e un the sheets o f newsnaner , loosely, into individual balls anDroximatelv 150 m m (6 inA- in d iamete r a n d place t h e m in the inside of tile chimney.

~, Itmite t he c r u m o l e d newsoaoer , f rom the ton. with a single m a t c h , ensu r ing tha t - the newsoat~er is well lit. Allow free b u r n i n g 9f the ma t t r e s s ro l l unti l t h e first" of the following condi t ions is - reached: (a) all b u r n i n g has ceased or (b) f lashover in the test 1.onto anoears inevitable. In this case. extinmaish the mat t ress fire lil~rlu~llly and r eno r t the resul t as a flashover. Weigh t ing of the mat t ress r emains is no t necessarv in this case. After visi-ble f lames h~v¢ ceased, let the mat t ress cool to r o o m t emne ra t u r e a n d check to ensure tha t t he re is no visible smoke a n d tha t the mat t ress is no t smolder ing . This t h e n concludes the test.

D. U n o n c o m n l e d o n of the test. weigh the mat t ress remains , if any. after o lac ing t h e m in a ore-weighed n o n combust ib le ~0ntainer.

E. Conduc t the test in dunlicate. C onduc t each burn on an un tes t ed spec imen.

Exception: Mattresses in r ooms or snaces fully vro tec ted bv an annroved au tomat ic spr inkler system. S U B S T A N T I A T I O N : In has been shown tha t ASTM E1590 and NFPA 267 (which is the r e q u i r e m e n t r equ i red in Sect ion 6-6.4) are inadequa te for the assessment of the fire pe r fo rmance o f mat t resses i n t e n d e d for de t en t ion or correct ional occupancies . T h e inadequacy is of two kinds: (a) the igni t ion source is o f insuff icient severity to offer e n o u g h protec t ion for a de ten t ion cell env i ronmen t because mat t resses can "pass" the test s imply by virtue of no t igniting. In such cases, however, it is possible for the mat t ress to resul t in a severe fire if it actually ignites, a n d (b) the mat t ress is tested in a n unreal is t ic m a n n e r because m e l t i n g and dr ipp ing t h r o u g h the mat t ress suppor t is permit ted . It shou ld be no t ed tha t typical mat t resses used in a de ten t ion e n v i r o n m e n t exhibi t fire pe r fo rmance far super ior to those in the r equ i rements of NFPA 101 (i.e., peak rate o f hea t < 250 kW a n d total hea t release < 40 MJ in the first 5 rain of test). Moreover, this test m e t h o d does n o t address physical changes to protective layers due to wear, tear or abuse, which potential ly affect t he resulUng fire-test-response characteristics of the uphols te ry i tem. Unfor tunately , the NFPA Commi t t ee on Fire Tests will no t approve a fire test for detect ion mat t resses in t ime for use by NFPA 101 in its nex t edition. A fire hazard assessment shows that some of the mat t resses tha t have recently b e e n in t roduced into de ten t ion envi ronments , by mee t ing a m a x i m u m hea t release rate o f 250 kW a n d a total hea t released o f 40 MJ, in ASTM E1590, are likely to be unsafe. Moreover this limit, f rom Section 6-6.4, is significantly h ighe r t han the l imit r equ i red by California Technica l Bullet in CA TB129, which is a m a x i m u m hea t release rate of 10 kW and a total hea t release no t exceeding 25 MJ in the first 10 rain o f test- Mattresses have recent ly been in t roduced into de ten t ion env i ronmen t s which barely m e e t the 250 kW requ i r emen t s a n d can resul t in f lashover in a typical de t en t ion cell scenario.

The best known test p rocedure des igned specifically for de ten t ion matt ress inserts, or mattresses, is the so-called Michigan "Roll-up" Test, which is r e c o m m e n d e d for use in the applicat ion, a n d is inc luded in the text of the commen t . This is n o t new material , as the test m e t h o d ha d already been r e c o m m e n d e d in the proposal. T h e Michigan "Roll-up" test can be conduc t ed on comple te mat t resses as well as on mat t ress cush ion ings or paddings . However, the mos t f r equen t way in which the test has been conduc ted has b e e n wi thout the cover, for easier evaluation of de ten t ion mat t ress cushionings .

Note: Suppor t ing material is available for review at NFPA Headqua r t e r s . COMMITTEE ACTION: Hold. C O M M I T T E E STATEMENT: A l t hough the subject of mat t ress test ing was raised in the ROP, it was done by p ropos ing the use o f an NFPA test s t anda rd tha t itself would have been r e q m r e d t o g o t h r o u g h t he full NFPA consensus -making s t andards process. This has n o t occur red as the NFPA Fire Tests Commi t t ee has the

subject on hold. T h e fire test m e t h o d p roposed by this c o m m e n t has no t had publ ic review within the N'FPA s tandards arena. As such , the subject m u s t be he ld for the n e x t re~ision cycle. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 20 V O T E ON C O M M I T T E E ACTION:

AFFIRMATIVE: 19 N O T RETURNED: 1 Barbaro

C (Log #275) ommi t tee : SAF-DET

101- 371 - (15-7.4.3): Ho ld SUBM1TI'ER: Marcelo M. Hirschler , GBH Int ' l , Inc. C O M M E N T ON PROPOSAL NO: 101-529 RECOMMF2qDATION: Revise text:

15-7.4.B Newly in t roduced mat t resses within de ten t ion a n d correct ional occupancies shall be tested in accordance with the provisions of 6-6.2(b) a n d 6-&4-, when tes ted by the roll-up test descr ibed in this code. the mat t ress weight loss d u r i n g the test shall no t exceed 15 n e r c e n t of the initial mat t ress we igh t -

Tes t Procedure . A. Weigh 8 double sheets of black o r in t newsnaner (no tabloid

size) a n d r e c o r d the weight, to an accuracy o f no iess t h an 1.0 g. Weight the condi t ioned mat t ress , or mat t ress insert , a n d r eco rd the weight, to a n accuracy of no less t h a n 50 g. Tes t within B0 rain of weight ing the mattress.

I~, Use a n ine annrox imate iv 0.6-1.0 m (24-38 inA long a n d 230- 250 m m (9--16 in . i in in ternal d iameter , for rol l ing the mattress. Retain the mat t ress in nlace bv us ing steel poul t ry ne t t ing or a m i n i m u m of th ree steel wire des ancl c r ead r~ a "ch imney effect". Remove the n ine after t he mat t ress roll has l~een secured. Posit ion the mat t ress roll such that it is both: (1) secure f ro m falling a n d (~) tilted to one side at a n angle of 75-80 ° to the floor. Th~ts is achievable: (a) bv o ronn in~ u n t h e mat t ress roll on one side. with 0v9 70-80 m m (3 in.) steel angle irons or two bricks, with 70-100 m m separa t ion between t h e m . a n d secur ing the mat t ress roll f rom dDoing over du r ing tes t ing bv a t taching 3 wires to the steel nett ing. with the wires s u s n e n d e d f rom u n h igh (for examole f rom the ceiling) 91" (b) b v l e a n i n ~ the mat t ress a_oainst a n o n combust ib le ~qpp0rt at the reoui red angle. T h e ang led conf igura t ion is n e e d e d to allow air to e n ~ r at the bo t t om of the ch imney f o r m e d bv the mat t ress roll. C rumole uD the sheets of newsnaner . Iooselv~ into itlqlividual balls annrox imate lv 150 m m (6 in.~- in d iamete r a n d ulace t h e m in t he inside o f the chimney.

G, Ignite ~h¢ grompled newspaper, f rom the too. with a single match , ensu r ing tha t the newsnaner is well lit. Ailow free b u r n i n g 9f the mattress-roll unt i l t he first of the following condi t ions is 1.¢;~¢hed: (a) all b u r n i n g has ceased or (hi f lashover in the test room annears inevitable. In this case. ext intmish the mat t ress fire Inanually a n d repor t the resul t as a flashover_ Weight ing of t h e mat t ress r emains is no t necessarv in this case. After visible f lames have ceased, let the mat t ress cool to r o o m t e m n e r a m r e an d check ~o ensu re ~ a t there is no visible smoke a n d tha t the mat t ress is n o t smolder ing . This t h e n concludes the test.

D. U o o n comole t ion of the test. weighlXhe mat t ress remains , if any. after n lac ing t h e m in a n re -weigh~l n o n combust ib le ~n~ne r .

E. Conduc t the test in dunlicate. Conduc t each b u rn on an un tes t ed snec imen.

l~]tnqption: Mattresses in r ooms or snaces_ fully n ro tec ted by an anoroved automat ic snr inkler system. S ' IJBSTANTIATION: In has been shown tha t ASTM E1590 and NFPA 267 (which is the r e q u i r e m e n t r equ i r ed in Section 6-6.4) are inadequa te for the assessment o f the fire pe r fo rmance of mattresses i n t ended for de t en t ion or correct ional occupancies . Th e inadequacy is o f two kinds: (a) the igni t ion source is o f insuff icient severity to offer e n o u g h pro tec t ion for a de ten t ion cell env i ronmen t because mat t resses can "pass ~ t he test s imply by virtue o f n o t igniting. In such cases, however, it is possible for the mat t ress to resul t in a severe fire if it actually ignites, a n d (b) the mattress is tested-in an unrealist ic m a n n e r because me l t ing an d dr ipp ing t h r o u g h the mat t ress suppor t is permit ted . It shou ld be no ted that typical mat t resses u sed in a de ten t ion e n v i r o n m e n t exhibi t fire pe r fo rmance far super ior to those in the r equ i r emen t s o f NFPA 101 (i.e., peak rate of hea t _< 250 kW a n d total h e a t release < 40 MJ in the first 5 rain of test). Moreover, this test m e t h o d does n o t address physical changes to protective layers due to wear, tear or

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abuse, which potentially affect the resulting fire-test-response characteristics of the upholstery item. Unfortunately, the NFPA Committee on Fire Tests will not approve a fire test for detection mattresses in time for use by NFPA 101 in its next edition. A fire hazard assessment shows that some of the mattresses that have recently been introduced into detention environments, by meeting a maximum heat release rate of 250 kW and a total heat released of 40 MJ, in ASTM E1590, are likely to be unsafe. Moreover this limit, from Section 6-6.4, is significandy higher than the limit required by California Technical Bulletin CA TB129, which is a maximum heat release rate of 10 kW and a total heat release not exceeding 25 MJ in the first 10 min of test. Mattresses have recently been introduced into detention environments which barely meet the 250 kW requirements and can result in flashover in a typical detention cell scenario.

The best known test procedure designed specifically for detention mattress inserts, or mattresses, is the sow.ailed Michigan "Roll-up" Test, which is recommended for use in the application, and is included in the text of the comment. This is not new material, as the test method had already been recommended in the proposal. The Michigan "Roll-up" test can be conducted on complete mattresses as well as on mattress cnshionings or paddings. However, the most frequent way in which the test has been conducted has been without the cover, for easier evaluation of detention mattress cushionings.

Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE ACTION: Hold. COMMITrEE STATEMENT: Although the subject of mattress testing was raised in the ROP, it was done by proposing the use of an NFPA test standard that itself would have been required to go through the full NFPA consensus-making standards process. This has not occurred as the NFPA Fire Tests Committee has the subject on hold. The fire test method proposed by this comment has not had public review within the NFPA standards arena. As such, the subject must be held for the next revision cycle. NUMBER OF COMMrVrEE MEMBERS ELIGIBLE TO VOTE: 20 VOTE ON COMMITTEE ACTION:



101- $72 - (16-1.3 Hotels and 17-1.3 Hotels): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-535 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES reconsider its action, give consideration to Mr. Baldassarra's explanation of negative, adhere to the guidelines used by the glossary task group, and move explanatory material out of the definitions and into the .appendix. A definition is not to have an "include list" attached to I t . SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Move the last sentence of the definition to Appendix A for this definition to read as follows:

Hotels. So-called anartment hotels shall be classified as hotels because they are notentiallv subject to the same transient occunancv as hotels.

Retain the first sentence of the definition. COMMITTEE STATEMENT: The term "with or without meals" must stay in the definition to clarify that hotel rooms might have cooking facilities. The presence of cooking facilities does not automatically make the occupancy an apartment.

The list must stay because the result of moving it to the Appendix is a loss in enforceability. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 21 NEGATIVE: 1 NOT RETURNED: 2 Kelly, Oneisom

EXPLANATION OF NEGATIVE: BALDASSARRA: As per my previous negative vote, the committee

should amend the definition so as to include explanatory material and "lists" of examples into the appendix, in order to be consistent with proper formatting of definitions. COMMENT ON AFFIRMATIVE:

LATHROP: The committee made progress but should have gone further moving material to the appendix.


101- $75- (16-1.$ Hotels and 17-1.$ Hotels): TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed to reflect Mr. Baldassarra's Explanation of Negative by:

1. deleting from the definition of Hotels in 16-1.$ and 17-1.$ the words "whether designated as a hotel, inn, club, motel, bed and breakfast, or by any other name."

2. Creating a new 16-1.1.2 and 17-1.1.2 (and splitting current 16- 1.1/17.1.1 into 16-1.1/17.1.1 Application and 16-1.1.1/17.1.1.1 verbiage) to read:

"16-1.1.2/17-1.1.2 The term hotel, wherever used in this Code, shall include a hotel, inn, club, motel, bed and breakfast, or any other term meeting the definition of hotel. ~

This action removes explanatory information from.the definition in accordance with the NFPA style manual. The format of 16-1.1.2/17-1.1.2 is consistent with that used by SAF-HEA in revising the definitions of Hospital and Nursing Home via Comment 101-$25 (Log #54) and Comment 101-$24 (Log #55). SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-536 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES reconsider its action, adhere to the guidelines used by the glossary task [group, and move explanatory material out of the definitions and into the appendix as requested in Proposal 101-535. A definition is not to have an "include lisC attached to it. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Principle.

No change in action on Committee Proposal 101-536. , COMMITTEE STATEMENT: "Bed and Breakfast" facilities must be added because they are dearly hotels when they can accomodate more than 16 guests.

This assists the enforcer in determining the occupancy classification when a bed and breakfast is this size. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BALDASSARRA: The committee statement says "Accept in

Principle," but also indicates ~no change in action ~ on this proposal. All explanatory material should be included in

endix, not in definitions. ENT ON AFFIRMATIVE:

LATHROP: The committee made progress but should have gone further moving material to the appendix.


101- 374- (16-3.5.2 Exception): Reject SUBMITI'ER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-547 RECOMMENDATION: Retain, but revise the wording of the Exception to this paragraph as follows:

Exception: Buildings other than high rise, where all guest sleeping rooms have a door that opens directly to the outside at street or at ground level ~.r t~ ::==e-~.- er='t ~.~..~ ~r=~g=~ ".~ acc~rd=~ce : - -~ ~ 5.~. SUBSTANTIATION: The purpose of the revised exception is to require automatic sprinkler protection in non-high rise buildings that have guest room egress to exterior access balconies above grade. Several recent fires have indicated that exterior vertical fire spread in unsprinklered buildings poses a significant hazard to the life safety of the building occupants and their associated egress path. Such exterior fire spread would directly expose the exit access needed for egress even in buildings that are less than 75 ft in height, and warrants the installation of automatic sprinkler protection for new construction. The reference to buildings other than high rise has been retained in order to address the arrangement of a building with multiple levels which may all have at grade access due to building construction and surrounding topographic conditions. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: As stated in the Committee Statement on Proposal 101-547, the fire death record in hotels has decreased indicatang that the current provisions are effective.

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The submitter of the comment has not provided any new information tojnstify even this modificauon to the proposal. NUMBER OF COMMITTEE MEMBERS EUGIBLETOVOTE: 24 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: ISMAN: The National Fire Sprinkler Association agrees with Mr.

Bush that people in these large nonsprinklered hotels are at risk. Without minimum construction requirements, the possibility exists that people will die in their room after being trapped by a fire starting below them.

LATHROP: Mr. Bush is correct. Since there are no minimum construction types specified, there is a significant possibility that a person could be trapped in their room in a multi-story situation. COMMENT ON AFFIRMATIVE:

BALDASSARRA: Mr. Lathrop's comment is not persuasive. To think multi-story buildings are constructed without reasonable construction types is not realistic. One cannot ignore the reality of building code requirements that will also apply.


101- 375 - (16-$.5.5 and 17-3.5.$): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-551 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES revise the proposed wording to clarify intent. The table is not all inclusive; reference to the base paragra~ph wording of 16-3.2.2/17-3.2.2 is needed. The phrase ~as described within Table 16-3.2.2" could be reworded to read "addressed in 16-$.2.2f SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise 16-$.5.5 as follows: "Portable fire extinguishers in accordance with %7.4 shall be

provided in hazardous areas addressed in 16-$.2.2." Exception remains the same as proposed. Revise 17-3.5.$ as follows: "Portable fire extinguishers in accordance with 7-7.4 shall be

nrovided in hazardous areas addressed in 17-$.2.2." - Exception remains the same as proposed. COMMITTEE STATEMENT: Editorial change. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITrEE ACTION:



101- 376 - (18-1.1, 19-1.1, and 16-1.$, 1%1.$): Reject SUBMITrER: Southern Regional Fire Code Den. Committee COMMENT ON PROPOSAL NO: 101-565 RECOMMENDATION: Reconsider the Committee Action and accept the proposal. SUBSTANTIATION: Time shares are a great concern in many areas of the country. The Code currendy ~.ve guidance on classification of many occupandes, to darffy time shares would assist the user in providing the correct protection for these occupancies. Time shares by definition of hotel "...sleeping accommodations for more than lfi persons primarily used by transients (those who occupy accommodations for less than $0 days)...". By adding the proposed word in the proposal you are clarifying that time shares are hotels due to the transient nature. This would also clarify the classification until 2003 when the committee will look at the consolidation of these chapters. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee stands on the Committee Statement on Proposal 101-565.

Furthermore the determination of occupancy in these cases must be taken on a case-by-case basis taking into account such things as

1. Is it new or existing. 2. Is the occupancy operating more like a hotel or apartments. 3. It is possible to consider these mixed occupancies under the

provisions in Chapter 4 and apply the most restrictive requirements.



(Log #CCA51 ) Committee: SAF-RE, S

101- $77 - (18-S.1.1 Exception No. 4): Accept SUBMrrrERx Technical Committee on Residential Occupancies COMMENT ON PROPOSAL NO: 101-570 RECOMMENDATION: Delete exception and a a new secdon as follows:

18-3.1.2 There shall be no unenclosed vertical opening in any building or fire section with only one exiL

Renumber the current 18-3.1.2 as 18-3.1.3 SUBSTANTIATION: The current exception as written is not an exception to 18-$.1.1 but more appropriately a separate requirement. Moving the language and creating the new paragraph is the correct action. COMMrlTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:


COMMENT ON AFFIRMATIVE: BALDASSARRA: Sentence is awkwardly worded. Suggest rewrite

as, ~unenclosed vertical openin~ in any building or fire section with only one exit shall not be permitted."

LATHROP: I concur with the affirmative comment of Mr. Baldassarra.


101- $78 - (18-3.4.4.1): Reject SUBMITTER: John W. Hallman III, Norfolk Naval Base Hre Dept. COMMENT ON PROPOSAL NO: 101-575 RECOMMENDATION: Revise text to read:

18-5.4.5.1 Approved, single-station smoke alarms shall be installed in accordance with 7-6.2.10 outside every sleeping area in the immediate vicinity of the bedrooms, nrior to the first sleevin~ room door in each sleenin~ area hallway, and on all levels of the dwelling unit including-bas-ements. SUBSTANTIATION: A smoke alarm placed in a hallway prior to the first bedroom door will provide earlier warning to occupants. A smoke alarm placed on the end of a "dead end" hallway allows the hallway to fill with smoke prior to the alarm sounding.

This section does not state a specific location for the smoke alarms to benefit the occupants. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This section does state a specific location for the benefit of the occupants.

The criteria in the code and NFPA 72 provide adequate early warning for all occupants as currently written. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:



101- 379 - (18-3.5.1 Exception No. 1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-576 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES give consideration to Mr. Lathrop's comment on affirmative so as to clarify that it accepted the proposal but for reasons in addition to, or in lieu of, that provided by the submitter. It reads:

LATHROP: Although I concur with the Committee action, the Committee confirmedduring the meeting that the proposer's substantiation was not totally accurate. The Committee had specifically intended to override NFPA 13R but concurs this is no longer needed. SUBSTANTIATION: See the above recommendation.

200

N F P A 101 - - F 9 9 R O C

COMMYPYEE ACTION: Accept in Principle. No action on test.

CoMMrrYEE S T A ~ : The Committee wi~hes to note that it had never specifi.cally addressed whether or not the exception applied towstenm designed to ~"PA I$IL This change now clarifies the committees intent.

OF ~ Ml~l l tE~q ELIG]MLE TO V O T ~ 24 VOTE ON COIVlMYITEE ACYION:


101- 380 - (18-3.5.2): Reject SUBMITrF~ Kenneth E. Bush, ~ S/~te Fire Marshal's Office COMMENT ON PROPOSAL NO:. 101-578 RECOMMENDATION: Delete 18-8.5.2 Exception (b). Reletter existing (c) to (b). SUBSTANTIATION: The purpose of this exception is to require automatic sprinkler protection tn buildings that have egress to exterior stairs above grade. Several recent fires have indicated that exterior vertical fire spread in unspfinldered buildings poses a significant hazard to the life r~fety of the building occupants and their associated egre~ path. Such exterior fire spread would directly expose the exit access needed for egress, especially from areas below not under the direct control or obeervadon of the occupants in question, and warrants the imtallafion of automatic sprinkler protection for new comremction. COMMITTEE ACTION: Reject. COMM1TYEE STATEMENT: As stated in the Committee Statement on Propmal 101.578, there has been no substantiation that the protection provided is somehow deficient.

The submitter of the comment has not provided any new information to iustify even this modifica~on to the NUMBER OF ~OMMr[WEE MEM3EI~ ELIGII tLgTO VOTE: 24 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 21 NEGATIVF_~ 1 NOT RETURNED:. 2 Kelly, Oneisom

EXPLANATION OF NEGATIVE: ISMAN: We are voting negatively on Comment 101-380 (Log

#369) (Section 18-$.5.2) because we believe that people are at risk in unsprinklered buildings with unprotected combustible means of egre t . COMMENT ON AFFIRMATIV~

BAIXIA58ARR~ People are not at risk in all buildinss. The Pthroposal reflects reasonable risk as per historical date available to

e committee.

• (log #362a) Committee: Y~AF-R~

101- $81 - (18-$.5.2): Accept SUBMITITA~ Kenneth E. Bush, MD State Hre Marshal's Office COMMENT ON PROPOSAL NO:. 101-264 RECOMMENDATION: Renumber existing 18-8.5,2 to 18-$.5.~1 and relocate proposed 18~.1.1 Exception No. S to a new 18-~.5.2.2. SUBSTANTIATION: It is bad Code language to write requirements by means of exceptions. These exceptiom have been relocated to paragraphs which otherwise contain the requirements for the installation of sprinkler protection in these variom occupa~n~., type~ All of the basic requirementa for the imtallation of sprinkler protection should be located in a common section of the Code resardle~ of the the intent of installation requirements. COMMITTEE ACTION; Accept. NUMBER OF COMMn"fEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:


Committee: ( I ~ - ~ 101- ~82 - (18-5.5.4 and 19-$~5.7): Accept in Principle SUBMITrER: Technical Correlafi'ng Committee on Safety to Life COMMENT ON PROPOSAL NO: I01.579 RECOMMENDATION: The Technical Correlating C o m n d ~ e on Sxfe~ to Hfe (SAF-AAC) request, that SAF-RES ~ s e . thepropmed wording to clarify intent. The table is not all inclusive; re~erence to the base paragraph wording of 18-S.2.1/19-$.2.1 is needed. The

phrase "as described withinTable 18-&2.1" could be reworded to read "addremed in 18-$.?,1.

Further, S&F-AAC directs that the pebfic comment reguest that SAF-RES expand ~ ml~emtiation to a d d r a the technical change made by addling exceptiom for q~rinklered tan'kilns. SUBSTANTIATION: See the above recommendation. COMMITrgg ACTION: Accept in Principle.

Revbe 18-&5.4~followE • "Portable fire *qctlr~,nkhem in zer~ntm~ce with 7-7. 4 ~ he

~m~ded in i , ~ d o u s a re~ ~ d d , , ~ d In m - s . ~ . ~ . ' Excep~on renmlm the same as p r o p 6 s ~ " Revise 19-~.5.7 as f011ow~ ~0rtahle fire egfintmhthers in accordance with 7-7.4 shall he

[~rovlded in ~ d o u s a r m a~lremed in 19-&~l." Exception remains the same as proposed.

COMblrITEE STATEMENT: Editorial change. NUMBER OF COMkffYrEE MEM]$EI~ ELIGIBLE TO VOTE: 24- VOTE ON COMMITYEE ACTION:

AFFIRMATIVE: NOT RETURNED: 2 Kelly, Oneimm

Committee: ( l ~ t ~ 101- SSS - (19-8.4.3.1 Exception and 19-S,4.4.1 Exception No. 1 ): Accept in Principle SUBMITYIUh Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-590 . RECOMMENDATION: The Technical Correlating Committee on "Safety to Life (SAF-AAC) requests that SAF-RES comider adding the words "in accordance with 7~2.8" to the end of Exception No. 1 to 19-&4.4.1 for correlation purprae~ The wording of the prop.osal refers to a "complete automatic smoke detection ~ t e m . " It will be helpful to the mer to-have a direct reference to 7-6.2.8 which addreses complete smoke detection ~ . If 8AF-RES does not mean for the complete automatic smoke detection system to be in compliahce with 7-B.2.8, then it should adopt a different term.

Further, SAF-AAC directs that the public comment request that SAF-RES substan~te the technical change that resulted from replacing the word "existin~ with the word "previomly approved." This has the effect of impomng a new requirement retroactively-- but without s u ~ o n . By current code language, the m~oke detection system only neecb to be existing; the new wording requirm that the AHJ must have previomly approved the existing smoke detection system (Le., no new approvals of existing ~UBSTANT term)"

IATION: See the above recommendation. COMMITYEE ACTION: Accept in Principle.

I Revise as fol lo~: 19-&4.~.1 Exceptien: ~ approved presignal sy~erm shall be

in accordance with Exceptlon No. 1 to 7-6.$.~ 19-3.4.4.1 Exception No. I: The single4tation smoke alarm shall

not be required where the building is equipped throughout with an g ~ a l i n g _ g a m i ~ automatic smoke detection system. COMMITIT~ STATEMENT: Upon review the Conurdttee concurs with the T(3C, howe~r the retention of the word "complete" is necemary for consistency. NUM3ER OF COMMITTEE MEM3F.~S ELIGIBLE TO VOTE: 24 VOTE ON COMMITYEE ACTION:

AFHRMATIVF~ 22 NOT RETURNED: 2 Kelly, Oneisom

(L~g#1Sl) Committee: SAF-RES

101- 384- (19~.4.4.1): Reject S ~ John W. Hallman llI, Norfolk Naval Base F'we

D ~ t W ~ I T ON PROPOSAL NO:. 101-575 R E C O ~ T I O N : Revise mxt to read:

19-S.4.5.1 Approved, sinRte4nafion smoke alarrm shall be installed in ar.cordance with 7-6.2.10 oumide every sleeping area in the immediate ViCinity of the bedrooms, nrlor to tlue tlrst sleenir~_ room door in each sleening area hallway, and on all levels of the dwelling unit induding-ba~mentL

Ex~emlon No. ~k In mehainlt earmructlon, mnoke alarms may he ne rm~ed r o b e cominued in~use. ~tUBSTANTIATION: A smoke alarm placed in a hallway prior to the first bedroom door will provide earlier warning to occulgmtL

201

N F P A 101 ~ F 9 9 R O C

Due to the expense of relocation, hard-wired smoke alarms shall be permitted to remain in place.

A smoke alarm placed on the end of a ~dead-end" hallway allows the hallway to fill with smoke prior to the alarm sounding.

This section does not state a specific location for the smoke alarms to benefit the occupants. COMMITrEE ACTION: Reject. COMMITrEE STATEMENT: This section does state a specific location for the benefit of the occupants.

The criteria in the code and NFPA 72 provide adequate early warning for all occupants as currently written. NUMBP_~R OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITI'EE ACTION:


(Log #64) Committee: SAF-RF_~

101- 385 - (20-2.1.1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-595 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES substantiate the technical change that resulted from deletion of the word "existing." The deletion makes the code more lenient by permitting a new fire escape stair to serve as a primary means of escape- but without substantiating that change. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Reject the Proposal. COMMITIXE STATEMENT: Upon furfher review it was not the intent of the committee to make this provision more lenient. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITI?EE ACTION:



101- 386 - (20-2.2 Exception No. 2): Accept in Principle SUBMITTER: Kenneth S. Fauistich, Dept. of Veterans Affairs COMMENT ON PROPOSAL NO: 101-597 RECOMMENDATION: Revise 20-2.2, Exception No. 2 to read as follows:

Exception No. 2: Stairways shall be permitted to be unenclosed in accordance with Exception No. 1 and No. 2 to 20-5.1.1." SUBSTANTIATION: In addition to the change made by this proposal to 20-3.1.1, changes to 20-2.2, Exception No. 2 are needed to coordinate this revision. COMMITI'EE ACTION: Accept in Principle.

Accept the proposal and revise language as follows: Exception No. 2: Stairways shall be permitted to be unenclosed

in accordance with the exceptions to 20-3.1.1. COMMITI'EE STATEMENT: Editorial change to the comment. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:



101- $87 - (20-$.1.1 Exception No. 2): Reject SUBMITTER: Terry A~ Brouwer, Waterford, CT COMMENT ON PROPOSAL NO: 101-597 RECOMMENDATION: Revise the Committee language as follows:

Exception No. 2: In buildings two or fewer stories in height protected throughout by an approved, supervised automatic sprinkler system in accordance with 20-3.5.1 which utilizes residential or ouick resnonse snrinklers, stair enclosures shall not be required, lfart (b) of the exception to 21-2.2.1 shall not be used. SUBSTANTIATION: The use of residential or quick response sprinklers is important when addressing the unprotected vertical opening which is to be used as the primary means of escape in a Lodging or Rooming House.

This language must be added to the exception as NFPA 15 permits the use of residential or quick response sprinklers but does not mandate the use of them like NFPA ISD andNFPA ISR. COMMrlqT_.E ACTION: Reject. COMMITTEE STATEMENT: Residential or quick response sprinklers are mandated by NFPA 13 for light hazard occupancies. It the designer chooses to go to Ordinary Hazard for design then there are other provisions that effect design. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: LATHROP: I concur with Mr. PuhlicL PUHLICI~ The following is my reason for voting negative: "A building which has an existing automatic fire sprinkler system

can change use to lodging or rooming without utilizing quick response or residential sprinklers under the exceptions to Section 5-2.1.3 of NFPA 15-1996, even if the system was designed as light hazard. Remember, we are allowing an open stair (unprotected vertical opening) to serve as the primary means of escape."


101- 388 - (20-3.5.1): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-604 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the extinguishing systems provisions of NFPA 101, review Proposal 101-604 for correlation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

I Retain the language of the Proposal. Revise %7.1.1 Exception No. 2 as follows: Exception No. 2: NFPA 13 D, Standard for the Installation of

Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes, shall be permitted for use as provided in Chapters ~-~0 through 23 of thin Code. COMMITTEE STATEMENT: SAF-RES is being asked to modify the appendix note to clarify the intent of this change. Based on the outcome of that action, the revision to Exception No. 2 of 7-7.1.1 is necessary. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14

(Log #65a) Committee: SAF-RES

101- 389 - (20-3.5.1): Accept in Principle SOBMI~AR: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-604 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES revise the appendix note (A-90-3.5.1) to reflect the change being made to 20-$.5.1. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Delete current text ofA-20-$.5.1 and replace with the following: A-20-3.5.1 The decision to allow the use of the criteria from NFPA

1 $D. Standard for the Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes. in these occuanncies is based on (1) the desire of the Committee to obtain

level of fire suDnression and control avnroximatelv the same as that delivered by residential facilities orotected bv such systems (see the annendix statement in NFPA ISD. Standard for the Installation of Snrinlder Systems in One- and Two-Family Dwellin~ and Manufactured Homesl. and (21 the fact that notential fire exposure and challenge to the suppression system in a small lod~in~ and rooming occunancv is of the same nature and no more severe than that found in residences. COMMITTEE STATEMENT: Addresses the TCC comment. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:


202

N F P A 101 m F 9 9 R O C

EXPLANATION OF N]KE~TIVE: ~

#6IS5 a~Nan~i W ~ I ~ 0 ~ . . ~ ~ ~ ~ ~Ol~"~gc~s~( wLw°~ee ar e concerned with the use of NFPA ISD outside of its scope.

(Log #415d) Committee: ~oAF-RF~

101- 390 - (20-3.5.1): Accept in'Principle SUBMITrER: John G. O'Neill, C, age-Babcock & Assoc. Inc. COMMENT ON PROPOSAL NO: 101-604 RECOMMENDATION: I continue to be concerned with the affafmppip.fication of NFPA 15D to occupancies other than one and two

ly dwelfings given the definitions of a dwelling and dwelling unit in NTPA 15D. SUBSTANTIATION: I serve as Cludr o~ the Technical Correlating Committee on Automatic Sprinkler S~e ms (NFPA 15D). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

The Residential Occupancy Committee needs to consider that criteria in NFPA 15D are what are the min imum t~'quiremeats for a sprinkler system intended to meet the scope and purpose dearly stated in 1-1 and 1-2, with the supportin~ appendices. In developing the ~ requirements, It has been the continuing goal of the Sprinkler Committee to keep down the costs of these systems, while still meeting the scope and objectives of the NFPA 15D standard, COMMITTEE ACTION: Accept in Principle: COMMITTEE STATEMENT: The committee has taken the safeguards to ensure that the occupancies really do resemble one and two family dwelling. See Committee Comment 101-592 (Log #450) for further darification oflntent. NUMBER OF COMMITIT_,E MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMrrTEE ACTION:


EXPLANATION OF NEGATIVE: ISMAN: We are voting negatively on Comment 101-589 (Log

#65a) and 101-590 (Log #415d) (Section 20-5.5.1) because we are concerned with the use of NFPA 15D ouedde of its scope.

Committee: ( ~ - ~ 101- 891 - (20-3.5.1 Exception No. 1): Accept in Principle SUBMITrFAh Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: I01-606 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF_-~C) requests that SAF-RES give consideration to Mr. Lathrop s comment on ~ v e so as to clarify that it accepted the proposal but for reasons in addition to, or in lieu of, that provided by the submitter. It reads:

LATHROI~. Although I concur with the Committee action, the Committee confirmed during the meeting that the proposer's substantiation was not totally accurate. The Committee had specifically intended to override NFPA ISR but concurs this is no longer needed. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

No action on text. C O ~ STATEMENT: The Committee wishes to note that it had never specillcail~ addressed whether or no t the exception applied to systems destgned to NFPA ISR. This change now clarifies the committees intent. NUMBER OF'COMMITrEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 22 NOT RETURNEI~. 2 Kelly, Oneisom

(Log #CC4~0) Committee: ~ t ~ - ~

101- 392 - (20-$.5.1 Exception No. 2): Accept S ~ Technicld Committee on R~.'sidential Occupancies COMMENT ON PROPOSAL NO: 101-604 R E C O M M E N D A T I O N : Revise the th ird s e n t e n c e o f the except ion as follo~: "

Lodging and rooming houses with sleeping accomodations for more than 8 occupants shall be treated as two family dwellings with regard to the water mpply.

SUBSTANTIATION: To further clarify the committees intent regarding the threshold of 8. occupants. COMMITTEE ACTION: Accel~ NUMBER O1~ COMMIITEE I~gM]SEI~ ELIGIBLE TO VOTE: 24 VOTE ON COMMYITEE ACTION:

AFFIRMATIVE: 22 NOT RETL~NED: 2 Kelly, Oneisom

(Log #f~58) Committee: SAF-RES

101- 395 - (20-3.5.2): Reject SUBMITrFAh Kenneth E. Bush, MDState F~re Marlhal's Office COMMENT ON PROPOSAL NO: 101-607 RECOMMENDATION: Revise the wording of the Exception as follows:

Exception: I f every sleeping room has a door opemng directly to _thY -

of the revised .exception is to require automatic sprinkler protection in buildings that have egress to exterior stairs above grade. Several recent fires have indicated that exterior vertical fire spread in unsprinklered buildings poses a significant hazard to the life safety of the building occupants and their assodated egress path. Such exterior fire spread would directly expose the exit access needed for egrem, especially from areas below not under the direct control or observation o f the occupants in question, and warrants the installation of automatic

m k l ~ c t i o n fur new construction. ACTION: Reject.

COMMITTEE STATEMENT/ As stated in ~ e Committee Statement on Proposal 101-607; there has been no substantiation that the protection provided is somehow deficient.

The submitter of the comment has not provided any new information to justify even this modification to the proposal. NUMBER OF CoMMrITEE MEMBERS ELIGIBLE- TO VOTE: 24 VOTE ON COMM1TYEE ACTION:

AFFIRMATIVE: 21 NEGATIVE: 1 NOT ~ W _ D : &~eA , ~ e i s o m

EXPLANATION OF ISMAN: We are voting negatively on Comment 101-39$ (Log

#f~8) (Section ~D.3.5.2) because we believe that people are at risk in unsprinklered buildings with unprotected combustible means of egress.

Conunittee.. ( ~ - ~ 101- 394 - (91-2.2.S Exception): A~.ept in Principle S ~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO:. 101-610 _ RECOMMENDATION: The Technical Correlating Committee on S.~ee/to Life (SAF4~C) requem that 8AF-R~ mfmantiate the technical change that resulted from replacing the word "existing" with the word "previously." This has the effect of impm'mg a new requirement retroactively - but without substantiation. By current code language, the means of escape only needs to be existing and receive approval; the new wording requires that the AHJ must have previously approved ~ e exlsfing means of escape (i.e., no new approvais of existing teaturet). SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

I Reject the Proposal COMMYITEE STATEMENT: Upon further review the committee agrees with the T C ~ It is not the intent of the committee to change this provision in this manner.

OF COMMITT]~ MEMIIE]~ ELIGIBLE TO VOTE: 24 VOTE ON COMMrlWEE ACTION:

AFFIRMATIV~ 22 NOT RETURNED: 2 Kelly, Oneisom

N F P A 101 ~ F99 R O C


101- 595 - (21-2.2.3(c) and 30-2.11.1 ): Reject SUBMrrrER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-611,101-849 RECOMMENDATION: We suggest that the two technical committees or the Correlating Committee review these proposals and ensure consistency between these requirements. SUBSTANTIATION: The Chapter 30 Committee accepted a proposal submitted to them that was rejected by the Chapter 22 committee that were almost identical. There needs to be correlation between these items to ensure consistency in text and enforcement. COMMITTEE ACTION: Reject. COMMITIXE STATEMENT: The proposals deal with separate issues.

One is a minimum size opening. The other is a depth which is adequately addressed in the

~ to 21-2.2.3(c). OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24

VOTE ON COMMITrEE ACTION: AFFIRMATIVE: 22 NOT RETURNED: 2 Kelly, Oneisom


101- 396- (21-2.5.1): Reject SUBMrlWER: Jake Pauls, Silver Spring, MD COMMENT ON PROPOSAL NO: 101-613 RECOMMENDATION: Revise text:

21-2.5.1 Stairs, ramps, guards, and handrails shall be in accordance with 5-2.2 for stairs and 5-2.5 for ramps.

Exception No. 1: The provisions of 5-2.205, 5-2.2.5.5, and 5-7.B shall not apply.

Exception No. 2: If serving as a secondary means of escape, stairs complying with fire escape requirements of Table 5-2.8.4(a) or (b) and ramps complying with the existing ramp requirements of Exception No. 2 t o 5-2.5.2 shall be permitted.

Exception No. 3: Maximum riser heights of 7 ~ /4 in. (19.7 cm) and minimum tread depths of 10 in. (25.4 cm) shall be permitted for stairs in new construction provided that a warning sign in compliance with ~1-~.5.1.1 is mounted so as to be readily visible to users of the stair.

~1-~.5.1.1 Safety Sign for Inadequate Step Geometry. A safety sima shall be provided for stairways with riser heights, measured exceeding 7 in. (178 mm~ or with tread depths less than 11 in. f279 mm) measured in accordance with 5-9.2.B.5. The safety sign shall consist of the triantmlar safety alert symbol, the "WARNING" signal word. the oictorial of a falling person and the applicable message set out in ~gu re t1-~.5.1.1. The tlesima shall be located and be of a size so as to be readily visible to and readable by stairway users before their stairway use is commenced. The back t, round to the "WARNING" simaal word and the "!" in the triangular safety alert symbol, shown shaded in F'Lgure 21-2.5.1.1. shall he safety orange in ~olor. Other hack t~round shall be white and all text plus t, raphics

SUBSTANTIATION: There is a societal responsibility, even a duty tha t could be court-enforced, that producers of a product and builders/owners of a building posing dangers to users provide a warning if the product poses a hazard that is not open and obvious to the user, if a suitable means exists to avoid the hazard and if the provision of a warning or instruction would reduce the risk associated with the hazard. Of course, if the hazard can be reasonably eliminated or guarded agaimt by the designer/builder, this takes precedence over provision of a warning (without product improvemen0 and this is the strategy behind my other proposal for this section of the Code. Indeed, it is widely accepted among public health professionals that injury prevention through product /environmental design/construction is the most effective public health strategy generally.

i

Stairway steps are small and steep oompe;'ed to steJrwaye In most bulldlngo.

A fall, oeriouo injury and dieob||Hy oould ooour. Escape duflng a fire will be extra dlfflcult.

Limit stairway use if sleepy or impaired. Walk 8fawly. Twist Net to the side to maximize support. Avoid oanylng objects and children.

Remove thiok oerpet and pod from ~epo.

Bgam.llff~tda.

Currently, it appears that the Residential Committee is not willing to apply the more-effective public health strategy that modifies the environment to remove or guard against hazards. Some members appear to put the responsibility on the dwelling unit occupants to cope with the extremely low-standard stairways permitted by the current Code. In other words, the committees--and the home builders' demands to which such committees often defer - - implicitly take the discredited and unconscionable approach of blaming the victim of a fall without correctin.~ the environmental defect which unreasonably increases the likehhood of the environmentally-triggered human error, misstep, fall, injury, disability and death.

The cost impact to providing safety signs is a tiny fraction of the cost of stair-related injuries (which are identified in detail in my related proposal on step geometry) and a small fraction of the cost of designing and constructing the stair with reasonable measures for usability and safetymwhlch, if done, would of course obviate the need for the sign.

This proposal is one of a series, dealing with safety signs, submitted also on the drafts of ICC codes. Submission of these proposals is in tended to make committees and voting members of the code community aware of the seriousness of deficient stair design and construction. Enforcement should also be improved as a result. Finally (regardless of what the Residential Committee, the ICC, the regulators and home builders do), there is also the prospect of litigation based on failure to provide a reasonably safe product a n d / o r failure to warn. Given the amount of evidence of serious safet)r/.nsability problems with stairways and the double standard which has existed too long with deficient home stairways (as described in detail in an accompanying proposal which would obviate need for the sign), regulators and builders cannot condnue to blame the victims for their falls and injuries.

Bibliography In developing the proposed sign, reference has been made the

ANSI 535 series of American National Standards. These provide detailed guidance on text size, color, alternative formats for the sign, etc. (note that, while the ANSI Z535 Secretariat is the National Electrical Manufacturers Association (NEMA), these consensus standards are comprehensive and are prepared by a diverse committee including highly qualified experts in ergonomics--- human factors--of warnings and product safety.)

ANSI Z535.1, Safety Color Code, NEMA, Rosslyn, VA, 1998. ANSI Z535.2, Environmental and Facility Safety Signs, NEMA,

Rosslyn, VA, 1998. ANSI Z535.3, Criteria for Safety Symbols/Pictorials, NEMA,

Rosslyn, VA, 1998. ANSI Z535.4, Product Safety Signs and Labels, NEMA, Rosslyn,

VA, 1998. COMMITTEE ACTION: Reject.

204

NFPA 101 - -

COMMITTEE STATEMENT: The committee b on record m stating that the 7 $/4 x 10 configuration is a safe m i r geometry. It is important tO follow the providom of Chapter 5 an~the appendix note A-5-2.~.$3 On how tO make the mea~remen~ If these provisions are ~ollowed then the r e , it is a safe stair.

This' proposal would contradict current committee actions NUI~ER OF ~ MEMBEi~ ELIGmLE TO VOTE: .24 VOTE ON CoMMrrrEE AL'rlON:

AFFIRMATIV~ 22 NOT RETURNED: 2 Kelly, Oneisom

Com tte 101- $97- (21-2.5.1): Reject SUBMrrrER: Jake Pauis, Sliver Spring, MD COMMENT ON PROPOSAL NO- 1012613 RECOMMENDATION: Revise texU

21-2.5.1 Stain, ramps, guard& and handrails ~ ! 1 be in accordance with 5-2.2 for stairs and 5-2.5 for ramie.

Exception No. 1: The provisions of 5-2.5.5, 5-2,~3.5, and 5-7.3 shall not apply.

Exception No. 2: If serving as a secondary meam of escape, stairs complying with fire escape requirements of Table 5-2.8.4(a) or (b) and ramps Complying with the existing ramp requirements of Exception No. 2 to 5-2.5.2 shall be permitted.

~Z.-..-.~=-:.Z.--x--z_y-_r.-~^Z . . . . . . . . . . . . . . . . . . r ~ ......

SUBSTANTIATION: This comment correctly states the major proposed change that I had intended with my submittal of Proposal I0126~. Essentially this is intendedto ~nalmtream" the "7-11" stair geometry s o t h a t it is applicable as the minimum requirement for dwellings as it isthe minimum requirement, in the Life Safety Code (and other codes), for buildings, generally.

The Bottom Line. The bottom line of a very large jmtificafion for this comment is that if the "7-11" step geometry is" jm~dfied asthe minimum standard for buildings where a minority Of injurioos falls occor--and where fire-related emergency egress is considerably le~ dangerous overall than in a dwelling (in view of national statistics on locatlom of fire deatl~)--then the "7-11" geometry should also be the minimum requirement for dwellings.

Other Committee Member Viem. In addition to representing the long-established and well-published viem of this c0mmentor, the comment is also consistent with the comment of ~ommittee member Mr. Gerdes as published in relation to his Negative Ballot in the ROP. It is also consistent with the comment by Means of Egress Committee member Mr. Alkman in relation to Comment 101B-5 in 1998. In that comment he said:

"A critical dimension of stairs in an egress situation down the stairs is the effective depth of tread available to the user. For this purpose the size of the nosing is completely irrelevant. The critical dimension is the effective portion of the tread on which the foot can be placed. The back of the foot (heel or shoe) has to be placed clear of the front edge of the step, thin the effective tread • surface is probably one half to one inch lem than ~ e ran. The critical value is not the tread depth. Even a ~ of 7 in. is onerom for elderly persons with limited joint mobility. A value of about 6 in, hm been indicated by seniors as a preferred value. Although rise values exceeding 7 in. have been and still are being used to regulate stairs, NFP~ 101 should be taking a leadership role to improve requirements, not just followh3g on the tradltiom of other authorities. It does not make muchsense to exdude stairs in dwelling units from the benefits of the 7/11 stair - these stairs have the greater use, have a greater mix of users witha wide r~mge of abilities and are often subject to accidental falls in everyday use. To desi~gn these only for emergency use doesnot make sease."

Mr. Gerdes' comment on this negative ballot (for the NFPA 101 ROP) also echoes Mr. Aikman's; i.e., ~ h e Committee's decision to defer to a BOCA ad-hoc committee is a shirking of responsibility,"

Turninlg to a much~hortened version of my own standard justificauon statement on this topic (m has been published recendy--early 1999---in the code-change proposal monographs for the IC~ code chanqe hearings for the ~ edition "lnternatmnal Codes"), I am providing first some updated information revising what was published in the ROP for Proposal 1012615.

Statistics. On the matter of CPSC stat~tics (which dearly identify stairs as the NEISS-coded product with the greatest number of hospital-treated injuries)-, fewer than half ofigjuries, generally, are treated in hospital emergency departmencq more are treated m

F99 ROC

doctors' officers and, with the.increasing reliance on HMO~ clinics equipped to handle most injuries of the fall type (involving broken bones, dislocation& etc.) are every more likely to be (and required by HMOs to be used) rather than hospital emergency departments. Thus CPSC NEISS statisfi~ dramatic as they are, are only indicative of the problerm; .they understate the problem& Stairs are the leading or secolui4eading catego.ry related to injuries. Notably for the older age groups s~irs are a dose second to floors even though elderly persons tend to use stairways less than other age groups and, generally, we tend to use floon somewhere in the range of ten to one hundred times more than we use stairs. The bottom line is that stairs are a relatively hazardous product.

Injury Com. Also updating from what was publishad with Proposal 101-61& the comprehemive cons (to moiety) of stair- related injuries are comid~ably higher than previomly reported. The National Public Services Research lmfimte, Landover, MD, has provided the following esfimat~ of injury costs related to stairs. These figures are for the year 1995 in the U~S. and are rated in 1907 dollars.

Medical cost~ $ 4.7 bil~on Productivity loues $ 7.1 billion Quality of Life lomes $~.1 billion Tom1 Cram $49.9 billion

These cos~ are what are termed "Comprehemive Costs." They are based on an Injury Cost Model taking a sodetal viewpoint and using data from the 1990s (indudingCl~SC/HEISS and 17 other large data sees) considering 11 cost ~:omponehts: inpatient, ambulance, ancillary andpost.discharge costs; health insurance claims processing costs; short-term and long4erm work lc~es plus employer losses; quality of life, and pain and suffering cost (subjected to a ~mitlrlty analysis comidering Quality Adjusted Life Years or QALYs); and product liability costs consisting ot insurance administration costs and litigation com. A comervatlve 9.5 percent discount rate is used in the Model.' These~estimates share, with earlier more-crude estimates, the characteristic (~ being about an order of ~ e greater (a factor of ten) than stair construction cmts annually in the U.S. Such a huge mimmtr.h of injury costa and comtrucfion costs underlines that there b a huge unsolved stair ~fety problem; therefore improved requirements for design and construction--including riser-tread requirements similar to those required in lem-demanding settings--are dearly warranted. (Incidentally, the severity of laalr-related injuries places them in the dubious company of tobacco products, firearms and illegal drugs m issues warranting major concern by the p~blic, by the public health community, as well as by the legal community phm the media.)

Referencei to More-Detailed Information. For a faidy complete comment on the need for maln~eaming the "7-11" step geometry standard for dwellings interested readers are referred to p~.ges ~9- 255 of the 1999 Proposed ~t~mges to the International Residential Code TM Final Draft, International Code Council, Falls Church, VA. Related issues are also discumed (in relation to carpeting of stairs) on pages 260-262 of the above cited publication and (in relation to warning sigm), on pages 255-258 of the above cited publication. Original copie s of my mbmiued propmals to ICC on these issues are being lXovided ~ part of this comment and should be distributed to the NFPA Residential Committee for reference. (Jake Paub is the copyright holder of the origi_lmlly submitted propo~s tO ICC; therefore distribution to NFPA Committee memben and other interested parties is specifically authorized.) Such material would have been incorporated within this comment except for the concern about NFPA not p ublishin~ such extensive jmfifieationL Aim made available to the Residential Committee (in July 1998 and generally available to any interested pertain) wm an extemively referenced pape~ Paub, J. (1998) Benefit, trot analym and homing affordability:. The case of stairway usability, safety, design and related requirements and guidelin~ for new and existing homes. Proceedings of Pacific Rim Conference of Building Officials, pp. 21-~8.

Generally, the above noted materials addrem the following topics in detail:

Stair-related Injuries as a Relatively Large, Growing Problem Injury Coats Related to Stairs Hypocrisy about a Double Standard for Stairs

S ~ ~or Improved Step Geometry Requirements in Codes and

Other History Behind Step Geometry Requiremenm History of Ri~r-Tread Deliberations in ICBO

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Deficiencies with Model Code Drafting and Development Procedures

Building and Marketing Improved Stairs Increased Space and Benefit-Cost Effectiveness of Improved Step

Geometry for Stair Safety and Usability Politically~driven Local and State Adoption Process I am fully prepared to discuss any of these points (which are

covered in detail in material generally available) with the NFPA Residential Committee and, at the Fall Meeting, with NFPA members voting on this matter. Furthermore, the failure of the model code and national standards community to deal reasonably and adequately with this leading problem of building safety and usability is being addressed as well in a policy resolution which I have submitted to the American Public Health Association for processing and APHA membership approval in November 1999 (the week before the NFPA Fall Meeting). Featured in the policy resolution is the hypocrisy in model codes and standards organizations in dealing inequitably with the step geometry issue (and related safety/usability issues) in dwellings relative to what is required for buildings generally.

Moreover, a number of points need to be made which have not been published elsewhere.

Committee Jurisdiction. Regarding the scope of the Residential Committee which is acting on this comment; quoting from the published Committee Scope (of the F99 Report on Proposals): "This Committee shall have primary responsibility for documents on protection of human life from fire and other circumstances producing similar consequences, and on the emergency movement of people, in hotels, c[ormitories, apartments, lodging and rooming houses, and one- and two-family dwellings." The scope for other committees is broader, including nonemergency movement of people; note that the Means of Egress Committee scope states: "This Committee shall have primary responsibility for documents on ... the nonemergency and emergeno/movement of people." The base requirement for the "7-11" stmr geometry--with no exception allowing new stairs of lower standard (except for somewhat higher risers permitted in certain sightline-constrained portions of assembly seating aisles)mis found in Chapter 5 over which the Means of Egress Committee has control. Therefore, as a matter of jurisdiction, the Residential Committee should not dictate the geometry of stairs in dwellings where there is both an emergency movement concern and a nonemergency movement concern.

Scope of the Life Safety Code. The Scope of the Life Safety Code is consistent with this comment. Section 1-2.3, Other Considerations, states (in the F99 Report on Proposals), "The Code addresses other minimum considerations that are essential for life safety in recognition that life safety is more than a matter of egress. ~ Section 1-3.4 states: "The Code does not address:... (b) prevention of personal injuries incurred as a result of an individual's own negligence..." The implied (and formerly used) term "accidents" is no t much used an~trn, ore in the public health field in relation to injuries; "accident implies unpredictable and unpreventable. If stair-related injuries were accidents in this strict sense there would be little or no justification for any step geometry requirements anywhere in the Life Safety Code. Indeed many other requirements intended to reduce or prevent injuries would have to be deleted from the Code as well is these were accidents. As for the currently used phrase "incurred as a result of an individual's own negligence, ~ the vast majority of falls on stairs are notably due to an "individual's own negligence." Thus the prevention of stair- related injuries on stairs is within the scope of the Life Safety Code and has been for a long time.

Use of the Life Safety Code. The Life Safety Code has relatively little use in the regulation of dwellings. However, the Life Safety Code is widely known as the best model or source for other codes' requirements. It tends to lead the model codes on technical issues. With the development of the so-called "International Codes" by the ICC and the political moves across the U.S. to adopt such codes, the established role of the Life Safety Code as the leader for others to follow eventually is once again relevant on this controversial issue of step geometry for dwellings. If the Code is not go ing to be adopted, and if other codes (such as the GABO/IGC One and Two-Family Dwelling Code and the BOCA National Building Code) also having the compromise 7 3 /4 by'10 step geometry requirement are further compromised back to the o l d 8 1 /4 by 9 rule because of the selfish political pressures from the NAHB and home builders generally, then the NFPA should maintain its purity, standards, and traditional position as standing above such socially irresponsible political compromises. Indeed, when I personally submitted a proposal (and fought the home builders through to a complaint, by NAHB, to the Standards

Council) on the compromise 7 3/4 by 10 standard, I did so with the hope (shared byBOGA and GABO) that the homebuilders would at least agree to try the new step geometry standard to assess its effectiveness and acceptability within the marketplace. This compromise of what I knew about the need for the "7-11" step geometry and the need to try something new politically was a futile gesture on my part and on the part of many leaders in the model code community. The NAHB and homebuilders generally refused to go along with the new rule even through they had been disproportionately prominent on the very committees who recommended the compromise rule (as on the BOCA Ad Hoc Committee on Stairway Safety). After my 32 years working on model codes and standards in the U.S., Canada and elsewhere, I am professionally offended by the irresponsible behavior of homebuilders on this crucial issue of home safety and usability. Increasingly the backward stance of homebuilders is only explainable by their apparent motivation to control regardless of the costs to society and to reasonable regulation of buildings. Thus it is time for NFPA and other socially responsible organizations to desist from cowtowing to the homebuilders and to stand up for what is right. Again, if "7-11" is not "right" as a long established minimum standard for stair safety and usability (a standard now going back nearly four decades), then it should be struck from the Life Safety Code and other codes wherever it is used. That is, if it is not technically justified, then it is not technically justified anywhere. However, it is the "7-11" that is best

justified by research and which has been recommended by researchers for dwellings since the mid 1970s. After two and a half decades, perhaps it is time for the Life Safety Code to take note of its own long-standing reliance on the "7-11" standard and the wealth of technical backing for it, and to establish the "7-11" as the minimum standard for exactly the situations where it is most needed- - in dwellings.

Finally, to rebut the argument that the better step geometry is justified where there are crowds to be evacuated in emergencies as opposed to small numbers of people in dwellings, it should be absolutely, clear that the researchers most skilled in issues of safe and efficaent crows movement (notably Dr. J o h n Fruin, Dr. John Templer, Dr. John Archea, and Jake Pauls) all are on record-- in writing--as advocating the 7-11 as the minimum standard for dwelling unit stairs just as for other stairs. This reflects the greater exposure to stair fall risks on home stairs and the greater vulnerability due to demographics and use conditions in dwellings inducting the more rapid egress/escape that must occur in dwellings where desperately little time is available in fire emergencies. Notably speed of movement on stairs is a factor in falls (whereas, on heavily Used public stairs where there is a high degree of fire protection features, crowd movement in egress occurs most efficiently at relatively slower speedwbecause flow is the product of speed and density with speed varying inversely with density).

avaA~adabin, as noted above, there is a wealth of published information le on this issue. This comment can only show the t ip of the

iceberg both for technical aspects and political aspects. NFPA's credibility as a past, present and future leader in building safety is at stake here as ispublic health, safety and welfare. Refusal of the NFPA Life Safety Code committees (both Means of Egress and Residential) to deal with this will almost certainly lead to this issue going before the NFPA membership as well as being featured in current and future considerations by the public health community of the role of codes and standards in public health generally.

Postscript. It should be noted that the recently published NFPA 101B includes the 7 ~ /4 by 10 requirement as Exception No. 2 to Table 3-2.2.2.1 Stair Criteria. I serve as a member of the Means of Egress Committee which is largely responsible for this standard however, it should be noted that I proposed the "7-11" standard and argued for it despite not being able to at tend either the last committee meeting before its publication or the 1998 Fall Meeting where it was approved. In both cases, there were prior commitments (to the Pacific Rim Conference of Building Officials where the paper (submitted with this comment) was presented and to the Annual Conference of the American Public Health Assodation for which I serve as the APHA representative to the ICC Industry Advisory Committee). Of course I did submit a negative ballot on the matter and would have taken this issue to the floor of the 1998 Fall Meeting had there not been the unfortunate scheduling conflict.

Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE ACTION: Reject. COMMrITEE STATEMENT: The Committee Statement on Proposal 101-615 has not be addressed by the submitter. No new

N F P A 101 - - F 9 9 R O C

information has been presented that would connect the accident statistics directly to stmr geometry. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMM1T1T.E ACTION:

AFFIRMATIVE: 19 NEGATIVE: B NOT RETURNED: 2 Kelly, Oneisom

EXPLANATION OF NEGATIVE: GERDES: The submitter has submitted significant data that

shows there are numerous and cosily stair acddents every year. The committee thinks there are too many variables to manage the situation and that adequate stair geometry is not ascertainable. I disagree. If the code mandates 7 - 11 for all other stairs this is the basis for 7 - 11 for one- and two-family dwelling units.

JARDIN: During the ROC meeting, the commenter pointed out a major flaw associated with the current requirement for new stair geometry. Riser height and tread depth should be measured considering the floor coveting to be used on the stair. A-5-2.2.$.5, applicable to new stair construction in one- and two-family dwellings, discusses the reduction of effective tread depth caused by the use of floor coverings. It is not dear to many code users, that new stair geometry in one- and two-family dwellings should be measured in accordance with A-5-2.2.3.5.

After much discussion, a motion was made to develop text similar to A-5-2.2.$.5 within Chapter 21 as a reminder, to ensure a true %$/4-10 in. riser tread relationship. The commenter stated be would consider this approach acceptable. The motion narrowly failed (7-8). Those opposing the motion stated that enforcement of the measurement technique contemplated by A-5-2.2.3.5 is difficult. The opponents stated that once the stair is built and pproved, there is no control over the future floor coverings varying range of types and thickness). It appears that there exists a blatant disregard for the current code

requirements, concerning the design and measurement of stairs for new one- and two-family, dwellings. Although the Code currendy requires 7-$/4-10 in. stmrs many acknowledge that this is not what is being produced (considering floor covering application). Many state they should not be forced to consider future floor coverings when seeking stair approval.

Therefore, in order to ensure that what is being built, post floor covering application provides something close to 7-3/4-I0 in., it is time to require a 7/11 stair for stairs in new one- and two-family dwellings. This will provide for safe stair travel while relieving home builders of the worry over future floor coverings.

LATHROP: I believe the committee should go to the 7-11 but clarify that recalculations after carpeting is installed not needed. This results in what the Code now reqmres (7-3/4 x 10 but consider carpeting). COMMENT ON AFFIRMATIVE:

BROWN: The Committee Statement "No new information has been presented that would connect the accident statistics directly to stair geometry" is accurate. I fully agree with this conclusion. When you try to associate the proponents vast compilation of submitted data with this reasoning, there is no conclusion. There is no bottom line.

CHRISTIE: Indude with the Committee Action the following list of possible causes of accidents on stairs that was dated April 21, 1999 and submitted by Peter Christie at the committee meeting on May 4, 1999.

As Mr. Jake Pauls' comments have been repeated on this ballot, then the list noted above on the possible causes of accidents on stair should also be included with this ballot to question the use of hospital statistics on stair acddents as the justification for 7:11 stair geometry.

A. Geometry of stair risers and treads. There is insufficient technical data on stair design for one and

two family dwellings (or for all other uses for that matter) to justify changing from stairs with 7-$/4 in. risers and 10 inch treads to stairs with 7 in. risers and 11 in. treads. Even Mr, Jake Panls admits that there is less research than he would like in the relationship between step geometry and misstep/fall/injury rates. Perhaps we have all recognized the lack of sufficient research. Furthermore, Mr. Pauis has relied on some broad statistics on hospital treated injuries related to steps and stairs to justify a 7:11 stmr design. Whilst he implies that stair geometry is the primary cause of the injuries, the probability is that there are one or several other causes from the following list that contributed to the accidents.

1. 7:11 stair geometry 2. 2R x T=25 in. geometry $. Other riser/tread geometry. R+T+17 RT=75 R/TffiTan (R-g)

x8 degrees

4. One of twO steps (many law suits) (peripheral visions & depth)

5. Irregular heights or width (dimensional nonconformity) 6. Treads out of plane (beyond allowable tolerances). . 7. Abutting surfaces out of plane (usually at bottom ot stair) 8. Inconsistent winders on curved stairs 9. Slippery treads or nosings

10. Carpeted stairs (loose, torn, thickness) 11. Lack of handrails 12. Only one handrail (not two) 13. Misplaced handrail (improper height or length) 14. Handrail graspability 15. Poor lighting (amount or location) 16. Undefined start of stair 17. Failure of user to look for stair 18. Iml?roper headroom 19. Objects or obstructions on stair 20. Other people on stair (passing) 21. Age of user (young and elderly) 22. Physical ailments of user (heart, cane, crutches) 25. Speed of user on stair 24. Two risers at a time (up or down) 25. Condition of shoes (untied, loose fitting) 26. Heel height 27. Familiarity with stair (use everyday vs. occasional use) 28. Playing on stair, horse play 29. Drunkenness of user $0. Visual diswactions (I was once sued unsuccessfully because the decorations were

"too attractive" - a woman fell! There were different art or decorations adjacent to each step).

It is probable that riser/tread i~eometry in itself has little or nothing to do with most of the injuries referred to by Mr. Pauis. Until careful research as to the specific causes of those accidents can confirm a clear necessity for the 7:11 formula, Exception No. 3 to 21-2.5.1 should stand a n d a revision should be made to Table 5-2.2.2.1 (a).

(Log #334a) Committee: SAF-MEA

101- 398- (21-2.5.1): TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed to "REJECT." SAF-AAC directs this action because:

1. Primary responsibility rests with the SAF-RE$ committee which was aware of the action taken by the SAF-MEA committee when it rejected Comment 101-397 (Log #334).

2. The proponent has not provided sufficient new information to justify chahging the existing text. SUBMITTER: Jake Pauls, Silver Spring, MD COMMENT ON PROPOSAL NO: 101-613 RECOMMENDATION: Revise text:

21-2.5.1 Stairs, ramps, guards, and handrails shall be in accordance with 5-2.2 for stairs and 5-2.5 for ramps.

Exception No, 1: The provisions of 5-2.5.5, 5-2.2.5.5, and 5-7.3 shall not apply.

Exception No. 2: If serving as a secondary means of escape, stairs complying with fire escape requirements of Table 5-2.8.4(a) or (b) and ramps complying with the existing ramp requirements of Exception No. 2 to 5-2.5.2 shall be permitted.

~'..~. 25".7,, '-- 2 L ~ " . ~ ~7.Y. ~,.':"^ Z . . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . .

SUBSTANTIATION: This comment correctly states the major

~ roposed change that I had intended with my submittal of roposal 101-615. Essentially this is intended to "mainstream" the

"7-11" stair geometry so that it is applicable as the minimum Uirement for dwellings as it is the minimum requirement, in the

Safety Code (and other codes), for buildings generally. The Bottom Line. The bottom line of a very large justification for

this comment is that if the "7-11" step geometry is justified as the minimum standard for buildings where a minority of injurious falls occur--and where fire-related emergency egress is considerably less dangerous overall than in a dwelling (in view of national statistics on locations of fire deaths)-- then the "7-11" geometry should also be the minimum requirement for dwellings.

Other Committee Member Views. In addition to representing the long-established and well-published views of this commentor, the comment is also consistent with the comment of Committee member Mr. Gerdes as published in relation to his Negative Ballot

207

N F P A 101 ~ F 9 9 R O C

in the ROP. It is also consistent with the comment by Means of Egress Committee member Mr. Aikman in relation to Comment 10113-5 in 1998. In that comment he said:

"A critical dimension of stairs in an e h, ress situation down the stairs is the effective depth of tread available to the user. For this purpose the size of the nosing is completely irrelevant. The critical dimension is the effective portion of the tread on which the foot can be placed. The back of the foot (heel or shoe) has to be placed clear of the front edge of the step, thus the effective tread surface is probably one half to one inch less than the run. The critical value is not the tread depth. Even a rise of 7 in. is onerous for elderly persons with limited jo in t mobility. A value of about 6 in. has been indicated by seniors as a preferred value. Although rise values exceeding 7 in. have been and still are being used to regulate stairs, NFPA 101 should be taking a leadership role to improve requirements, not just following on the traditions of other authorities. It does not make much sense to exclude stairs in dwelling units from the benefits of the 7 / I 1 stair - these stairs have the greater use, have a greater mix of users with a wide range of abilities and are often subject to accidental falls in everyday use. To design these only for emergency use does not make sense."

Mr. Gerdes' comment on this negative ballot (for the NFPA 101 ROP) also echoes Mr. Aikman's; i.e., "The Committee's decision to defer to a BOCA ad-hoc committee is a shirking of responsibility."

Turning to a much-shortened version of my own standard justification statement on this topic (as has been published recently---early 1999.--in the code-change proposal monographs for the ICC code chan~e hearings for the 2000 edition "International Codes"), I am provtding first some updated information revising what was published in the ROP for Proposal 101-613.

Statistics. On the matter of CPSC statistics (which dearly identify stairs as the NEISS-coded product with the greatest number of hospital-treated injuries), fewer than half of injuries, generally, are treated in hospital emergency departments; more are treated in doctors' officers and, with the increasing reliance on HMOs, clinics equipped to handle most injuries of the fall type (involving broken bones, dislocations, etc.) are every more likely to be used (and required by HMOs to be used) rather than hospital emergency departments. Thus CPSC NEISS statistics, dramatic as they are, are only indicative of the problems; they understate the problems. Stairs are the leading or second-leading category related to injuries. Notably for the older age groups stairs are a close second to floors even though elderly persons tend to use stairways less than other age groups and, generally, we tend to use floors somewhere in the range of ten to one hundred times more than we use stairs. The bottom line is that stairs are a relatively hazardous product.

Injury Costs. Also updating from what was published with Proposal 101-615, the comprehensive costs (to society) of stair- related injuries are considerably higher than previously reported. The National Public Services Research Institute, Landover, MD, has provided the following estimates of injury costs related to stairs. These figures are for the year 1995 in the U.S. and are stated in 1997 dollars.

Medical costs $ 4.7 billion Productivity losses $ 7.1 billion Quality of Life losses $~8.1 billion Total Costs $49.9 billion

These costs are what are termed "Comprehensive Costs." They are based on an Injury Cost Model taking a societal viewpoint and using data from the 1990s (including CPSC/NELSS and 17 other large data sets) considering 11 cost components: inpatient, ambulance, ancillary and post-discharge costs; health insurance claims processing costs; short-term and long-term work losses plus employer losses; quality of life, and pain and suffering cost (subjected to a sensitivity analysis considering Quality Adjusted Life Years or QALYs); and product liability costs consisting of insurance administration costs and litigation costs. A conservative 2.5 percent discount rate is used in the Model. These estimates share, with earlier more-crude estimates, the characteristic of being about an order of magnitude greater (a factor of ten) than stair construction costs annually in the U.S. Such a huge mismatch of injury costs and construction costs underlines that there is a huge unsolved stair safety problem; therefore improved requirements for design and construction--including riser-tread requirements similar to those required in less-demandlng settings--are clearly warranted. (Incidentally, the severity of stair-related injuries places them in the dubious company of tobacco products, firearms and illegal drugs as issues warranting major concern by the public, by the public

health community, as well as by the legal community plus the media.)

References to More-Detailed Information. For a fairly complete comment on the need for mainstreaming the "7-11" step geometry standard for dwellings interested readers are referred to p~.es 239- 253 of the 1999 Proposed Changes to the International Restdential Code TM Final Draft, International Code Council, Falls Church, VA. Related issues are also discussed (in relation to carpeting of stairs) on pages 260-262 of the above cited publication and (in relation to warning signs) on pages 255-258 of the above cited publication. Original copies of my submitted proposals to ICC on these issues a rebe ing provided as part of this comment and should be distributed to the NFPA Residential Committee for reference. (,lake Pauls is the copyright holder of the originally submitted proposals to ICC; therefore distribution to NFPA Committee members and other interested parties is specifically authorized.) Such material would have been incorporated within this comment except for the concern about NFPA not publishing such extensive justifications. Also made available to the Residential Committee ( inJuly 1998 and generally available to any interested persons) was an extensively referenced paper. Pauls, J. (1998) Benefit-cost analysis and housing affordabiliW. The case of stairway usability, safety, design and related requirements and guidehnes for new and existing homes. Proceedings of Pacific Rim Conference of Building Officials, pp. 21-38.

Generally, the above noted materials address the following topics in detail:

Stair-related Injuries as a Relatively Large, Growing Problem Injury Costs Related to Stairs Hypocrisy about a Double Standard for Stairs History for Improved Step Geometry Requirements in Codes and

Standard Other History Behind Step Geometry Requirements History of Riser-Tread Deliberations in ICBO Deficiencies with Model Code Drafting and Development

Procedures Building and Marketing Improved Stairs Increased Space and Benefit-Cost Effectiveness of Improved Step

Geometry for Stair Safety and Usability Politically-driven Local and State Adoption Process I am fuUypre .~yed to discuss any of these points (which are

covered in detml in material generally available) with the NFPA Residential Committee and, at the Fall Meeting, with NFPA members voting on this matter. Furthermore, the failure of the model code and national standards community to deal reasonably and adequately with this leading problem of building safety and nsability is being addressed as well in a policy resolution which I have submitted to the American Public Health Association for processing and APHA membership approval in November 1999 (the week before the NFPA Fall Meeting). Featured in the policy resolution is the hypocrisy in model codes and standards organizations in dealinginequitably with the step geometry issue (and related safety/usability Issues) in dwellings relative to what is required for buildings generally.

Moreover, a number of points need to be made which have not been published elsewhere.

Committee Jurisdiction. Regarding the scope of the Residential Committee which is acting on this comment; quot ing from the ~ublished Committee Scope (of the F99 Report on ProposaLs): This Committee shall have primary responsibility for documents

on protection of human life from fire and other circumstances producing similar consequences, and on the emergency movement of people, in hotels, dormitories, apartments, lodging and rooming houses, and one- and two-family dwellings. ~ The scope for other committees is broader, including nonemergency movement of people; note that the Means of Egress Committee scope states: "This Committee shall havepr imary responsibility for documents on ... the nonemergency andemergency movement of people." The base requirement for the "7-11 ~ stm'r geometry--with no exception allowing new stairs of lower standard (except for somewhat higher risers permitted in certain sightline-constrained portions of assembly seating aisles)--is found in Chapter 5 over which the Means of Egress Committee has control. Therefore, as a matter ofjurisdicdon, the Residential Committee should not dictate the geometry of stairs in dwellings where there is both an emergency movement concern and a nonemergency movement concern.

Scope of the Life Safety Code. The Scope of the Life Safety Code is consistent with this comment. Section 1-2.$, Other Considerations, states (in the F ~ Report on Proposals), ~rhe Code addresses other minimum considerations that are essential for life safety in recognition that life safety is more than a n~t te r of

2O8

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egress." Secdon 1-3.4 states: "The Code does not address:... (b) prevention of personal injuries incurred as a result of an individual's own negligence..." The implied (and formerly used) term "acddents" is not much used anymore in the public health field in relation to injuries; "accident" implies unpredictable and unpreventable. If stair-related injuries were accidents in this strict sense there would be little or no justification for any step geometry requirements anywhere in the Life Safety Code. Indeed many other requirements intended to reduce or prevent injuries would have to be deleted from the Code as well is these were accidents. As for the currently used phrase "incurred as a result of an individual's own negligence," the vast majority of falls on stairs are notably due to an "individual's own negligence." Thus the prevention of stair- related injuries on stairs is within the scope of the Life Safety Code and has been for a long time.

Use of the Life Safety Code. The Life Safety Code has relatively little use in the regulation of dwellings. However, the Life Safety Code is widely known as the best model or source for other codes' requirements. It tends to lead the model codes on technical issues. With the development of the so-called "International Codes" by the ICC and the political moves across the U.S. to adopt such codes, the established role of the Life Safety Code as the leader for others to follow eventually is once again relevant on this controversial issue of step geometry for dwellings. /f the Code is not going to be adopted, and if other codes (such as the CABO/ICC One and Two-Family Dwelling Code and the BOCA National Building Code) also having the compromise 7 3/4 by 10 step geometry requirement are further compromised back to the o ld8 1/4 by 9 rule because of the selKsh political pressures from the NAHB and home builders generally, then the NFPA should maintain its purity, standards, and traditional position as standing above such socially irresponsible political compromises. Indeed, when I personally submitted a proposal (and fought the home builders through to a complaint, by NAHB, to the Standards Council) on the compromise 7 3/4 by 10 standard, I did so with the hope (shared by BOCA and CABO) that the homebuilders would at least agree to try the new step geometry standard to assess its effectiveness and acceptability within the marketplace. This compromise of what I knew about the need for the "7-11" step geometry and the need to try something new politically was a futile gesture on my part and on the part of many leaders in the model code community. The NAHB and homebuilders generally refused to go along with the new rule even through they had been disproporuonately prominent on the very committees who recommended the compromise rule (as on the BOCA Ad Hoc Committee on Stairway Safety). After my B2 years working on model codes and standards in the U.S., Canada and elsewhere, I am professionally offended by the irresponsible behavior of homebuilders on this crucial issue of home safety and usability. Increasingly the backward stance of homebuilders is only explainable by their apparent motivation to control regardless of the costs to society and to reasonable regulation of buildings. Thus it is time for NFPA and other socially responsible organizations to desist from cowtowing to the homebuilders and to stand up for what is right. Again, if "7-11" is not "righC as a long established minimum standard for stair safety and usability (a standard now going back nearly four decades), then it should be struck from the Life Safety Code and other codes wherever it is used. That is, if it is not technically justified, then it is not technically justified anywhere. However, it is the "7-11" that is best justified by research and which has been recommended by researchers for dwellings since the mid 1970s. After two and a half decades, perhaps it is time for the Life Safety Code to take note of its own long-standing reliance on the "7-11" standard and the wealth of technical backing for it, and to establish the "7-11" as the minimum standard for exactly the situations where it is most needed-- in dwellings.

Finally, to rebut the argument that the better step geometry is justified where there are crowds to be evacuated in emergencies as opposed to small numbers of people in dwellings, it should be absolutel}t clear that the researchers most skiiledin issues of safe and eflioent crows movement (notably Dr. John Fruin, Dr. John Templer, Dr. John Archea, andJake Pauls) all are on record--in writing--as advocating the "7-11 as the minimum standard for dwelling unit stairs just as for other stairs. This reflects the greater exposure to stair fall risks on home stairs and the greater vulnerability due to demographics and use conditions in dwellings including the more rapid egress/escape that must occur in dwellings where desperately little time is available in fire emergencies. Notably speed of movement on stairs is a factor in falls (whereas, on heavily used public stairs where there is a high degree of fire protection features, crowd movement in egress

occurs most efficiently at relatively slower speed--because flow is the product of speed and density with speed varying inversely with density).

Ah, a in, as noted above, there is a wealth of published information avatlable on this issue. This comment can only show the tip of the iceberg both for technical aspects and political aspects. NFPA's credibility as a past, present and future leader in building safety is at stake here as ispublic health, safety and welfare. Refusal of the NFPA Life Safety Code committees (both Means of Egress and Residential) to deal with this will almost certainly lead to this issue going before the NFPA membership as well as being featured in current and future considerations by the public health community of the role of codes and standards in public health generally.

Postscript. It should be noted that the recendy published NFPA 101B includes the 7 3/4 by 10 requirement as Exception No. 2 to Table 3-2.Z2.1 Stair Criteria. I serve as a member of the Means of Egress Committee which is largely responsible for this standard however, it should be noted that I proposed the "7-11" standard and argued for it despite not being able to attend either the last committee meeting before its publication or the 1998 Fall Meeting where it was approved. In both cases, there were prior commitments (to the Pacific Rim Conference of Building Officials where the paper (submitted with this comment) was presented and to the Annual Conference of the American Public Health Association for which I serve as the APHA representative to the ICC Industry Advisory Committee). Of course I did submit a negative ballot on the matter and would have taken this issue to the floor of the 1998 Fall Meeting had there not been the unfortunate scheduling conflict.

Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE ACTION: Accept. COMMITTEE STATEMENT: The SAF-MEA Committee was asked to act on this comment, in addition to the action taken by SAF- RES. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BROWN: My main concern is that this Comment was not based

on a proposal that was before the Technical Committee on Means of Egress. Of concern is also the fact that the proponent 's proposal was not associated with the code secuon his comment addressed.

The original proposal submitted to the Technical Committee on Residential Occupancies addressed Section 21-2.5.1 Exception #2. This was the proposal that was submitted prior to the closing date for proposals. Apparently, the proponent did not review his submittal for accuracy. He later claimed he erred in his proposal, and submitted a letter stating what he really wanted to address. The Technical Committee on Residential Occupancies discussed the original proposal, and also the additional information received after the closin~ date. The Technical Committee on Residential Occupancies rejected the proponent ' s proposal. The committee statement also noted it did not agree vdth the proponent on his additional information.

It appears, not able to persuade the Technical Committee on Residential Occupancies to change their minds, he submitted a comment to the Technical Committee on Means of Egress, which has no jurisdiction over modifications made by another technical committee as outlined in Section 1-3.8.

The Technical Committee on Residential Occupancies at their ROC meeting again upheld their original decision not to accept the proponent 's proposal or comment. Their statement "No new information has been presented that would connect the accident statistics direcdy to stair geometry ~ is accurate. I fully agree with this conclusion. When you try to associate the proponents vast compilation of submitted data with his reasoning, there is no conclusion. There is no bottom line.

(Lo 8 #68) Committee: SAF-RF_.~

10b 399 - (21-2.6 Exception): Accept in Principle SUBMYFTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-615 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES substantiate the technical change that resulted from replacing the word "existing"

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with the word "previously." This has the effect of imposing a new requirement retroactively - but without substantiation. By current code language, the hallway only needs to be existing and receive approval; the new wording requires that the AHJ must have previously approved the existing hallway (i.e., no new approvals of existing features). SUBSTANTIATION: See the above recommendation. COMM1TFEE ACTION: Accept in Principle.

[ Reject the Proposal. COMMITFEE STATEMENT: Upon further review the committee agrees with the TCC. It is not the intent of the committee to change this provision in this manner. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 22 NOT RETURNED: 2 Kelly, Oneisorn

(Log #1 ~2) Committee: SAF-RES

101- 400 - (21-3.$.1): Reject SUBMITTER: John W. Hallman lII, Norfolk Naval Base Fire Dept. COMMENT ON PROPOSAL NO: 101-617 RECOMMENDATION: Move (c) to (d); and add new (c):

(c) In each sleenin~ area hallway, odor to the first sleenin~ room door..

Exceotion: In existirm construction, smoke alarms may be permitted to be continued in use. SUBSTANTIATION: A smoke alarm placed in a hallway prior to the first bedroom door will provide earlier warning to occupants. Due to the expense of relocation, hard-wired smoke alarms shall be permitted to remain in place.

A smoke alarm placed on the "dead-end" end of a hallway allows the hallway to fill with smoke prior to the alarm sounding.

This section does not state a specific location to benefit the occupants. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: This section does state a specific location for the benefit of the occupants.

The criteria in the code and NFP,~ 72 provide adequate early warning for all occupants as currently written. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITrEE ACTION:



101- 401 - (21-3.4): Reject SUBMITEER= Frederick J. Benn, Advanced Automatic Sprinkler, Inc. COMMENT ON PROPOSAL NO: 101-621 RECOMMENDATION: I agree with the proposal as written. Fire sprinklers have been proven to save lives and property. SUBSTANTIATION: The Committee's Statement is at best flawed, smoke detectors have reduced fire deaths by 50 percent, but the approximate 5,000 deaths per year will not change until the next level of protection i.e., fire sprinkler systems are incorporated into one and two family homes. COMMITTEE ACTION: Reject. COMM1T~E STATEMENT: The Committee stands on its statement to Proposal 101-621. Furthermore the committee feels that if the previous level of detection is responsible for a 50 percent reduction, then the additional detection should produce even better results. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITFEE ACTION:


EXPLANATION OF NEGATIVE: GERDES: One and two-family dwelling units are America's fire

problem. The committee's belief that smoke detectors are the sole and total solution is misplaced. The model codes have had interconnected, battery back-up smoke detector requirements for 15 - 17 years. There is still significant life loss. Sprinkler protection is effective.

ISMAN: We are voting negatively on Comment 101-401 ( L o g #159), 101-402 (Log #207), 101-405 (Log #158), and 101-404 (Log #'245) because we believe that the time is right to install fire sprinkler systems in one and two family dwellings. While thousands of people die each year from fires in these occupancies, the Life Safety Code continues to allow these dwellings to be unprotected. Without fire sprinklers, Chapter 21 of the Life Safety Code is in conflict with the scope and purpose in Chapter 1. Smoke detection alone is insufficient for protecting occupants of the room of fire origin, even when they are not intimate with ignition. Fire sprinklers are the best, most reliable, most efficient tools for this purpose. COMMENT ON AFFIRMATIVE:

BROWN: The truth is that smoke alarm installed in residential occupancies save lives - - PERIOD. If all jurisdictions had mandatory requirements to require hard-wired, with battery back- up, interconnected smoke alarms in ALL existing residential dwellings, the death rate from fire incidences would be drastically lowered. The main problem with the statistics sighted when relating deaths in residential fires is the lack of data on when the dwelling unit was constructed. This directly relates to lives saved by smoke alarms. The advent of Model code requirements for fire blocking in balloon framing, the use of gypsum wall coverings, and most importantly, the installation of a full interconnected smoke alarm system has reduced the deaths in dwellings that have been constructed since 1982. If the incidents of fire death data can be associated by the year the dwelling was built, the rate of death would be shown to be sufficiently lower than homes and apartments built before the advent of these Model code requirements. This same type of fire death data has been shown in manufactured housing with a discernible decline for those units built after the use of the Federal Manufactured Housing Construction Safety Standards had been initiated. The California Building Industry Association (BIA) Technical Department recently concluded a study of fire deaths on California. This extensive study directly associates the actual date the residential unit was constructed to the rate of death. (A summary report is on file at NFPA).

PUHLICK: The following is my Comment on Affirmative: "There has not been any empirical data submitted which verifies

that casualties and /o r fatalities are occurring in one- or two-family dwellings which fully comply with the current requirements of the "code". Without such data, we do not know whether or not the additional cost associated with requiring automatic sprinkler protection in one- or two-family dwellings is warranted; nor do we know what, if any, "trade-offs" and /or exceptions are appropriate. ff casualties and /o r fatalities are occurring in structures whmh do not meet current mandates as published in the 1997 edition of the Life Safety Code (I suspect this is the case; there was discussion at the ROP meeting of a recently published study in California supporting this which is supposed to be distributed to committee members), the concentration should be put into compliance with the current regulations, not adding further regulation and mandates.

I continually hear undocumented "talk", within professional/trade organizations and at NFPA committee meetings, that maintenance of smoke detectors and smoke detection systems does not always happen, sometimes to the point where the detectors and /or systems are not operational (I believe this is substantiated by the fire reporting system reports). The point made here is that if.sprinkler systems are mandated, they have to be maintained to remmn operational, especially in areas which do not have any or an adequate public water supply. If we have a problem keeping code required items maintained and the lack of the maintenance is a contributing casualty/fatality factor in those buildings, let's seek enforcement of the current regulations and not add new regulations."

C (Log #207)

ommittee: SAF-RF~ 101- 402- (21-$.4): Reject SUBMITrER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-620 RECOMMENDATION: Reconsider the Committee Action and accept the proposal. SUBSTANTIATION: We agree with the submitters substantiation and the negative comments of committee members.

Affordable technology exists that can affect the fire death rates in one- and two-family dwellings. The results of this requirement will not be immediate to a large scale, but given time will see great

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results. The effects of this proposal cannot be realized until the provision is placed in the code. Jurisdictions who do not feel this

quirement is needed for their community can delete it during the adoption process. It is our understanding that many jurisdictions are waiting for a national code to require sprinklers so they do not have to fight the battle on a local level.

We are also disturbed by the fact that a committee member termed this proposal ridiculous. If Technical Committee members fail to take proposals seriously and belittle submitters the process suffers. The process provides all the opportunity to express their views on any subject.

This proposal has been before this technical committee many times over the years and is nothing new. As a matter of fact it came close to passing in the ROPfor the 1994 edition. COMMITFEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Comment 101-401 (LOg #159). NUMBER OF C O M M ~ MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMYITEE ACTION:


EXPLANATION OF NEGATIVE: GERDES: One and two-family dwelling units are America's fire

problem. The committee's belief that smoke detectors are the sole and total solution is misplaced. The model codes have had interconnected, battery back-up smoke detector requirements for 15 - 17 years. There is sdll significant life loss. Sprinkler protection is effective.

ISMAN: We are vodng negatively on Comment 101-401 (Log #139), 101-402 (Log #'207), 101-405 (Log #138), and 101-404 (Log #243) because we believe that the time is right to install fire sprinkler systems in one and two family dwellings. While thousands of people die each year from fires in these occupancies, the Life Safety Code continues to allow these dwellings to be unprotected. Without fire sprinklers, Chapter 21 of the Life Safety Code is in conflict with the scope and purpose in Chapter 1. Smoke detection alone is insufficient for protecting occupants of the room of fire origin, even when they are not intimate with ignition. Fire sprinklers are the best, most reliable, most efficient tools for thispurpose. COMMENT ON AFFIRMATIVE:

BROWN: See my Comment on Affirmative on Comment 101-401 (Log #139).


that casualties and /o r fatalities are occurring in one- or two-family dwellings which fully comply with the current requirements of the "Code". Without such data, we do not know whether or not the additional cost associated with requiring automatic sprinkler protection in one- or two-family dwellings is warranted; nor do we know what, if any, "trade-offs" and /or exceptions are appropriate. If casualties and /o r fatalities are occurring in structures which do not meet current mandates as published in the 1997 edition of the Life Safety Code (I suspect this is the case; there was discussion at the ROP meeting of a recendy published study in California supporting this which is supposed to be distributed to committee members), the concentration should be put into compliance with the current regulations, not adding further regulation and mandates.

I continually hear undocumented "talk", within professional/trade organizations and at NFPA committee meetings, that maintenance of smoke detectors and smoke detection systems does not always happen, sometimes to the point where the detectors and /o r systems are not operational (I believe this is substantiated by the fire reporting system reports). The point made here is that if sprinkler systems are mandated, they have to be maintained to remain operational, especially in areas which do not have any or an adequate public water supply. If we have a problem keeping code required items maintained and the lack of the maintenance is a contributing casualty/fatality factor in those buildings, let's seek enforcement of the current regulations and not add new regulations."


101- 403 - (21-3.5.2): Reject SUBMrITER: FrederickJ. Benn, Advanced Automatic Sprinkler, Inc. COMMENT ON PROPOSAL NO: 101-625 RECOMMENDATION: I agree with the proposal as written. Fire

nklers have been proven to save lives and property. TANTIATION: The Committee's Statement is at best flawed,

smoke detectors have reduced fire deaths by 50 percent, but the approximate 5,000 deaths per year will not change until the next level of protection i.e., fire sprinkler systems are incorporated into one and two family homes. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Comment 101-401 (Log #159). - NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMII~rEE ACTION:


EXPLANATION OF NEGATIVE: GERDES: One and two-fami!y dwelling units are America's fire

problem. The committee's behef that smoke detectors are the sole and total solution is misplaced. The model codes have had interconnected, battery back-up smoke detector requirements for 15 - 17 years. There is still significant life loss. Sprmkler protection is effective.

ISMAN: We are voting negatively on Comment 101-401 ( L o g #159), 101-402 (Log #207), 101-405 (Log #158), and 101-404 (Log #245) because we believe that the time is right to install fire sprinkler systems in one and two family dwellings. While thousands of people die each year from fires in these occupancies, the Life Safety Code continues to allow these dwellings to be unprotected. Without fire sprinklers, Chapter 21 of the Life Safety Code is in conflict with the scope and purpose in Chapter 1. Smoke detection alone is insufficient for protecting occupants of the room of fire origin, even when they are not intimate with ignition. Fire sprinklers are the best, most reliable, most efficient tools for this purpose.

LATHROP: If we seriously want to improve life safety in the long haul, we must address sprinklers in 1 and 2 family dwellings. If the adopting agency wants to remove it, so be it, but we should state what we feel is needed. COMMENT ON AFFIRMATIVE:

BROWN: See my Comment on Affirmative on Comment 101-401 (Log #159).


that casualties and /or fatalities are occurring in one- or two-family dwellings which fully comply with the current requirements of the "Code". Without such data, we do not know whether or not the additional cost associated with requiring automatic sprinkler protection in one- or two-family dwellings is warranted; nor do we know what, if any, "trade-offs" and /o r exceptions are appropriate. ff casualties and /o r fatalities are occurring in structures which do not meet current mandates as published in the 1997 edition of the Life Safety Code (I suspect this is the case; there was discussion at the ROP meeting of a recendy published study in California supporting this which is supposed to be distributed to committee members), the concentration should be put into compliance with the current regulations, not adding further regulation and mandates.

I continually hear undocumented "talk", within professional/trade organizations and at NFPA committee meetings, that maintenance of smoke detectors and smoke detection systems does not always happen, sometimes to the point where the detectors and /o r systems are not operational (I believe this is substantiated by the fire reporting system reports). The point made here is that if sprinkler systems are mandated, they have to be maintained to remain operational, especially in areas which do not have any or an adequate public water supply. If we have a problem keeping code .required items maintained and the lack of the maintenance is a contributing casualty/fatality factor in those buildings, let's seek enforcement of the current regulations and not add new regulations."

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101- 404 - (21-5.5.2): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-623 RECOMMENDATION: Accept proposal 101-625. SUBSTANTIATION: Smoke detectors alone are insufficient to handle America's fire problem. A true cost benefit analysis would show that sprinklers save money and lives over the long run. COMMNWEE ACTION: Reject. COMMITTEE STATEMENT: The submitter has provided no new information that addresses the committee statement on Proposal 101-623. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GERDES: One and two-fami!y dwelling units are America's fire

problem. The committee's behef that smoke detectors are the sole and total solution is misplaced. The model codes have had interconnected, battery back-up smoke detector rec~uirements for 15 - 17 years. There is still significant life loss. Sprmkler protection is effective.

ISMAN: We are voting negatively on Comment 101-401 ( L o g #139), 101-402 (Log #207), 101-405 (Log #138), and 101-404 (Log #243) because we believe that the time is right to install fire sprinkler systems in one and two family dwellings. While thousands of people die each year from fires in these occupancies, the Life Safety Code continues to allow these dwellings to be unprotected. Without fire sprinklers, Chapter 21 of the Life Safety Code is in conflict with the scope and purpose in Chapter 1. Smoke detection alone is insufficient for protectin~g occupants of the room of fire origin, even when they are not inumate with ignition. Fire sprinklers are the best, most reliable, most efficient tools for this purpose.

LATHROP: If we seriously want to improve life safety in the long haul, we must address sprinklers in 1 and 2 family dwellings. If the adopting agency wants to remove it, so be it, but we should state what we feel is needed. COMMENT ON AFHRMATIVE:

BROWN: See my Comment on Affirmative on Comment 101.401 (Log #159).

(Log #69) Committee: SAF-BCF

101- 405 - (Chapter 22, various references): Accept in Principle SUBMIT'IT_.J~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF substantiate the technical change that resulted from deletion of the word "existing" in 22-2.2.2. The deletion makes the code more lenient by permitting a new fire escape stair to serve as a primary means of escape- but without substantiating that change. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Reinsert the word "existing" in 22-2.2.2. C O ~ STATEMENT: In this case the word "existing" is necessary. Its removal would make the requirement more lenient. This was not the intent of the committee. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 406- (22-1.2): Accept in Principle SUBMITFER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 1-01-627 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-HEA, which has

mAary responsibility for the health care occupancy provisions of 101, review Exception No. 2 to 22-1.2.1 of Proposal 101-627

for correlation and technical nature. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

No further action needed.

COMMITTEE STATEMENT: Action by the SAF-BCF Committee reverts the text to that in the 1997 edition of the Code. As such, no conflict exists. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 17 NOT RETURNED: I Crowley


101- 407- (22-1.2): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-627 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF give consideration to Mr. Lathrop's comment on affirmative so as to coordinate this change with SAF-HEA. It reads:

LATHROP: Although I concur with the proposal and the Committee action, the substantiation only addresses 22-1.2.2 and 22-1.2.5. The new Exception No. 2 is not addressed in the substantiation. This needs to be coordinated with SAF-HEA. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

I Delete 22-1.2.1 Exception No. 2. Renumber Exception No. 3.

COMMITTEE STATEMENT: Upon further review of the requirements for health care occupancy construction there is an extremely limited number of occurances when this exception would be applicable.

The committee does not feel it has been technically justified to have an exception that addresses such rare occurances. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON CO MITrEE ACTION:

AFFIRMATIVE: 16

(Log#71) Committee: SAF-BCF

101- 408- (22-2.$.1.1): Accept in Principle SUBMITIT.R: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-644 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF give consideration to Mr. Groner 's comment on affirmative so as to avoid confusing the issue. It reads:

GRONER: I agree with the substantiation, but the resulting wording is confusing and requires editorial modification. I suggest the following:

Revise: "Vertical openings shall be considered protected ff the opening is cut off by smoke nartitions in accordance with 6-2.4 . . . . . . . . . . . . . . . r . . . . . . . . . . r.-.+.~ . . . . . . . . . . from one story to any primary means of escape on another story," to read follows:

"Vertical openings shall be considered protected if the opening is cut off by smoke partitions in accordance with 6-2.4 ouch- that

prevent the passage of smoke from one story to any primary means of escape on another story." SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise 22-2.5.1.1 as follows: Vertical openings shall be considered protected if ~ d ~

~.pca'=g ": ~- t ~ffby smoke vartitions in accordance with 6-2.4 such-that 4~aia4e*s prevent the passage of smoke from one story to any primary means of escape on another story. COMMITTEE STATEMENT: The Committee agrees with Mr. Groner's comments and made a further editorial revision. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16

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101- 409 - (22-2.3.4.5 and 22-5.5.4.7): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-649 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise the wording for consistency with respect to the use of the term "smoke alarm." For example, the word "detectors" appears three times in 22- 2.$.4.3.1 and its exception. SUBSTANTIATION: See the above recommendation." COMMITTEE ACTION: Accept in Principle.

Revise text to read: "Approved :m~ke a-.etectc~ ~:.:gle : ~ 2 v ~ smoke alarms shall be

provided in accordance with 7-6.2.10. :Deteeto~Smoke alarms shall be installed on all levels, including basements, but excluding crawl spaces and unfinished attics. Additional d ~ - t o n v s m o k e alarms shall be installed for all living areas as defined in Section $-2."

Exception: Detec-to~ Smoke alarms shall not be required in buildings protected throughout by an approved, automatic sprinkler system installed m accordance with 22-2.$.5 using quick response or residential sprinklers. COMMITTEE STATEMENT: Change is necessary for consistency. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 410 - (22-2.$.5.1 Exception No. 1): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-654 RECOMMENDATION: Reconsider the Committee Action and accept the proposal. SUBSTANTIATION: We agree with the negative comments of Mr. Gardner. Conversion of these facilities should be no different that any other occupancy. This provision also provides a loophole for operators to construct a new one- and two-family dwelling and converting it to a small facility without the protection required by Chapter 22. COMMITTEE ACTION: Reject. COMMITIT~ STATEMENT: The committee does not feel that this action is necessary. The committees action change makes the current code more stringent than the previous edidon. Furthermore, the code would not permit the scenario that is presented by the submitter. Under 22-1.1.$ a conversion can only apply to a change from an existing residential or health care occupancy. The definition of "existing" in Chapter 5 would not permit a newly built residential occupancy to be considered existing immediately upon completion. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITI'EE ACTION:


EXPLANATION OF NEGATIVE: GARDNER: I stand by my "Explanation of Negative" as it appears

in ROP 101-654. Additionally, the committee statement from the ROC is flawed because the Committee states that the definition of "existing" in Chapter $ would not permit a newly built residential occupancy to be considered existing immediately upon completion. Although this may be true - the Committee's flaw is exposed in a situation where the conversion takes place some time after ~immediately upon completion." As a group of fire protection professionals, if we truly want top ro tec t persons in sleeping occupancies from fire (where NFPA fire statistics show the greatest loss of life) then we must require the affordable, practical, and cost effective protection provided by NFPA 15D sprinkler systems.

sprinklers. This presents a technical change that SAF-BCF didn ' t expect and, therefore, d idn ' t address in the substantiation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

I Add a sentence to Exception No.1 and 2 as follows: ] ~Door closin¢ shall be reCulated by 22-2.$.6.4."

COMMITTEE-STATEMEI~T: This a ~ o n clarifies the intent of the committee that the door closing requirements for board and care occupancies are different than those established in Chapter 6 for smoke partitions. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 412 - (22-$.$.6.$ Exception): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-677 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise wording to clarify that door closers are permitted to be omitted as has traditionally been allowed via Exception No. 2 to 22-$.$.6.6. By making compliance with new 6-2.4 a condition of an exception, new 6-2.4.$ will require door closers regardless of the presence of sprinklers. This presents a technical change that SAF-BCF didn ' t expect and, therefore, d idn ' t address in the substantiation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Add a sentence to the exception as follows: "The vrovisions of 6-2.4.$.5 shall not anvlv."

COMMITTEE STATEMENT: This action clarifies the intent of the committee that the door closing requirements for board and care occupancies are different than those established in Chapter 6 for smoke partitions.

The reference to 6-2.4.5.5 is the result of CG#500 that editorially reorganized 6-2.4.5 regarding doors in smoke partitions. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMI1~rEE ACTION:

AFFIRMATIVE: 16


101- 415- (22-5.5.6.5): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-681 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise wording to clarify that door closers are permitted to be omitted as has traditionally been allowed via Exception No. 2 to 22-5.3.6.6. By making compliance with new 6-2.4 a condition of 22-5.$.6.5, new 6-2.4.5 will require door closers regardless of the presence of sprinklers. This presents a technical change that SAF-BCF didn ' t expect and, therefore, d idn ' t address in the substantiation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Add a sentence to the paragraph as follows: "The provisions of 6-2.4.5.5 shall not apply."


The reference to 6-2.4.5.5 is the result of CC,#500 that editorially reorganized 6-2.4.5 regarding doors in smoke partitions. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 411 - (22-2.3.6.1 Exception No. 1 and 2): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-665 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise wording to clarify that door closers are permitted to be omitted as has traditionally been allowed via the Exception to 22-2.5.6.4. By making compliance with new 6-2.4 a condition of an exception, new 6-2.4.5 will require door closers regardless of the presence of


101- 414 - (22-7.5.2): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-691 RECOMMENDATION: The Technical Correlating Committee on Safe~ to Life (SAF-AAC) requests that SAF-BCF change the wording in two places f rom%moke detector(s)" to "smoke alarm(s)" for co-ordination with SAF-BCF action on Proposal 101- 649.

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SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise Exception to read as follows: "Upholstered furniture belonging to the resident in sleeping

rooms, provided that a smoke M a r m ~ is installed in such rooms. Battery-powered single-station smoke a la rmsd~ ,~4o~ shall be permitted." COMMITI'EE STATEMENT: Correlation with SAF-BCF action on Proposal 101-649. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 415 - (22-7.5.3): Accept in Principle SUBM1TrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-692 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF change the in two places from "smoke detector(s)" to "smoke alarm(s)" for coordination with SAF-BCF action on Proposal 101-640. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Principle.

Revise to read as follows: "Mattresses belonging to the resident in steeping rooms~ provided

that a smoke ~ a r m ~ is installed in such rooms. Battery- powered single-station smoke a l a r m s ~ shall be permitted." COMMITTEE STATEMENT: Correlation with SAF-BCF action on Proposal 101-649. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 416 - (Chapter 23, various references): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-693 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF substantiate the technical change that resulted from deletion of the word "existing" in 25-2.2.2.1. The deletion makes the code more lenient by permitting a new fire escape stair to serve as a primary means of escape - but without substantiating that change. SUBSTANT'IATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

] Reinsert the word "existing" into 25-2.2.2.1. COMMITTEE STATEMENT: In this case the word "existing" is necessary. Its' removal would make the requirement more lenient. This was not the intent of the committee. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 16


101- 417- (25-1.2): Accept in Principle SUBMITrER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-696 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-HEA, which has primary responsibility for the health care occupancy provisions of NFPA 101, review Exception No. 2 to 25-1.2.1 of Proposal 101-696 for correlation and technical nature. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

No further action needed. COMMrFrEE STATEMENT: Action by the SAF-BCF Committee reverts the text to that in the 1997 edition of the Code. As such, no conflict exists. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 418- (25-1.2): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-696 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF give consideration to Mr. Lathrop's comment on affirmative so as to coordinate this change with SAF-HF~ It reads:

LATHROP: Although I concur with the proposal and the Committee action, the substantiation only addresses 22-1.2.2 and 22-1.2.3. The new Exception No. 2 is not addressed in the substantiation. This needs to be coordinated with SAF-HEA. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Prindple.

] Delete 23-1.2.1 Exception No. 2. [ Renumber Exception No. 3.

COMMITTEE STATEMENT: Upon further review of the requirements for health care occupancy construction there is an extremely limited number of occurances when this exception would be applicable.

The committee does not feel it has been technically justified to have an exception that addresses such rare occurances. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTEz 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 419- (25-2.3.1.1): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-707 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF give consideration to Mr. Groner's comment on affirmative so as to avoid confusing the issue. It reads:

GRONER: I agree with the substantiation, but the resulting wording is confusing and requires editorial modification. I suggest the following:

Revise: Wertical openings shall be considered protected if the opening is cut off bv smoke partitions in accordance with 6.2.4 . . . . h .t.~+ 1..~: . . . . . . . . . . . ,~. . . . . . . . . .~f 3:'...Okc from one story to any primary means of escape on another story," to read follows:

Wertical openings shall be considered protected if the opening is cut off by smoke partitions in accordance with 6-2.4 ~ that

prevent the passage of smoke from one story to any

g rimary means of escape on another story. ~ UBSTANTIATION: See the above recommendation.

COMMITTEE ACTION: Accept in Principle. I evise 23-2.3.1.1 as follows:

"Vertical openings shall be considered protected if ~¢4h~:it£~ ~he opc~'.'ng "~ cut offby smoke oartitions in accordance with 5-2.4 sac-h- that 4~m=r4e,s prevent the passage of smoke from one story to any primary means of escape on another story." COMMITrEE STATEMENT: The Committee agrees with Mr. Groner's comments and made a further editorial revision. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 420 - (25-2.$.4.$, 25-3.$.4.2 Exception to (d), and 23-$.$.4.5): Accept in Principle SUBMITrER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-711 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise the wording for consistency with respect to the use of the term "smoke alarm." For example, the word detectors" appeaxs two times in 25-2.$.4.3 and the exception. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise 25-2.8.4.8 and A-25-2.3.4.3 and 23-3.$.4.5 Exception No. 1 as follows:

23-2.3.4.3* Smoke : D e t e e t o ~ a r m s . Approved smoke de tee to~ alarms shall be provided in accordance with 7-6.2.10. These detec-to~ alarms shall be powered from the building electrical system and, when activated, shall initiate an alarm that is audible in

I sleeping areas. ~ ~ shall be installed on all levels, including basements, but exduding crawlspaces and

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unfinished attics. Additional de tee to~smoke alarmsshall be installed for living rooms, dens, day rooms, and similar spaces.

Exception No. 1: Buildings protected throughout b~t an approved, automatic sprinkler system installed in accordance wzth 25-2.$.5 using quick response or residential sprinklers with approved, single-station smoke de t ee to~ alarms installed in each sleeping room ifi accordance with 7-6.2.10 and powered by the building electrical system.

Exception No. 2: Buildings protected throughout b~ an approved, automatic sprinkler system installed in accordance v~th 25-2.3.5 using quick response or residential sprinklers with existing battery- powered de tee to~smoke alarms in each sleeping room and where, in the opinion of the authority having jurisdiction, the facility has demonstrated testing, maintenance, and a battery replacement program that ensures the reliability of power to the detectors alarms.

A-23-2.3.4.3 Most often deteetem smoke alarms sounding an alarm at 85 d.BA or greater, installed outside the bedroom area, will meet the intent of this requirement. Detee to~ Smoke alarms remotely located from the bedroom may not be loud enough to awaken the average person. In such cases, it is recommended that de tee to~smoke alarmsbe interconnected so that the activation of

I any d~toc-tor~ smoke alarmswill cause all d ~ , t ~ o ~ alarms to alam~ acti~te.

23-3.3.4.5 Exception No. 1: Existing battery-opecated alarms, rather than building electrical service-powered alarms, shall be accepted where, in the opinion of the authority having jurisdiction, the facility has demonstrated testing, maintenance, and battery replacement programs that ensure the reliability of power to the detectors. COMMITrEE STATEMENT: The Committee has identified these references and changed them accordingly. NUMBER OF COMMrFFEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 421 - (25-2.3.6.1 Exception No. 1 and 2): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-716 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise wording to clarify that door closers are permitted to be omitted in sprinklered buildings as has traditionally been allowed via the Exception to 25-2.3.6.4. By making compliance with new 6-2.4 a condition of an exception, new 6-2.4.3 will require door closers regardless of the gresence of sprinklers. This presents a technical change that SAg

CF didn ' t expect and, therefore, d idn ' t address in the substantiation. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Principle.

Add a sentence to Exception No.1 and 2 as follows: "Door closing shall be regulated bv 25-2.3.6.4."

COMMITTEE STATEMEIqT: This action clarifies the intent of the committee that the door closing requirements for board and care occupancies are different than those established in Chapter 6 for smoke partitions. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 422 - (23-3.3.4.3): Accept in Principle SUBMITI'ER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-719 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF add for the ROC a statement similar to the committee statements in the ROP for Proposals 101-710 and 101-674 which explain that positive alarm sequence was considered but found to be inappropriate for board and care occupancies. Without such statement, the committee action of Accept on Proposal 101-719 is ambiguous with respect to what to do on the subject of positive alarm sequence as introduced in the recommendation from SAF-BSF. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Retain Committee Proposal 101-719.

COMMITrEE STATEMENT: The committee accepts the change proposed in Committee Proposal 101-719. However after considering the use of positive alarm sequence and its inherent delay in occup.ant notification, it was determined that these systems are inappropriate for board and care facilities. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16

(Lo~#84) Committee: SAF-BCF

101- 423 - (23-3.3.6.3 Exception No, 1 and 2): Accept in Principle SUBMITrER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-726 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise wording to clarify that door dosers are permitted to be omitted as has traditionally been allowed via Exception No. 2 to 23-3.3.6.6. By making compliance with new 6-2.4 a condition of an exception, new 6-2.4.3 will require door closers regardless of the presence of sprinklers. This presents a technical change that SAF-BCF didn ' t expect and, therefore, d idn ' t address in the substantiation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Add a sentence to the exceptions as follows: "The prgvi~igns of 6-2.4.3.5 shall not apply."


The reference to 6-2.4.3.5 is the result of CC#500 that editorially reorganized 6-2.4.3 regarding doors in smoke partitions. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 16


101- 424 - (23-3.3.6.4 Exception No. 3): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-727 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revise wording to clarify that door closers are permitted to be omitted in sprinklered buildings as has traditionally been allowed via Exception No. 2 to 23-3.3.6.6. By making compliance with new 6-2.4 a condition of an exception, new 6-2.4.3 will require door closers regardless of the presence of sprinklers. This presents a technical change that SAF- BCF didn ' t expect and, therefore, d idn ' t address in the substantiation. SUBSTANTIATION: See the above recommendation. COMMITI'EE ACTION: Accept in Principle.

Add a sentence to the exception as follows: "The nrovisions of 6-2.4.3.5 shall not apply."


The reference to 6-2.4.3.5 is the result of CC#500 that editorially reorganized 6-2.4.3 regarding doors in smoke partitions. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 16


101- 425 - (23-3.3.6.5): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-728 RECOMMENDATION: The Technical Correlating.Committee on Safety to Life (SAF-AAC) requests that SAF-BCF revue wording to clarify that door closers are permitted to be omitted in sprinklered buildings as has traditionally been allowed via Exception No. 2 to 23-3.3.6.6. By making compliance with new 6-2.4 a condition of an exception, new 6-2.4.3 will require door closers regardless of the

esence of sprinklers. This presents a technical change that SAF- d idn ' t expect and, therefore, d idn ' t address in the

substantiation. SUBSTANTIATION: See the above recommendation.

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N F P A 1 0 1 - - F 9 9 R O C

COMMIT1T~ ACTION: Accept in Principle. I Add a sentence to the exception as follows: [ "The provisions of 6-9.4.3.5 shall not apply."

COMMITTEE STATEMENT: This action clarifies the intent of the committee that the door closing requirements for hoard and care occupancies are different than those established in Chapter 6 for smoke partitions.

The reference to 6-2.4.3.5 is the result of CC#500 that editorially reorganized 6-2.4.3 regarding doors in smoke partitions. NUMBER OF COMMITTEE MFaMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMr[TEE ACTION:

AFFIRMATIVE: 16


101- 426 - (23-7.5.2): Accept in Principle SUBMITFER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-730 RECOMMENDATION: The Technical Correlating Committee on Safe~ to Life (SAF-AAC) requests that SAF-BCF change the wording in two places from "smoke detector(s)" to "smoke alarm(s)" for co-ordination with SAF-BCF action on Proposal 101- 711. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

I evise exception to read as follows: "Upholstered furniture belonging to the resident in sleeping

rooms, provided that a smoke ~a rm deteetor- is installed in such rooms. Battery-powered single-station smoke a l a rmsde tee to~ shall be pe rmi t t edf COMMITTEE STATEMENT: Correlation with SAF-BCF action on %101_711

OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITrEE ACTION:

AFFIRMATIVE: 16


101- 427 - (23-7.5.3): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-731 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BCF change the in two places from "smoke detector(s) ~ to ~smoke alarm(s)" for coordination with SAF-BCF action on Proposal 101-711. SUBSTANTIATION: See the above recommendation. COMMITFEE ACTION: Accept in Principle.

Revise to read as follows: ~dattresses belonging to the resident in sleeping rooms, provided

that a smoke ~a rm deteetor- is installed in such rooms. Battery- powered single-station smoke a l u m s de t ee to~ shall be permitted." COMMITTEE STATEMENT: Correlation with SAF-BCF action on Proposal 101-711. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16


101- 428 - (Chapter 24): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: f01-732 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER clarify what, if anything, is to be done to the wording of 24-1.7(a) given that Proposal 101-738 is replacing all the 24-1.7's with a reference to the new Table 5-3.1.2. It appears that there will be no 24-1.7(a) to modify. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

No further change is needed. COMMITIT~ STATEMENT: The recommendation of Proposal 101-738 is the action which the committee prefers. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 429 - (Chapter 24): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-733 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that S AF-MER clarify if it intended to insert the word supervised in Exception No. 3 to 24-3.6.1 so as to read: "...an approved, supervised automatic sprinkler system.. 7. It appears, from the fourth sentence of the substantiation, that such rewording was intended because the wording is "part of a condition of an exception." SUBSTAHTIATION: See the above recommendation. COMMITIT.E ACTION: Accept in Principle.

Revise 24-3.6.1 Exception No. 3 to read: Exception No. $ Corridors shall no t be required to have a fire

resistance rating within buildings protected throughout by an approved, supervised automatic sprinkler system in accordance with Section %7. COMMrITEE STATEMENT: The Commi~ee concurs with the suggestion of the TCC note. NUMBER OF COMMrVrEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


(Log #CCA52) Committee: SAF-MER

101- 430 - (24-1.1.2): Accept SUBMITTER: Technical Committee on Mercantile and Business Occupancies COMMENT ON PROPOSAL NO: 101-732 RECOMMENDATION: Revise the following paragraphs by replacing "stores" with "mercantile occupancies ~ or "tenant space"

24-1.1.2 This chapter establishes life safety requirement; for all new mercantile bnilding~ Specific requirements for suboccupancy groups such as Class A, Class B, and Class C mercantile occupancy stores, covered malls, and bulk merchandising retail buildings are contained in paragraphs pertaining thereto.

24-2.5.6 In Class A mercantile occupancies stores, at least one aisle of 5 ft (1.5 m) minimum width shall lead directly, to an exit.

24-2.5.10 Exit access in Class A and Class B mercantile occupancies stores that are protected throughout by an approved, supervised automatic sprinkler system and exit access in all Class C mercantile occupancies stores shall be permitted to pass through storerooms, provided the following conditions are met:

(a) Not more than 50 percent of exit access shall be provided through the storeroom.

(b) The storeroom shall not be subject to locking. (c) The main aisle through the storeroom shall be not less than

44 in. (112 cm) wide. (d) The path of travel, defined with fixed barriers, through the

storeroom shall be direct and continuously maintained in an unobstructed condition.

A-24-2.2.7 Exception To design egress from a covered mall building, the following steps should be used: (1) The covered mall /pedestr ian way has been assigned no occupant load, but it must be provided with means of egress sized to accommodate tl3e total occupant load of the covered mall building based on the gross leasable area. The exits for the covered mall /pedestr ian way can be provided by a combination of exterior exit doors and exit passageways. (2) After completion of step (1), each tenant space (i.e., store) is to be judged individually for occupant load and egress capadty. This step normally sends some portion or all (per 24-4.4.2.2) of the tenant space store s occupant load into the covered mall and any remaining occupants through the back of the tenant space store into an exit passageway that may serve multiple tenant space stores and the covered mall. (3) The exit passageway must be sized for the most restrictive of the following conditions: (a) Minimum 66 in. (168 cm) per 24-4.4.1 Exception (b), or (h) The pprtion of the egress capacity from the largest single tenant space store being served by the exit passageway, or (c) The portion of the egress capacity from the covered mall being

I provided by the exit passageway. The concepts used in the above steps include the following: (1) After proper egress capadty is provided for the covered mail/pedestrian way, each tenant space store must then independently provide egress capacity for its occupants. (2) The covered mall and the tenant space store's required exit passageway width need not be added together.

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($) The required exit passageway width for a tenant space store need not be added to that of other space stores using the same exit passageway.

A-24-4.4.1 Exception (b) The minimum requirement for terminating mall exit access in no t less than 66 in. (168 an) of exit width relates to the minimum requirement for at least one aisle in Class A mercantile occupancies stores [30,000 ft2 (2,800 m2) or greater sales area] to be 5 ft (152 cm) in width.

A-24-4.4.2.3 It is not the intent of this paragraph to require that large tenant spaces stores be considered anchor stores. A tenant space store not considered in determining the occupant load of the mall must be arranged so that all of its means of egress will be independent of the covered mall. SUBSTANTIATION: These revisions are a continuation of the activity associated with the original Proposal 101-732 (Log #CP905). These represent those items that where not addressed in the original proposal. COMMITTEE ACTION: Accept. NUMBER OF COMMITIT, E MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 431 - (24-1.1.4, 25-1.1.4): Accept SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-734 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER clarify its intent by adding a second sentence to the new 25-1.1.4 to read: ~ / h e n a mercantile occupancy changes from a Class C to a Class A or B, or from a Class B to a Class A the provisions of Chapter 24 shall apply." This is requested for ease of use ~iven that a person dealing with a subclass change in an exisung building might not know to go to Chapter 24 (which applies to new construction) to find the wording of new 24-1.1.4. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept. Revise 25-1.1.4 to read:

25-1.1.4 When a mercantile occupancy changes from a Class A to a Class B or Class C, or from Class B to a Class C, the provisions of this chapter shall apply. When a mercantile occupancy changes from a Class C to a Class A or B, or from a Class B to a Class A, the provisions of Chapter 24 shall apply. NUMBER OF COMMrIR'EE MFaMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 432- (24-3.1 Exception No. 1 (d) ) : _ ~ . TCC NOTE: The Technical Correlating t3ommittee on ~atety to Life (SAF-AAC) directs that the action on this comment be changed to "Reject Proposal 101-741 ~ for correlation with the action by SAF-BSF on Comment 101-455 (Log #92) and the input receivedfrom the Technical Committee on Automatic Sprinklers via Comment 101-435 (Log #415) from its Chair. Also see Mr. Bush's Explanation of Negative associated with Comment 101-435 (Log #415). SUBMrlTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-741 RECOMMENDATION: Revise the wording of this Exception No. 1 (d) as follows:

(d) The draft stop and closely space sprinkler requirements of NFPA 15, Standard for the Installation of Sprinkler Systems, shall not be required for unenclosed vertical openings p.r, lXlfi.g~ idemified in (a), (b), m-~d- or (c). SUBSTANTIATION: The intent of this comment is to coordinate the wording of this exception with accepted Code language without changing the overall concept of this proposal. COMMITTEE ACTION: Accept. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: OSMAN: While I support the Committee Action on this item, it

should disappear if the action on Comment 101-435 (Log #415) is reversed.


101- 433 - (24-3.1 Exception No. 1 (d) (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-741 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the extinguishing systems provisions of NFPA 101, review the technical aspects and correlation issues of Proposal 101- 741 and provide input for consideration by SAF-MER at its ROG- preparation meeting. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Reject Proposal 101-741. COMMITTEE STATEMENT: Based on the comments from the chair of the Technical Committee on Automatic Sprinklers, there has been insufficient technical justification provided for permitting this change in system design. NUMBER OF COMMITFEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14


101- 454 - (24-3.1 Exception No. 1 (d) (New)): TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed to ~R.eject Proposal 101-741 ~ for correlation with the action by SAF-BSF on Comment 101-455 (Log #92) and the input received from the Technical Committee on Automatic Sprinklers via Comment 101-435 (Log #415) from its Chair. Also see Mr. Bush's Explanation of Negative associated with Comment 101-435 (L_~#415). ~UBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-741 RECOMMENDATION: The Technical Correlating Committee on Safety to L~f,e_ (SAF-AAC) requests that SAF-MER give consideration to Mr. Bush s conunent on affirmative for clarification purposes. It reads:

BUSH: While the concept for this proposed change is appropriate, the wording of the new (d) to Exception No. 1 to 24-3.1 should be modified as follows: The draft stop and closely spaced sprinkler requirement of NFPA 13, Standard for the Installation of Sprinkler Systems, shall not be required for unenclosed vertical openings idemifae~ge, i l n i K ~ in (a), (b), o r (c). SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-432 (Log #'201). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: OSMAN: While I support the Committee Action on this item, it

should disappear if the action on Comment 101.455 (Log #415) is reversed.

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101- 435 - (24-3.1 Exception No. 1 (d) (New)): I TCC NOTE: The Technical Correlating Committee on Safety to ] Life (SAF-AAC) directs that the action on this comment be [ changed to "Accept in Principle. Reject Proposal 101-741. ~ This is [ done for correlatton with the action by SAF-BSF on Comment 101- 1 433 (Log #92) and the input received from the Technical [ Committee on Automatic Sprinklers via Comment 101-435 (Log I #415) from its Chair. Also see Mr. Bush's Explanation of Negative [ associated with Comment 101-435 (Log #415).

SUBMITI'ER: John G. O'Neill, Gage-Babcock & Assoc. Inc. COMMENT ON PROPOSAL NO: 101-741 RECOMMENDATION: I recommend that the proposed text not be accepted and that direction be given to follow NFPA 13 since the issue affects the design and installation of the sprinkler system. SUBSTANTIATION: I serve as Chair of the Technical Correlating Committee on Automatic Sprinkler Systems (NFPA 13). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

The criteria for the draft stops and closely spaced sprinklers have been in NFPA 13 for many years and are based on the concern that heat from a fire close to an opening, but not in the opening, on a lower floor may cause sprinklers to open on upper floors. A full scale test program conducted over 30 years ago dealing with escalator openings supported this concern. The escalator type opening in a mercantile occupancy was certainly one of the conditions considered in developing the criteria_ The language in NFPA 13 regarding the exception was adopted in the 1987 edition when the sprinkler committee determined that such a risk would not apply to large openings such as in covered malls or atriums.

The only proposal or comment regarding these criteria received for 1999 edition a~plied to residential applications only, therefore, 1999 edition, as it w~ll be presented at the 1999 Annual Meeting, still contains the same text for the smaller openings. The Technical Committee on Installation Criteria will be directed to examine this issue again in the next cycle considering the recommendations and supporting information from the Committee on Safety to Life - Mercantile Occupancies. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee has reviewed the statements made by the submitter. The supporting documentation noted in the substantiation is over 30 years old and to the best of the committee's knowledge is misplaced and is not available for review. In general discussions it was noted that these tests were developed for a specific application or project. The committee believes that there has been significant activity since that time to permit the omission of draft stops. Some of the earlier editions of the model build codes have permitted openings in a building floor without draft stops. There has not been significant documentation to show that there was a problem associated with these installations.

The current exception for the omission of draft stops on large openings such as an atrium found in NFPA 13 was derived from the atrium provision found in NFPA 101. There was no documentation or research to show that the 1000 sq. ft with a 20 foot minimum dimension was chosen for a specific application to omit the draft stops. The 1997 edition of NFPA 101 has now eliminated the mimmum sizing requirements for an atrium. How will this effect the requirement that is currently found in NFPA 137 The committee recognizes that technolog~y and the type of sprinklers required to be installed have advanced significantly since the referenced test of 30 years ago. The installation of quick response sprinklers now should be reviewed as a posidve event and permit the omission of draft stops. Draft stops may have been required to be installed to assist in the collection of heat and speed the operation of standard sprinklers as it related to the opening in the floor with the technology and fire sprinklers of years gone by. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BUSH: The specification of design criteria for automatic

protection should be regulated by the Technical mmittee on Automatic Sprinkler Systems, and not by a

Technical Committee of the Life Safety Code. Where exceptions to such design criteria are deemed necessary, they should be forwarded to the appropriate Technical Committee for consideration, processing with opportunity for public comment, and inclusion as a part of the applicable design standard. Design details for automatac sprinkler systems within the Life Safety Code will lead to confusion and misapplication of the Standard for the

Installation of Sprinkler Systems as designers and installers of these systems may not routinely reference the Life Safety Code for all such requirements. Exceptions for the elimination of draftstops for unprotected vertical openings, a requirement of the Standard for the Installation of Spnnkler Systems, should be made only after the study of recent technical jnstiflcation, appropriate consideration, and proper documentation and coordination between the members of both technical committees, and not by simple elimination by only one of the technical committees concerned with a specific occupancy type.

OSMAN: No technical substantiation has been provided to allow this deviation from NFPA 13. At the request of the Correlating Committee the Technical Committee on Building Service and Hre Protection Equipment reviewed this proposed exception and developed the following Committee Statement: "Based on the comments from the chair of the Technical Committee on Automatic Sprinklers, there has been insufficient technical justification provided for permitting this change in system design."

This requirement has been in NFPA 13 for many years. It was stated in discussion at the mercantile and business committee meeting that many buildings have been erected without this protection. To legitimize buildings built in non-compliance with NFPA 101 and NFPA 13 is not a valid reason to change the code.

The chair of NFPA 13 stated in his substantiation that the Technical Committee on Installation Criteria will be directed to examine this issue again in the next cycle considering the recommendations and supporting information from the Committee on Safety to Life - Mercantile Occupancies. At the mercantile and business meeting a task group was organized to assist NFPA 13 in their study on draft stops.

Considering the length of time that this requirement has been in NFPA 13 and considering the lack of new technical data, it makes sense to allow time for the NFPA 13 Technical Committee on Installation Criteria and the mercantile and business task group complete their work and come back to NFPA 13 and NFPA 101 with proposals, if appropriate, for the next editions of these standards and codes. COMMENT ON AFFIRMATIVE:

SCHULTZ: My voted is affirmative on all items and I would like to add several comments in support of the Committee's Action on Comment 101-435 (Log #415) and 101-453 (Log #415a).

It must be noted that the full scale test program conducted over 30 years agogiven as the primary justification by the Technical Correlating Committee on Automatic Sprinkler Systems for the rejection of the proposed new code wording should not be considered as validjustiflcation based on the following.

There is considerable confusion about the testing that was done since no documentation is available. A representative from the firm that performed the fire test has indicated that the test was not a highly scientific test nor was it well documented. As explained to out committee, the 30 year ago test used a flammable liquid pan fire located adjacent to the escalator floor opening. The floor level the test was performed on and the number of stories connected by the escalator was unknown as well as the size of the escalator floor opening the size of fire and the location of the fire test pan to the escalator floor opening. There was also no knowledge regarding whether there was a stack effect condition.

When reviewing the old building code languages about escalator openings, there were discussions of creating down drafts in the escalator floor opening when a fire condition was detected. This is obviously a reflection of construction techniques where escalators serve a large number of floors. These type of conditions may justify the need for closely spaced sprinklers and draft stops as required by NFPA 13. However, in openings connecting three levels, such stack effects can not be expected and, therefore, can not be used to justify the need for closely spaced sprinklers and draft stops.

This same logic would seem to be consistent with the rationale submitted by the NFPA 13 Technical Committee on Automatic Sprinklers in 1982 on Proposal 1~-04-(4-4.8.2.4) when they included the exception for closely spaced sprinklers and draft stops around large openings in fully spnnklered buildings. The justification given by the committee was "SUBSTANTIATION: Fire experience does not indicate a need to use draft stops in combination with closely spaced sprinklers in fully sprinHered buildings."

It is also our committee's opinion that the fire experience available will not support the need for closely spaced sprinklers and draft stops for openings between three floor levels. Such protection may be appropriate when located in conditions where stack effect can realistically occur. It is well recognized that the degree of stack effect that can be generated by a floor opening communicatin~ two or three levels in buildings are not of the type that warrant this type of protection.

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(Log #CC551) Committee! SAF-MER

101- 456 - (24-3.1 Exception No. $): Accept I TCC NOTE: The Technical Correlating Committee on Safety to

Life (SAF-AAC) directs that the action on this comment be expanded so that the same reformatting be done to Exception No. $ to 25-3.1. Thus, the actions for both new and existing mercantile occupancies will be correlated. SUBMITrER: Technical Committee on Mercantile and Business Occupancies COMMENT ON PROPOSAL NO: 101-264 RECOMMENDATION: Reformat 24-3.1 Exception No.3 to read:

Exception No. 3: In Class A or Class B mercantile occupancies protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 7-7, unenclosed openings in accordance with 6-2.5.5 shall be permitted. SUBSTANTIATION: It was brought to the committee's attention that the proposed wording of the exception was not consistent with the phrasing used in other exceptions. The relocation of the requirement for protection throughout to the first part of the exception provides the needed clarification. COMM/TFEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


(Log #362b) Committee: SAF-MER

101- 437- (24-3.5.1, 25-3.5.1): Reject SUBMrI'I'ER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-264 RECOMMENDATION: Renumber existing 24-3.5.1 to 24-3.5.1.1 and relocate proposed 24-3.1 Exception No. 4 to a new 24-3.5.1.2.

Renumber existing 25-3.5.1 to 25-3.5.1.1 and relocate proposed 25-3.1 Exception No. 5 to a new 25-3.5.1.2. SUBSTANTIATION: It is bad Code language to write requirements by means of exceptions. These exceptions have been relocated to paragraphs which otherwise contain the requirements for the installation of sprinkler protection in these various occupancy types. All of the basic requirements for the installation of sprinkler protection should be located in a common section of the Code regardless of the the intent of installation requirements. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The action by the Committee on Comment 101-438 (Log #93) should satisfy the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101-438- (24-3.5.1 (d) Exception, 25-3.5.1(d) Exception, A-24-3.5.1 (d) and A-25-3.5.1 (d)): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-747 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER revise its action to: (1) address 25-3.5.1(d) for consistency with what it did to 24- 3.5.1(d), and (2) reformat 24-3.5.1/25-3.5.1 to avoid the lapse in parallelism that it created with the revised wording. Note that the lead-ins to 24-$.5.1 and 25-3.5.1 mention the sprinkler system that the revised (d) mentions again. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Reformat 24-3.5.1 (d) to read: (d) Throughout the building with mixed occupancies in

accordance with 4-1.12 when the conditions of (a), (b) or (c) apply to the mercantile occupancy. COMMITTEE STATEMENT: The reformatting of 24-3.5.1 (d) should satisfy the request of the TCC for parallelism. The committee does not want to add the same provision for 25-3.5.1 (d). This would require that the entire building to be protected throughout by a fire sprinkler system. The committee wishes not to apply this requirement retroactively as it would exceed those found currendy.

NUMBER OF COMMITI"EE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITI'EE ACTION:


19


101- 459 - (24-3.5.1(d) and 25-3.5.1 (d)): Reject SUBMI'Iq'ER: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-747 RECOMMENDATION: Reconsider the proposal with revisions that bring the language more into conformity with the action taken by the committee on proposal 101-257, on page 147 off the ROP. The revised proposed Exception to 24-$.5.1 (d) and 25-3.5.1(d), and an appendix note are shown below.

ProposedException to 24-3.5.1(d) and 25-$.5.1 (d), and for an A ~ e n d i x note to same:

ception to (d)*: For safety to life purposes, in shopping center buildings with multiple tenant spaces, but which are not covered mall buildings, and where each tenant space has independent means of egress as required for the occupancy classification of such space, the sprinkler protection requwements shall only apply to tenant spaces occupied by mercantile occupancies where the condition of (a), (b), or (c) are involved, provided, the mercantile occupancies required to be sprinkler protected are separated from other tenant spaces not otherwise required to be sprinkler protected by this Code or by another code by vertically aligned 2-hr or greater fire walls in accordance with NFPA 221, Standard for Fire Walls and Fire Barrier Walls.

A-24-3.5.1 (d) [A-25-3.5.1 (d) ] The fire wall rating of 2-hr is minimum for the protection of life and is not intended to replace more protective tenant or occupancy separation requirements of the applicable building code or other codes. The Exception to (d) shall not apply to covered mails or covered mall buildings as defined in this Code. The Exception does not replace or remove any requirement of this Code, or any other applicable code such as a building code, for automatic sprinkler protection for any other occupancy classification or sub-classification that may be located in the shopping center building. Each tenant space must comply with the reqmrements of this Code for the occupancy classification or sub-classification located therein. SUBSTANTIATION: Although the value of automatic sprinkler protection is clear with regard to property protection, its value from a safety to life from fire point of view is often not clear in certain occupancies such as small mercantile and small assembly occupancies. Even in shopping centers that are not covered mall buildings, sprinkler protection for safety to life purposes is often questionable in all tenant spaces where there are ample independent means of egress. There appears to be a need to provide an alternative to total sprinkler protection supported on safety to life reasons for shopping center buildings that are not covered mall buildings.

The proposal as revised would r eco~ ize unpenetrated fire walls having at least a 2 hr rating and meeung the provisions of NFPA 221, as a reasonable level of protection to life safety where mercantile or other occupancies are in tenant spaces that otherwise would not be required to have sprinkler protectaon, but which are located in shopping centers that are no t a part of a covered mall building, and where each tenant space has means of egress independent of others. The proposal would provide developers design options without increasing risks to life safety above that faced by occupants of free standing single tenant buildings. The proposal recognizes the exception would not be approprmte for covered mall buildings where occupants of tenant spaces may be more at risk from a fire in another space or in the mall. A drawing illustrating a simple example of the intent of the

proposal is also shown below. It is not intended that the drawing be included in the appendix note.

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z kmtt fu~ wltlla I , - 1 ] INo

NO'I'g: I~tcb tamm slm~ lu~ ~ m~am d ~ r t ~ at

Example of the intent of the proposed Exception to 24-3.5.1 (d) and 25-3.5.1 (d).

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The recommendat ion introduces some new terms which are not defined such as ~safety to life purposes" and "shopping center buildings ~. The separation recjuirements that establishes when there are two independent buddings is not addressed in this document. As noted in paragraph 1-2.7. the Life Safety Code does not at tempt to address those provisions which are normally a function of a building code. If the submitter is establishing conditions for defining separation requirements for mixed occupancies then it would be advisable that these recommendations should be made to 4-1.13. N U M B E R O F C o M M r l q ' E E M E M B E R S E L I G I B L E TO VOTE: 19 VOTE ON COMMITIT~E ACTION:



101- 440 - (24-3.5.$ and 25-$.5.2): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-748 RECOMMENDATION: Add a new Exception to these sections as follows:

"Extinguishers shall bepermi t t ed to be omitted in buildings protected by a supervisedantomatic sprinkler system in accordance with Section 7-7." SUBSTANTIATION: This seems to be a reasonable middle ground between the submitter's original suggestion and the committee statement in support of the rejection. Extinguishers shouldn' t be needed in fully sprinklered buildings. COMMITI'EE ACTION: Reject. COMMIq[q'EE STATEMENT: The committee recognizes the importance of having manual fire suppression capabilities within these facilities. It is noted that small incipient fires are easily controlled by manual fire suppression. In reports done by the NFPA Fire Analysis and Research Department it is noted that approximately 13 percent of nonresidential fires are extinguished by manual means of fire suppression. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMYFrEE ACTION:



101- 441 - (24-3.6.1 Exception No. 2 Exception No. 3, A-24-3.6.1 (New)): Accept SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-749 RECOMMENDATION: Retain existing 24-3.6.1 and Exception No. 1.

Revise Exception No. 2 to read: "Within a suace occunied bv a finale tenant,"

Revise Exception No. 3 to read: ~Within buildings protected throughout by an anvroved, sut)ervised automatic sDrinkler system in accordance with Section 7-7. -~

Add a new A-~4-$.6.1 as follows: ~The intent of Excention Nos. 2 and $ ~;q this paragraph is to hermit snaces within single tenant

I spaces, or within buildings protected throughout by an annroved supervised automatic sprinkler system to be open tO the exit access corridor without separation." SUBSTANTIATION: The intent of this proposal is to specify the Committee's intended level of protection required for corridor wall construction in single tenant spaces and in buildings with complete automatic sprinkler protection. The new Appendix Note seeks to further clarify the Committee's position that use areas may be open to the corridor without separation under certain conditions. In accordance with the proposed wording in the ROP, 26-$.6.1 would require the construcuon of these walls in accordance with the much more restrictive requirements for smoke barriers, which does not agree with the Committee Statement for this proposal. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE M E M B E R S E L I G I B L E TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 442 - (24-$.6.1 Exception No. 2, Exception No. $, and 24-3.6.$ (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-749 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) rec)uests that SAF-MER: (1) insert the word ~supervised" in Exception No. $ for consistency with other actions taken, (2) revise its action to clarify its intent given that the committee statement conflicts with the wording, of the revised exceptions, (5) give consideration to Mr. Bush s and Mr. Perry's explanations of negative, and (4) substantiate the technical change that was introduced by adding the words "separated from use areas" given that current language seems not to prohibit the corridor from being used, for example, as a security station complete with desk, chair and business machines provided that the necessary clear width is maintained for egress purposes. The new wordin~ will require use areas to be separated from the corridor - a technical change that has not been substantiated.

The referenced wording reads: BUSH: The proposed wording of the new Exceptions are not

consistent with the committee intentions noted as a part of the Committee Statement for this proposal. If the intent of these Exceptions is to permit corridor walls that are not fire rated or that do not resist thepassage of smoke in spaces occupied by a single tenant or in buildings protected throughout by an approved, automatic sprinkler system, reference should not be made to 6-2.4 which prescribes the requirements for smoke partitions, including self-closing or automatic-closing doors in openings therein.

The wording of the new Exceptions to 24-$.0.1 should be modified as follows:

Exception No. 2: Spaces occupied by a single tenant, c~=ri~.m

::=_%=7_~,~.~'L7." ~-'_~ "'~- :~= . ~ ^ ~ - ~ % \ Z ^ ~ 7 .~:,"~% " 7 ~ ~ c e p t i o n No. 3: Buildings protected througho t by an" ~ ""

.1 k 1! k approved, automatic sprinkler system~ cc.~.'_:=: -..a:. === ~=

PERRY: Mr. Bush is correct. My notes @ore the meeting indicate that the Committee intent was to revise the Exceptions as shown in Mr. Bush's negative comment.

As presented, the committee action presents an increase in the requtrements of the Code, by adding "shall be separated from use areas by partitions in accordance with 6-2.47 The Committee intent, as shown in the committee statement, was to clarify that such non-rated corridors are not required to resist the passage of smoke.

The committee action as origiuaUy published is in error, and should be revised as shown in Mr. Bush's comment. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-441 (Log #160). COMMrITEE STATEMENT: The Committee Action should meet the submitter's intent. NLrMBER O F COMMI'IqT~ MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMI'Iq'EE ACTION:


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101- 443 - (24-4.4.1 and 25-4.4.1 ): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-751 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) rec]uests that SAF-MER give consideration to the public comment that is expected to be received from a task

rOUp of the technical correlating committee. SAF-AAC has rmed a task group of representatives of SAF-AXM, SAF-END,

SAF-HEA, SAF-IND, SAF-MER and SAF-RES. The task group is charged with developing code provisions that address covered mall buildings that contmn multiple occupancies. Also, the task group is to consider whether the covered mall provisions - applicable to numerous occupancy types - should be positioned in Chapter 32 similar to those for other special conditions that involve more than one occupancy. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

See Committee Action on Comments 101-85 (Log #117) and 101- 444 (Log #116). COMMITI'EE STATEMENT: The Committee Action on these comments should fulfill the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITI'EE ACTION:



101- 444 - (24-4.4.1 and 25-4.4.1 ): Accept in Part TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the Committee Statement be revised to state that SAF-MER retained its earlier action from the ROP that it is not necessary to establish a threshold at which the gross leasable area (GLA) used by occupancies other than mercantile would be subtracted from the total GLA so as to require that mall egress for those other occupancies be based on the requirements apl~licable to those occupancies. By not changing its earlier ROP action, SAF-MER gave de facto reconfirmation to part 2 of the recommendation. The current Committee Statement is inaccurate. Also, it appears that SAF-MER meant to reference Comment 101-85 (Log#117), not Comment 101-466 (Log #107). SUBMITrER: James R. Quiter, RolfJensen & Assoc., Inc. COMMENT ON PROPOSAL NO: 101-751 RECOMMENDATION: 1. Revise the first sentence of 24-4.4.1 and 25-4.4.1 to read:

"24-4.4.1 The covered mall building shall be treated as a single building for the purpose of calculation of means of egress a n d shall be subject to the requirements for appropriate occupancies excent as modified bv the nrovisions of 24-4.4. The covered mall shall be at least of sufficient clear width...".

"25-4.4.1 The covered mall building shall be treated as a single building for the purpose of calculation of means of egress and -

I shall be subject to the requirements for appropriate occupancies excevt as modified bv the provisions of 25-4.4. The covered mall shall-be at least of sufficient clear width...".

2. Reconfirm the earlier ROP action that it is NOT necessary to establish a threshold at which the gross leasable area (GLA) used by occupancies other than mercantile would be subtracted from the total GLA so as to require that egress for those other occupancies be based on the requirements of the code chapters applicable to those occupancies. SUBSTANTIATION: I served as Chair of the Life Safety Covered Malls Task Group that was convened by the Technical Correlating Committee on Safety to Life. Task group participants, and the life safety technical committees represented by the participants, at the December 1998 meeting included myself--Jim Quiter (SAF-AAC), Jim Antell (SAF-HEA), Carl Baidassarra (SAF-RES), Greg Miller (SAF-AXM), Ed Schultz (SAF-MER), Cathy Stashak (SAF-END), Greg Thomas (SAF-IND), and Bill Hiotaky (former chair of SAF- MER). This proposal was drafted by the task group.

RE: Item (1) in the above recommendation. The additional wording recommended by this comment - and identical wording recommended in the first part of Proposal 101-751 - clarifies intent without making technical changes. It is the Code's intent that the provisions of 24-4.4 and 25-4.4 be applicable to covered malls regardless of whether occupancies in addition to the mercantile occupancy axe present. The new wording will help to accomplish the needed clarification. Without such wording, the trail from occupancy chapter to 24-4.4 and 25-4.4 is unclear.

A related comment has been submitted to the SAF-AXM committee requesting that Chapter 8 and Ompter 9 clarify that assembly occupancyprovisions apply to the assembly occupancy tenant space within the covered mall building, and that the provisions of 24-4.4 and 25-4.4 apply outside the assembly occupancy tenant space (i.e., within the covered mall).

RE: Item (2) in the above recommendation. The use of the gross leasable area (GLA) concept for sizing the means of egress for the covered mall typically will not result in inadequate capacity where large assembly occupancies reside in part of the covered mall building."

Consider the following examples. Example 1: A 5000-seat cinema complex (i.e., a large assembly

occupancy) is to be housed within a new covered mall building. The dnema seating area, lobby and circulation space will occupy 100,000 sq ft. The covered mall building will have 550,000 sq ft of GLA (450,000 sq ft for mercantile use and 100,000 sq ft for the cinema complex).

Using Figure 24-1.7.1 (g), the GLA of the cinema will require that the covered mall have sufficient egress capacity to accommodate 2000 persons from the 5O00-seat cinema (i.e., 100,000 sq ft/55 sq ft per person because the covered mall building's GLA exceeds 400,000 sq ft). Also, the covered mall must have adequate egress capacity for another 8180 persons due to the GLA associated with the mercantile areas (i.e., 450,000 sq ft/55 sq ft per person). Given the main entrance/exit requirement of Chapter 8, egress for half the cinema occupant load (i.e., 2500 persons) will be provided through doors directly to the outside or via exit passageways. If the cinema was occupied to 100 percent capacity, the other 2500 ,~lersons would be expected to use the covered mall as exist access.

though there might appear to a deficiency of 500 persons capacity, there are safeguards i n t h e system:

• Cinemas do not operate at 100 percent capacity. Management typically stops selling tickets at 80 percent capacity because the larger crowds make for inefficient access to the highly-profitable concession stands, thus reducing revenue. Yet the occupant load was established by counting all of the seats.

• The covered mall is required to have a fire alarm system, not the overall covered mall building. This requirement considers that it would be very unusual to evacuate the entire covered mall building due to a fire in either the covered mall or one of the tenant spaces. Thus, the covered mall egress capacity will not be fully utihzed simultaneously, although the covered mall has excess capacity that easily absorbs the cinema occupants not otherwise considered.

• If the number of persons entering the covered mall from the tenant space - for emergency egress - was more than that for which the covered mall's egress system was sized, it doesn't mean that those extra persons will be unable to leave the building. Rather, it means that it will take longer to discharge everyone to the outside. The requirements for sprinkler protection throughout the covered mall building and for smoke control within the covered mall, help to maintain tenable conditions to permit a longer egress time. The covered mall.provides for safe exit access similar to that provided within an atrium.

Example 2: A restaurant with an occupant load of 300 persons is to be located within a new covered mall building that has GLA of 200,000 sq ft. The restaurant's 300-person occupant load is derived by dividing the 4500 sq ft of NET area usable for patron standing and seating by the 15 sq ft per person occupant load factor characteristic of the assembly use. However, the restaurant occupies a total GLA of 6000sq ft.

Using Figure 24-1.7.1(g), the GLA of the restaurant will require that the covered mall have sufficient egress capacity to accommodate 150 persons from the 300-persons restaurant (i.e., 6000 sq ft/40 sq f t p e r person because the covered mall building's GLA is 200,000 sq ft). Also, the covered mall must have adequate egress capacity for another 4850 persons due to the GLA associated with the mercantile areas (i.e., 194,000 sq ft/40 sq ft per person). Given the main entrance/exit requirement of Chapter 8, egress for half the restaurant occupant load (i.e., 150 persons) will be provided through doors directly to the outside or via exit passageways. The other 150 persons would be expected to use the covered mall as exit access. This results in a perfect match between the 150 persons who egress from the restaurant into the covered mall and the 150 person egress capacity imposed on the covered mall based on the GLA of the restaurant. COMMITTEE ACTION: Accept in Part.

Accept the revisions to 24-4.4.1 and 25-4.4.1. COMMITIT~ STATEMENT: The committee accepts the revisions to the 24-4.1.1 and 25-4.4.1. The committee does not accept the position of reconfirmation as noted in the second part of the

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recommendation. Additional Committee Action can be found in Comment 101-466 (Log #107). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 445 - (24-4.4.3.1): Reject SUBMrlq'ER: Terry A. Brouwer, Waterford, CT COMMENT ON PROPOSAL NO: 101-752 RECOMMENDATION: Accept the revision as proposed for new covered mall buildings. SUBSTANTIATION: In the Committee's Statement for rejecting the proposal, they stated that adequate justification had not been provided to support the installation of an alarm system in an "existing" covered mall building. The proposal sought the requirement for both new and existing covered mall buildings. I beheve the rejection of the entire proposal was an oversight. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee reviewed this comment and wishes to maintain the current l?osition not to require this provision for new or existing fadhties. As proposed, this comment would require a fire alarm system to be installed throughout the covered mall building including individual tenant spaces. Currently, the design and arrangements of covered mall buildings, including the provisions for means of egress from individual tenant spaces, fire protection features for the covered mall, and overall s,ze and volume of the covered mall preclude the notification of the occupants within individual tenant spaces for emergency egress purposes. The means of egress from a covered mall building is developed using a two part concept, one that involves travel directly from the tenant space and one that involves travel through the covered mall. Since the covered mall is usually an open area which exposes all of the occupants to a single emergency incident, it is important to notify the occupants of that ~_~oaCe of a fire or other emergency to initiate egress or relocating.

wever, the concepts used in the construction, seperation, arrangements, and protection of the covered mall building preclude the need to evacuate the entire building.

It should also be noted that the requirements for the fire alarm installation within individual tenant spaces is regulated by other provisons of this chapter depending on the size of the sales space. The substantiation provided with the original proposal has not fully supported or has shown that the current requirement is inadequate based on the realization that these facilities are no t required to fully evacuated. NUMBER OF COMMrlqT, E MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BUSH: The Committee Statement has provided no substantial

Jthustitication for the lack of a requirement of fire alarm systems rougbout new covered mall buildings. While it is understood

that the retrofit of fire alarm systems in areas of existing covered mall buildings outside of the covered mall and not currently provided with a fire alarm system may not be cost effective, there appears to be adequate justification for the installation of such systems in new buildings. This is amplified by the fact that an alarm system is required to be installed in the covered mall area, and that the committee statement indicates that a part of the egress concept for these building, involves travel through the covered mall. Occupants of indiwdual tenant spaces should be provided with early notification of any threatening condition which may exist along their required path o f egress travel. The size and configuration of all tenant spaces may preclude the early warning of these occupants from notification appliances located only within the covered mall. In addition, since these tenant spaces are typically open to the covered mall without separation, any threatening condition within the tenant space must be immediately communicated to all of those occupying the exposed space. Where remote exits directly from the tenant space to the exterior are provided, or where travel to a fire alarm initiating device within the covered mall is blocked or impeded, the time to activate the alarm system and to provide appropriate notification to all covered mall building occupants may be delayed or never initiated.

£Lo~ #06) Committee: ~AF-MER

101- 446 - (24-4.4.3.1 and 25-4.4.3.1 ): Accept in Principle SUBMIT1T, R: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-752 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) reguests that SAF-MER add for the ROC a statement that expands the ROP's committee statement to explain why the recommended change was not made for Chapter 24 for new mall buildings. The current committee statement addresses only why the change was not imposed relroactively on existing mall buildings. SUBSTANTIATION: See the above recommendation. COMMITIT_,E ACTION: Accept in Principle.

See Committee Action on Comment 101-445 (Log #155). COMMITTEE STATEMENT: The Committee's substantiation to Comment 101-445 (Log #155) should fulfill the submitter's request. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 447- (24-4.4.~.3.1): Reject SUBMITTER: Terry A. Brouwer, Waterford, CT COMMENT ON PROPOSAL NO: 101-754 RECOMMENDATION: Accept the revision as proposed for new covered mall buildings. SUBSTANTIATION: In the Committee's Statement for rejecting the proposal, they stated that adequate justification had not been provided to support the installation of an alarm system in an "existing" covered mall building. The proposal sought the requirement for both new and existing covered mall buildings. I believe the rejection of the entire proposal was an oversight. COMMITTEE ACTION: Reject. COMMITIT, E S T A ~ : The Committee reviewed this comment and wishes to maintain the current position not to require this provision for new or existing facilities. As proposed, this comment would require a fire alarm system to be installed throughout the covered mall building including individual tenant spaces. Currently, the design and arrangements of covered mall buildings, including the provisions for means of egress from individual tenant spaces, fire protection features for the covered mall, and overall size and volume of the covered mall preclude the notification of the occupants within individual tenant spaces for emergency egress purposes. The means of egress from a covered mall building is developed using a two part concept, one that involves travel directly from the tenant space and one that involves travel through the covered mall. Since the covered mall is usually an open area which exposes all of the occupants to a single emergency incident, it is important to notify the occupants of that

aCe of a fire or other emergency to initiate egress or relocating. wever, the concepts used in the construction, seperation,

arrangements, and protection of the covered mall building preclude the need to evacuate the entire building.

It should also be noted that the requirements for the fire alarm installation within individual tenant spaces is regulated by other provisons of this chapter depending on the size of the sales space. The substantiation provided with the original proposal has not fully supported or has shown that the current requirement is inadequate based on the realization that these facilities are no t required to fully evacuated. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE:. 16 NEGATIVE: 1 NOT RETURNED: 2 Holmes, Moon

EXPLANATION OF NEGATIVE: BUSH: The Committee Statement has provided no substantial

justification for the lack of a requirement of fire alarm systems throughout new covered mall buildings. While it is understood that the retrofit of fire alarm systems in areas of existing covered mall buildings outside of the covered mall and not currendy provided with a fire alarm system may not be cost effective, there appears to be adequate justification for the installation of such systems in new buildings. This is amplified by the fact that an alarm system is required to be installed in the covered mall area, and that the committee statement indicates that a part of the egress concept for these buildingrs " involves travel through the covered mall. Occupants of indivadual tenant spaces should be provided

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with early notification of any threatening condition which may exist along their required path of egress travel. The size and configuration of all tenant spaces may preclude the early warning of these occupants from notification appliances located only within the covered mail. In addition, since these tenant spaces are typically open to the covered mall without separation, any threatening condition within the tenant space must be immediately communicated to all of those occupying the exposed space. Where remote exits directly from the tenant space to the exterior are provided, or where travel to a fire alarm initiating device within the covered mall is blocked or impeded, the time to activate the alarm system and to provide appropriate notification to all covered mall building occupants may be delayed or never initiated.


101- 448 - (24-4.4.$.3.1 and 25-4.4.3.3.1): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-754 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER add for the ROC a statement that expands the ROP's committee statement to explain why the recommended change was not made for Chapter 24 for new mall buildings. The current committee statement addresses only why the change was not imposed retroactively on existing mall buildings. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle. .

See Committee Action on Comment 101-445 !Log #155). COMMITFEE STATEMENT: The Committee s substantiation to Comment 101-445 (Log #155) should fulfill the submitter's request. NUMBER OF COMM/TFEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITrEE ACTION:



101- 449 - (Chapter 25): Accept in Principle SUBM/TrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-757 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER clarify what, if anything, is to be done to the wording of 25-1.7(a) given that Proposal 101-758 is replacing all the 25-1.7's with a reference to the new Table 5-3.1.2. It appears that there will be no 25-1.7(a) to modify. SUBSTANTIATION: See the above recommendation. COMM/TrEE ACTION: Accept in Principle.

No further change is needed. COMMITTEE STATEMENT: The recommendation of Proposal 101-7~8 is the action which the committee prefers. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


(Log #CC555) Committee: SAF-MER

101- 450 - (25-1.1.2): Accept [ TCC NOTE: The Technical Correlating Committee on Safety to [ Life (SAF-AAC) directs that the action on this comment be I changed so that the wording of 25-2.5.10 reads: [ "25-2.5.10 Exit access in Class A mercantile occupancies that are [ protected throughout by an approved, supervisod antomatic [ sprinkler system in accordance with Section 7-7 and exit access in I all Class B and Class C mercantile occupancies shall be permitted

to pass through storerooms ..." It appears that the wording from Chapter 24 was mistakenly used

in preparing the recommendation on Chapter 25 so that Class B mercantile occupancies would have required sprinklers in order to use the provision. If this substantial technical change was intentional, it was not documented. See current 25-2.5.10 in the 1997 edition of the Code. SUBMITrER: Technical Committee on Mercantile and Business Occupancies COMMENT ON PROPOSAL NO: 101-757

I RECOMMENDATION: Revise the following paragraphs by replacing "stores" with "mercantile occupancies" or "tenant space"

I 25-1.1.2 This chapter establishes life safety requirements for all new mercantile buildings. Specific requirements for suboccupancy groups such as Class A, Class B, and Class C mercantile occupancy. stofe~, covered malls, and bulk merchandising retail buildings are contained inparagraphs pertaining thereto.

25-2.5.6 In Class A mercantile occupancies store,, at least one aisle of 5 ft (1.5 m) minimum width shall lead directly to an exit.

25-2.5.10 Exit access in Class A and Glass B occuoancies stores- that are protected throughout by an approved, supervised automatic sprinkler system and exit access in all Class C mercantile occupancies stores shall be permitted to pass through storerooms, provided the following conditions are met:

(a) Not more than 50 percent of exit access shall be provided th rough the storeroom.

(b) The storeroom shall not be subject to locking. (c) The main aisle through the storeroom shall be not less than

44 in. (112 cm) wide. (d) The path of travel, defined with fixed barriers, through the

storeroom shall be direct and continuously maintained in an unobstructed condition.

A-25-2.2.7 Exception To design egress from a covered mall building, the following steps should be used:

(I) The covered mail /pedestr ian way has been assigned no occupant load, but i t must be provided with means of egress sized to accommodate the total occupant load of the covered mall building based on the gross leasable area. The exits for the covered mail /pedestr ian way can be provided by a combination of exterior exit doors and exit passageways.

(2) After completion of step (1), each tenant space (L=., -=or=) is to be judged individually for occupant load and egress capacity. This step normally sends some portion or all (per 25-4.4.2.2) of the ~ ~ o f e ~ occupant load into the covered mall and any remaining occupants through the back of the 1 fg la l lgKl~ stor~ into an exit passageway that may serve multiple tenant ~ s t e v ~ and the covered mail.

($) The exit passageway must be sized for the most restrictive of the following conditions:

(a) Minimum 66 in. (168 cm) per 25-4.4.1 Exception (b), or (b) The portion of the egress capacity from the largest single

tenant tg~Sy, g s t o ~ being served by the exit passageway, or (c) The portion of the egress capacity from the covered mall

being provided by the exit passageway. The concepts used in the above steps include the following: (1) After proper egress capacity is provided for the covered

mall /pedestr ian way, each ~ ~ m u s t then independently provide egress capacity for its occupant~

(2) The covered mall and the ~ s t o e d e required exit passageway width need not be added together.

($) The required exit passageway width for a tenant ~ s t o r - e - need not be added to that of other f~tf, g stor-~ using the same exit passageway.

A-25-4.4.1 Exception (b) The minimum requirement for terminating mall exit access in not less than 66 in. (168 cm) of exit width relates to the minimum requirement for at least one aisle in i 2 Class A mercantile occupancies sto¢-~ [30,000 ft ~ (2,800 m ) or ~A_eater sales area] to be 5 ft (152 cm) in width.

25-4.4.2.$ It is not the intent of this paragraph to require that large tenant spaces ~ be considered anchor stores. A t e n e t KO.a£~ stole-not considered in determining the occupant load of the mall must be arranged so that all of its means of egress will be independent of the covered mall. SUBSTANTIATION: These revisions are a continuation of the activity associated with the original Proposal 101-757 (Log #CP906). These represent those items that where not addressed in the original proposal COMMITFEE ACTION: Accept. NUMBER OF COMM/TrEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:



101- 451 - (25-3.1(t) Exception No. 2 (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-762 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the extinguishing systems provisions of NFPA 101, rew'ew Proposal 101-762 for correlation.

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SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

Reject Proposal 101-762. COMMITTEE STATEMENT: Based on the comments from the chair of the Technical Committee on Automatic Sprinklers, there has been insui~cient technical justification provided for permitting this change in system design. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14


101-452- (25-3.1(f) Exception No. 2 (New)): [ TCC NOTE: The Technical Correlating Committee on Safety to I Life (SAF-AAC) directs that the action on this comment be [ changed to aReject Proposal 101#62" for correlation with the [ action by SAF-BSF on Comment 101451 (Log #99) and the input [ recCwed from the Technical Committee on Automatic Sprinklers I via uomment 101453 (Log #415a) from its Chair. Also see Mr. [ Bush's Explanation o f Negative associated with Comment 101453

[ S ~ ' I ~ I ~ - a , , - - ~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-762 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER give consideration to Mr. Bush's comment on aftirmative for clarification purposes. It reads:

BUSH: While the concept of this proposed change is appropriate, the wording of the new (f) to Exception No. 2 to 25-3.1 should be modified as follows: The draft stop and closely spaced sprinkler requirement of NFPA 13, Standard for the Installation of Sprinkler Systems, shall not be required for unenclosed vertical openings idendfiedp_qr.tXlRL~ in (a), (b), (c), (d), eead-or (c). SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITrEE ACTION:


EXPLANATION OF NEGATIVE: OSMAN: While I support the committee action on this item, it

should disappear if th~ action on Comment 101- (Log #415a) is reversed.


101- 453 - (25-3.1(f) Exception No. 2 (New)): I TCC NOTE: The Technical Correlating Committee on Safety to [ Life (SAF-AAC) directs that the action on this comment be [ changed to ~Accept in Principle. Reject Proposal 101-762." This is [ done for correlation with the action by SAF-BSF on Comment 101- 1 451 (Log #99) and the input received from the Technical [ Committee on Automatic Sprinklers via Comment 101453 (Log [ #415a) from its Chair. Also see Mr. Bush's Explanation of - ] Negative associated with Comment 101453 (Log #415a).

SUBMITTER: John G. O'Neill, Gage-Babcock & Assoc. Inc. COMMENT ON PROPOSAL NO: 101-762 RECOMMENDATION: I recommend that the proposed text not be accepted and that direction be given to follow NFPA 13 since the issue affects the design and installation of the sprinkler system. SUBSTANTIATION: I serve as Chair of the Technical Correlating Committee on Automatic Sprinkler Systems (NFPA 13). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life.

The criteria for the draft stops and closely spaced sprinklers have been in NFPA 13 for many years and are based on the concern that heat from a fire close to an opening, but not in the opening, on a lower floor may cause sprinklers to open on upper floors. A full scale test program conducted over 30 years ago dealing with escalator openings supported this concern. The escalator type opening in a mercantile occupancy was certainly one of the conditions considered in developing the criteria. The language in NFPA 13 regarding the exception was adopted in the 1987 edition when the sprinkler committee determined that such a risk would not apply to large openings such as in covered malls or atriums.

The only proposal or comment regarding these criteria received for 1999 edition applied to residential applications only, therefore,

1999 edition, as it will be presented at the 1999 Annual Meeting, still contains the same text for the smaller openings. The Technical Committee on Installation Criteria will be directed to examine this issue again in the next cyde considering the recommendations and supporting information from the Committee on Safety to Life - Mercantile Occupancies. COMMITTEE ACTION: Reject. COMMITFEE STATEMENT: The committee has reviewed the statements made by the submitter. The supporting documentation noted in the substantiation is over 30 years old and to the best of the committee's knowledge is misplaced and is not available for review. In general discussions it was noted that these tests where developed for a specific application or project. The committee believes that there has been significant acdvity since that time to permit the omission of draft stops. Some of the earlier editions of the model build codes have permitted openings in a building floor without draft stops. There has not been significant documentation to show that there was a problem associated with these installations.

The current exception for the omission of draft stops on large openings such as an atrium found in NFPA 13 was derived from the atrium provision found in NFPA 101. There was no documentation or research to show that the 1000 sq. ft with a 20 foot minimum dimension was chosen for a specific application to omit the draft stops. The 1997 edition of NFPA 101 has now eliminated the minimum sizing requirements for an atrium. How will this effect the requirement that is currently found in NFPA 13? The committee recognizes that technology a n d t h e type of sprinklers required to be installed have advanced significantly since the referenced test, of 30 years ago. The installation of quick response sprinklers now should be reviewed as a positive event and permtt the omission of draft stops. Draft stops may have been required to be installed to assist in the collection of heat and speed the operation of standard sprinklers as it related to the opening in the floor with the technology and fire sprinklers of years gone by. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BUSH: The specification of design criteria for automatic

sprinkler protection should be regulated by the Technical Committee on Automatic Sprinkler Systems, mad not by a Technical Committee of the Life Safety Code. Where exceptions to such design criteria are deemed necessary, they should be forwarded to the appropriate Technical Committee for consideration, processing with opportunity for public comment, and inclusion as a part of the applicable design standard. Design details for automatic sprinkler systems within the Life Safety Code will lead to confusion and misapplication of the Standard for the Installation of Sprinkler Systems as designers and installers of these systems may not routinely reference the Life Safety Code for all such requirements. Exceptions for the elimination of draftstops for unprotected vertical openings, a requirement of the Standard for the Installation of Sprinkler Systems, should be made only after the study of recent technical justification, appropriate consideration, and proper documentation and coordination between the members of both Technical Committees, and not by simple elimination by only one of the Technical Committees concerned with a specific occupancy type.

OSMAN: No technical substantiation has been provided to allow this deviation from NFPA 13. At the request of the correlating committee the Technical Committee on Building Service and Fire Protection Equipment reviewed this proposed exception and developed the following committee statement: "Based on the comments from the chair Of the Technical Committee on Automatic Sprinklers, there has been insufficient technical justification provided for permitting this change in system design."

This requirement has been in NFPA 13 for many years. It was stated in discussion at the mercantile and business committee meetin~ that many buildings have been erected without this protecuon. To legitimize buildings built in non-compliance with NFPA 101 and NFPA 13 is not a valid reason to change the code.

The chair of NFPA 13 stated in his substantiation that the Technical Committee on Installation Criteria will be directed to examine this issue again in the next cycle considering the recommendations and supporting information from the Committee on Safety to Life - Mercantile Occupancies. At the mercantile and business meeting a task group was organized to assist NFPA 13 in their study on draft stops.

Considering the length of time that this requirement has been in NFPA 13 and considering the lack of new technical data, it makes

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sense to allow time for the NFPA 13 Technical Committee on Installation Criteria and the mercantile and business task group complete their work and come back to NFPA 13 and NFPA 101 with proposals, if appropriate, for the next editions of these standards and codes. COMMENT ON AFFIRMATIVE:

SCHULTZ: My voted is affirmative on all items and I would like to add several comments in support of the Committee's Action on Comment 101-435 (Log #415) and 101-453 (Log #415a).

It must be noted that the full Scale test program conducted over 30 years ago given as the primary justification by the Technical Correlating Committee on Automatic Sprinkler Systems for the rejection of the proposed new code wording should not be considered as valid justification based on the following.

There is considerable confusion about the testing that was done since no documentation is available. A representative from the firm that performed the fire test has indicated that the test was not a highly scientific test nor was it well documented. As explained to out committee, the 30 year ago test used a flammable liquid pan fire located adjacent to the escalator floor opening. The floor level the test was performed on and the number of stories connected by the escalator was unknown as well as the size of the escalator floor opening the size of fire and the location of the fire test pan to the escalator floor opening. There was also no knowledge regarding whether there was a stack effect condition.

When reviewing the old building code languages about escalator openings, there were discussions of creating down drafts in the escalator floor opening when a fire condition was detected. This is obviously a reflection of construction techniques where escalators serve a large number of floors. These type of conditions may justify the need for closely spaced sprinklers and draft stops as required by NFPA 13. However, in openings connecting three levels, such stack effects can not be expected and, therefore, can not be used to justify the need for closely spaced sprinklers and draft stops.

This same logic would seem to be consistent with the rationale submitted by the NFPA 13 Technical Committee on Automatic Sprinklers in 1982 on Proposal 13-04-(4-4.8.2.4) when they included the exception for closely spaced sprinklers and draft stops around large openings in fuUy sprinklered buildings. The justification given by the committee was "SUBSTANTIATION: Fire experience does not indicate a need to use draft stops in combination with closely spaced sprinklers in fully sprinklered buildings."

It is also our committee's opinion that the fire experience available will no t support the need for closely spaced sprinklers and draft stops for openings between three floor levels. Such protection may be appropriate when located in conditions where stack effect can realistically occur. It is well recognized that the degree of stack effect that can be generated by a floor opening communicating two or three levels in buildings are not of the type that warrant this type of protection.


101- 454 - (25-3.5.2 and 25-4.2): Reject SUBMITTER= Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-766 RECOMMENDATION: Accept proposal 101-766. SUBSTANTIATION: As unsprinklered high-rise buildings around the world continue to burn down, more and more communities are realizing that these buildings represent special fire problems and are forcing the retrofit of sprinkler systems. No combination of construction, staff and fire fighters can save the occupants and the building. It took large loss fires in Type 1 Fire Resistive construction buildings in Philadelphia, Los Angeles, New York, Boston, and Baltimore to get legislation moving.

Should the Life Safety Code wait for more losses before it moves on? COMMI~rEE ACTION: Reject. COMMITTEE STATEMENT: The committee supports their original substantiation for the rejection of Proposal 101-766. The substantiation provided with this comment highlights examples that are not mercantile occupancies in nature. Therefore there is no additional justification provided to warrant this requirement specifically for this occupancy. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITFEE ACTION:



101- 455 - (26-2.5.3 Exception No. 2): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-777 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MER reword the exception for clarity. The repetition of the words "within a single tenant space" makes the provision difficult to understand. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

I Revise 26-2.5.3 Exception No. 2 to read: Exception No. 2: A common path of travel "a"..h'n :he =:.g=~:1

ten=~t :Face shall be permitted for the first 100 ft (30 m) within a single tenant spaces having an occupant load of not more than 30 persons

I " ° . .

COMMITTEE STATEMENT: The rewslon should provide the necessary clarification that the travel distance occurs within the tenant space. NUMBER OF COMM1TI'EE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMI'[TEE ACTION:



101- 456 - (26-$.1.1 Exception No. 1): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) affirms the action by SAF-BSF on this comment . Thus, Proposal 101-779 is rejected. This is consistent with the actions taken on Comments 101-452 (Log #201), 101-434 (Log #92a), 101-435 (Log #415), 101-452 (Log #99a), 101-453 (Log #415a), and 101-460 (Log #103). SUBMII~FER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-779 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the extinguishing systems provisions of NFPA 101, renew the technical aspects and correlation issues of Proposal 101- 779 and provide input for consideration by SAF-MER at its ROC-

~ reparation meeting. UBSTANTIATION: See the above recommendation.

COMMITTEE ACTION: Accept in Principle. [ Reject Proposal 101-779.

COMMITTEE STATEMENT: Based on the comments from the chair of the Technical Committee on Automatic Sprinklers, there has been insufficient technical justification provided for permitting this change in system design. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14


101- 457 - (26-3.5 and 27-3.5): Reject SUBMITTER= Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-785 RECOMMENDATION: Add a new Exception to these sections as follows:

"Extinguishers shall be permitted to be omitted in buildings protected by.a supervised automatic sprinkler system in accordance with Section 7-7." SUBSTANTIATION: This seems to be a reasonable middle ground between the submitter's original suggestion and the committee statement in support of the rejection. Extinguishers shouldn' t be needed in fully sprinklered buildings. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee recognizes the importance of having manual fire suppression capabilities within these facilities. It is noted that small incipient fires are easily controlled by manual fire suppression. In reports d o n e by the NFPA Fire Analysis and Research Department it is noted that approximately 13 percent of nonresidential fires are extinguished by manual means of fire suppression. N U M B E R OF C O M M I T I T ~ MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITTEE ACTION:


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c (Log #159)

ommittee: SAF-MER 101- 458 - (26-3.6.1 Exception No. 2, Exception No. 3, A-26-3.0.1 (New)): Accept SUBMITTER: Kenneth E. Bush, MD State Fire Marshal's Office COMMENT ON PROPOSAL NO: 101-786 RECOMMENDATION: Retain existing 26.3.6.1 and Exception No. 1.

Revise Exception No. 2 to read: "Within a snace occupied by a single tenant."

Revise Exception No. 3 to read: "Within buildings protected throughout bv an approved, suoervlsed automatic snrinkler svstem in accordance with Section 7-7. -~

Add a new A-26.3.6.1 as follows: A-26-3.6.1 The intent of Excentions No. 2 and No. 3 to 26.3.6.I is

to oermit snaces within single tenant snaces, or within buildings protected throughout by an aDoroved.-sunervised automatic - snrinkler svstem-to be onen to t.he exit access corridor without seoaration. SUBSTANTIATION: The intent of this proposal is to specify the Committee's in tended level of protection required for corridor wall construction in single tenant spaces and in buildings with complete automatic sprinkler protection. The new Appendix Note seeks to further clarify the Committee's position that use areas may be open to the corridor without separation under certain conditions. In accordance with the proposed wording in the ROP, 26-3.6.1 would require the construcUon of these wails in accordance with the much more restrictive requirements for smoke barriers, which does not agree with the Committee Statement for this proposal. COMMITTEE ACTION: Accept. NUMBER OF COMMrrTEE MEMBERS ELIGIBLE TO VOTE: 19 VOTE ON COMMITrEE ACTION:



101- 459 - (26-3.6.1 Exception No. 2, Exception No. 3, and 26-3.6.3 (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-786 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-MEPa (1) insert the wording for Exception No. 3 which is missing from the action, (2) revise its action to clarify its intent given that the committee statement conflicts with the wording of the revised exceptions, (3) give consideration to Mr. Bush's and Mr. Perry's explanations of negative, and (4) substantiate the technical change that was introduced by adding the words "separated from use areas" given that current language seems not to prohibit the corridor from being used, for example, as a secretarial station complete with desk, chair and business machines provided that the necessary clear width is maintained for egress purposes. The new wording will require use areas to be separated from the corridor - a technical change that has no t been substantiated.

The referenced wording reads: BUSH: The proposed wording of the new Exceptions are not

consistent with the committee intentions noted as a part of the Committee Statement for this proposal. If the intent of these Exceptions is to permit corridor walls that are not fire rated or that do not resist the passage of smoke in spaces occupied by a single tenant or in buildings protected throughout by an approved, automatic sprinkler system, reference should not be made to 6-2.4 which prescribes the requirements for smoke partitions, inducting self<losing or automatic-closing doors in openings therein.

The wording of the new Exceptions to 26-3.6.1 should be modified as follows:

Exception No. 2: Spaces occupied by a single tenant, c o r r . ' ~

Exception No. 3: Buildings protected throughout by an a k 11 k approved, automatic sprinkler system, cor~o=g ~..m. ~ot ~:

PERRY: Mr. Bush is correct. My notes fi'om the meeting indicate that the Committee intent was to revise the Exceptions as shown in Mr. Bush's negative comment.

As presented, the committee action presents an increase in the requirements of the Code, by adding "shall be separated from use areas by partitions in accordance with 6-2.4." The Committee

intent, as shown in the committee statement, was to clarify that such non-rated corridors are not required to resist the passage of smoke.

The committee action as originallypublished is in error, and should be revised as shown in Mr. Bush's comment. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-458 (Log #159). COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS F_JLIGIBLE TO VOTE: 19 VOTE ON COMM1TrEE ACTION:



101- 460 - (27-3.1.1 Exception No. 1): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) affirms the action by SAF-BSF on this comment. Thus, Proposal 101-794 is rejected. This is consistent with the actions taken on Comments 101-452 (Log #201), 101-454 (Log #92a), 101-435 (Log #415), 101-452 (Log #99a), 101-453 (Log #415a) and 101-456 (Log#101). SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-794 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF; which has primary responsibility for the extinguishing systems provisions of NFPA 101, review the technical aspects and correlation issues of Proposal 101- 949 and ~provide input for consideration by SAF-MER at its ROC- preparataon meeting. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Reject Proposal 101-794. COMMITTEE STATEMENT: Based on the comments from the chair of the Technical Committee on Automatic Sprinklers, there has been insufficient technical justification provided for permitting this change in system design. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 14

(Log #104) Committee: SAF-IND

101- 461 - (28-1.2.1 and 28-1.2.2 (New)): Accept in Principle SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-799 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-IND give consideration to Mr. Stelzer's comment on affirmative to correct the committee acdon so as to reference Proposal 101-551. It reads:

STELZERa The Committee Action should reference Committee Proposal 101-551 (Log #CP855). SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

No further action is needed. COMMITTEE STATEMENT: The committee reviewed this material and noted that the correct reference is to Proposal 101- 551. No further action is needed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:


C (Log #105)

ommittee: SAF-IND 101- 462 - (28-3.1.1 Exception No. 1 and Exception No. 6): Accept in Principle SUBMITTER: Technical Gorreladng Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-811 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAC-AAC) requests that SAF-IND give consideration to Mr. Stelzer's comment on affirmative to correct the paragraph reference. It reads:

STELZER: The Proposal was intended to reference to 28-5.1. It is an editorial error to reference to 28-~.1.1 since it does not exist. SUBSTANTIATION: See the above recommendation.

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COMMITTEE ACTION: Accept in Principle. No further action is needed.

COMMITTEE STATEMENT: The Committee reviewed this material, concurrs that the correct reference is to 28-3.1. and determined that no further action is needed. NUMBER OF COMMrrrEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:



101- 465 - (28-4.1 Exception No. 3): Reject SUBMITTER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-814 RECOMMENDATION: Accept Proposal 101-814. SUBSTANTIATION: As unsprinklered high-rise buildings around the world continue to burn down, more and more communities are realizing that these buildings represent special fire problems and are forcing the retrofit of sprinkler systems. No combination of construction, staff and fire fighters can save the occupants and the building. It took large loss fires in Type 1 Fire Resistive construction buildings in Philadelphia, Los Angeles, New York, Boston, and Baltimore to get legislation moving.

Should the Life Safety Code wait for more losses before it moves on? COMMITTEE ACTION: Reject. COMMITFEE STATEMENT: The committee supports their original substantiation for the rejection of Proposal 101-814. The substantiation provided with this comment highlights examples that are not industrial occupancies in nature. Therefore, there is no additional justification provided to warrant this requirement specifically for this occupancy. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITIY£ ACTION:



101- 464 - (29-1.2.1 and 29-1.2.2 (New)): Accept in Principle SUBM1TTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-815 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-IND give consideration to Mr. Stelzer's comment on affirmative to correct the committee action so as to reference Proposal 101-551. It reads:

STELZER: The Committee Action should reference Committee Proposal 101-551 (Log #CP833). SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

No further action is needed. COMMITTEE STATEMENT: The Committee reviewed this material and noted that the correct reference is to Proposal 101- 531. No further action is needed. NUMBER OF COMMrlWEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITFEE ACTION:


(Log #CC600) Committee: SAF-IND

101- 465 - (29-2.6): Accept SUBMITIXR: Technicai Committee on Industrial and Storage Occupancies COMMENT ON PROPOSAL NO: 101-819 RECOMMENDATION: Reformat 29-2.6 to read as follows:

29-2.6* Travel distance to Exits (See also Section 5-3) 29-2.6.1 In low hazard storage occupancies there shall be no

limitations on travel distance to exits 29-2.6.2 In ordinary hazard storage occupancies travel to exits

shall no t exceed 200 ft (60 m) from any point to reach the nearest exit.

Exception: In buildings protected throughout by an approved supervised automatic sprinkler system in accordance with Section 7-7, travel distance shall not exceed 400 ft (122 m).

29-2.6.$ Every area used for the storage of high hazard commodities shall have an exit within 75 ft (25 m) of any point in the area where persons might be present. Travel distance shall be measured in accordance with Section 5-6.

Exception No. 1: In areas used for the storage of high hazard commodities and protected throughout by an approved supervised automatic sprinkler system in accordance with Section 7-7, travel distance to an exit shall be within 100 ft (30 m) of any point in the area where persons might be present.

Exception No. 2*: In storage occupancies where flammable and combustible liquid products are stored and protected in accordanc¢ with NFPA 30, Flammable and Combustible Liquids Code, travel distance to an exit shall be permitted to be 150f t (45 M).

A-29-2.6 retain current text A-29-2.6.3 Exception No. 2. The committee determined that the

exception for extended travel distance should be addressed within the specific occupancy instead of being applied to a general application. It is recognized that the 1996 edition of NFPA $0 has been revised based on research that was done pertaining to the storage of flammable and combustible liquids and the necessary protection. Based on the revisions to the 1996 edition of NFPA 50 and the minimum protection stipulated that the limitation of 150 feet travel distance would be acceptable. It is recognized that this exception is dependent on the application of the provisions of the 1996 edition of NFPA 30. SUBSTANTIATION: The reformatting was done to satisfy the request of the TCC on Comment 101-466 (Log #107). The

~ roposed reformatting does not introduce any new requirements ut reorganizes the different requirements into more user friendly

format. The following is a cross reference chart: 1997 ed. 2000 ed. 29-2.6 29-2.6.2 29-2.6 Excep. 1 29-2.6.2 Exception 29-2.6 Excep. 2 29-2.6.1 29-2.6 Excep. 3 29-2.6.3 29-2.6 Excep. 4 29-2.6.5 Excep. 1 29-2.6 Excep. 5 29-2.6.5 Excep. 2

The appendix note to 29-2.6.3 Exception No. 2 was developed by the Committee Action taken on Comment 101-466 (Log # 107). The deletion of the second sentence in the proposed 29-2.6.3 was done for clarity as it is not needed. COMMITTEE ACTION: Accept. NUMBER OF CoMMrITEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:



101- 466 - (29-2.6 Exception No. 5 (New)): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) directs that the action on this comment be changed by revising the wording of the appendix note for clarity so that it reads:

A-29-2.6 Exception No. 5. The exception for extended travel distance in protected flammable and combustible liquids warehouses i s addressed within the storage occupancy provisions rather than in the generalized high hazard conte~ts previsions of Section 5-11. The 1996 edition of NFPA 30, F/ammable and Combm*/ble L/qu/ds Cede, represents an enhancement over earlier editions and is based on research. Provided that the protection is provided in accordance with the 1996 edition of NFPA $0, the mcreaso in travel distance to 150 ft (45 m) is justified. SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-819 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-IND develop an appendix note explaining the importance of providing NFPA 30 protection in accordance with the 1996 edition of NFPA $0. NFPA style guidefines will not permit the edition year ~1996 ~ to appear in Chapter 29; edition years for mandatory referenced publications must appear in Chapter 33.

Further, SAF-AAC directs that the pubfic comment request that SAF-IND reformat/revise the 29-2.6's to clarify intent. It is awkward that Exception No. 3 to 29-2.6 introduces a requirement that is stricter than the base provision of 29-2.6. It is not clear that the new Exception No. 5 is intended to be permitted to be used to override the 75 ft travel distance limitation of Exception No. 3. SUBSTANTIATION: See the above recommendation.

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COMMITTEE ACTION: Accept in Principle. Add an appendix note to 29-2.6 Exception No. 5 that reads: A-29-2.6 Exception No. 5. The committee determined that the

exception for extended travel distance should be addressed within the specific occupancy instead of being applied to a general application. It is recognized that the 1996 edition of NFPA 30 has been revised based on research that was done pertaining to the storage of flammable and combustible liquids and the necessary protection. Based on the revisions to the 1996 edition of NFPA $0 and the minimum protection stipulated that the limitation of 150 feet travel distance would be acceptable. It is recognized that this exception is dependent on the application of the provisions of the 1996 edition of NFPA 30. COMMITFEE STATEMENT: This revision should satisfy the request of the TCC to develop an appendix note explaining the importance of the specific reference to the 1996 edition of NFPA 30. It should be noted for editorial staff that there is a committee Comment 101-465 (Log#CC600) that was developed to address the second part of the TCC comment. This committee comment has reformatted 29-2.6 to address the awkwardness of the current language. The appendix note to exception 5 would be correctly referenced to 29-2.6.3 Exception No. 2 o n committee comment 101-465 (Log #600).

The TCC comment was divided into two parts to facilitate the discussion of what appears to be two separate requests from the TCC. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


(LOg #108) Committee: SAF-IND

101- 467- (29-3.4.3.2): Accept in Principle SUBMITFER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-824 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-IND give consideration to Mr. Stelzer's comment on affirmative. It reads:

STELZER: The Proposal was intended to reference 29-3.4.3.2. There is an editorial error reference to 28-3.4.3.2. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

No further action is needed . COMMITTEE STATEMENT: The Committee reviewed this material, concurrs that the correct reference is to 28-3.4.3.2 and . determined that no further action is needed. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITIT~E ACTION:


c (Log #246)

ommittee: SAF-IND 101- 468 - (29-4.1): Reject SUBM1TrER: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 10t-826 RECOMMENDATION: Accept Proposal 101-826. SUBSTANTIATION: As unsprinklered high-rise buildings around the world continue to burn down, more and more communities are realizing that these buildings represent special fire problems and are forcing the retrofit of sprinkler systems. No combination of consuuction, staff and fire fighters can save the occupants and the building. It took large loss fires in Type 1 Fire Resistive construction buildings in Philadelphia, Los Angeles, New York, Boston, and Baltimore to get legislation moving.

Should the Life Safety Code wait for nlore losses before it moves on? COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The committee supports their original substantiation for the rejection of Proposal 101-826. The substantiation provided with this comment highlights examples that are not industrial occupancies in nature. Therefore there is no additional justitication provided to warrant this requirement specifically for this occupancy. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:



101- 469 - (29-8): Accept in Principle SUBMITTE~ Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-827 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-IND reconsider its acceptance of the new provision that will require construction and

~ rotection of parking structures to be in compliance with NFPA 8A. The proposal's substantiation addresses only the definition of

open parking structure; not the mandatory use of NFPA 88A. NFPA 88A addresses both property protection and life safety. There are conflicts between NFPA 101 and NFPA 88A. For example, NFPA 101 would allow the stairs to be unenclosed if used for exit access; NFPA 88A requires the stairs to be enclosed. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise the action on Proposal 101-827 (Log #56) to accept in part. Accept only the revision to 29-8.2.6 Exception No. 1 and 29-8.$.4 Exception No. 1. COMMITTEE STATEMENT: The Committee wishes to revise their current position on the revisions to Section 29-8 addressing 29-8.1.1 and 29-8.1.3, Special Definitions: Open Parking Structures. The committee in response to the TCC notes to reconsider their previous action has determined that the current text as found in the 1997 edition should be retained. This is based on the recent activity to develop a task group between the technical committee responsible for NFPA 88A andth is committee to review the differences between the documents and develop the necessary actions to establish consistency.

The committee also wishes to maintain the current definition for open-air parking structures as found in the 1997 edition. The committee in further review of this definition determined that there is a significant difference between the proposed definition and the current definition as it relates to ventilation requirements. Additional research and review is needed to satisfy the application of the ~criteria associated with openness" as it relates to life safety for this type of facility. Because there is a task group being formed as noted in the TCC notes to Proposal 101-827 the committee requested that any revision be held until such time that it can be discussed by this task group. The current text provides adequate protection without any problems for the building occupants.

It is also noted for the TCC that the action to proposal 101-828 on the acceptance of a definition for open parking structures should be revised to be consistent with the action taken on this comment. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:


(Log #CC601) Committee: SAF-AAC

101- 469a - (29-8): Accept SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-828

I RECOMMENDATION: Reject Proposal 101-828 so as to retain_ the definition of Open-Air Parking Structure as found in the 1997 edition of the Code. SUBSTANTIATION: The Technical Committee on Industrial, Storage and Miscellaneous Occupancies, in its Committee Statement on Comment 101-469 (Log #109), requested this action for correlation purposes. The Technical Correlating Committee on Safety to Life agrees that it is necessary to retain the current definition for one more code edition. The subject will be addressed again during the preparation of the year-2003 edition of the Code. See Comment 101-469 (Log #109). COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMrFrEE ACTION:

AFFIRMATIVE: 16 NOT RETURNED: 2 Thonnings, Woodward


101- 470 - (30-1.6.1): Reject SUBMITI'ER: Craig V. Mayer, Pleasanton, CA COMMENT ON PROPOSAL NO: 101-838 RECOMMENDATION: I request that the committee reconsider its action to reject proposal 101-8238 submitted by the Western Regional Fire Code Development Committee. The information in

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the "story of exit discharge" row in the current Table $0-1.6.1 needs to be changed to require sprinklers in new day-care occupancies in buildings with Type III(200) and Type V(000) construction. SUBSTANTIATION: This change will essentially reestablish sprinkler requirements that originated in the 197~edition of the Life Safety Code. Those requirements were in effect for more than 20 years and contributed to the good fire record of day-care centers.

Only since the 1994 edition of the Life Safety Code is it possible to have an unlimited number of children, including infants and toddlers, in Type Ili(200) and Type V(000) day-care centers without sprinkler protection. Ironically, NFPA 150 would not allow such an unprotected structure to be used as a stable for horses.

The history of this problem goes back to Item 101-400 in the 1993 Fall Meeting Technical Committee Reports. That proposal led to an extensive reorganization of the requirements for new day-care occupancies. It was submitted to the current chair of the Technical Committee for Educational and Day-Care Occupancies. Her four-sentence substantiation for those changes included the statement, "The theory of staff ratios should be replaced with more stringent construction/protection." Paradoxically, buried in that extensive rewrite was the elimination of fire sprinkler requirements for new single story day-care centers in he most combustible types of construction, where NFPA statistics indicated most day-care center fires occurred. (See my comment on Proposal 101-872 where a similar tactic is now proposed to delete the same sprinkler requirements from Table 31-L6.1for existing day-cares. Again, the substantiation does not provide any technical basis for eliminating long established sprinkler requirements, or give any indication that is being done.)

I agree with the fire service representatives on the Western Regional Fire Code Development Committee. The way to resolve the "enforcement nightmare" they described is to reestablish these sprinkler requirements in Table 30-1.6.1, rather than deleting those in Chapter 31. Resolving discrepancies between chapters by deleting more sprinkler requirements sets a dangerous precedent. Allowing fire sprinkler requirements to be deleted without any technical substantiation could reverse much of the progress made in life safety. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The issue raised by the submitter was thoroughly' addressed when the 1997 edition of the Code was prepared. This included affirmation by the NFPA Standards Council, Board of Directors, and ANSI that the regulations had been followed. The submitter has not provided new information to justify the requested change. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14 NOT RETURNED: I Ewing


101- 471 - (Table $0-1.6.1): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101~837 RECOMMENDATION: Reconsider the Committee Action and accept the proposal. SUBSTANTIATION: We agree with the negative comments and the submitters substantiation. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See the Committee Statement for the

of ropo 101-837 OF COMMITTEE MEM EBS ELIGIBLE TO VOTE: 15

VOTE ON COMMITTEE ACTION: AFFIRMATIVE: 13 NEGATIVE: 1 NOT RETURNED: 1 Ewing

EXPLANATION OF NEGATIVE: TROTTER: I stand on my remarks from the 1999 November

Association Technical Committee ROP and support the statements made by Mr. Gene Endthoff, regardless of or lack of technical justification or statistics. It is time for the Life Safety Code to take the sprinkler advantage.

C (Log #211)

ommittee: SAF-END 101- 472 - ($0-2.9(b)): Reject SUBMITTER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-847 RECOMMENDATION: Reconsider the Committee Action and reject this proposal. SUBSTANTIATION: The term "Assembly use spaces" is not defined in this chapter, but assembly is. Confusion will take place as currently worded, when does this requirement kick in, when the area has a capacity of 50? We think the committee's intent was to require emergency lights in "common spaces or areas" where everyone has access to those areas. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See the Committee Statement for the rejection of Comment 101-$05 (Log #251) on 10-2.9. NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITIT_,E ACTION:



101- 473 - ($0-2.9(b) and 31-2.9(b) ): Reject SUBMITrER: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-847, 101-848, 101-872 RECOMMENDATION: The action of the Committee in 101-847 to delete the Exception to $0-2.9(b) is a step in the right direction, however, the action to change the word of (b) from "normally occupied spaces" to "assembly use spaces" does not adequately clarify the situation. There is no definition for "Assembly use spaces" unless it is intended to apply the definition of an "assembly occupancy" and require emergency lighting only in rooms or spaces with 50 or more occupants. If that is the intent, that does not address the issue. The action of the Committee in 101-847 (and 101-872) would better satisfy my concerns if the term "assembly use spaces" in (b) was replaced with the wording "spaces normally occupied by clients during periods of darkness" OR "spaces normally occupied by children or by adults not capable of self-preservation during periods of darkness." My original proposal was in 101-848, however, the Committee Action referenced hack to 101-847. The final proposed product for existing facilities was in proposal 101-872. SUBSTANTIATION: My primary concern is with any space that might be subject to occupancy by children during periods of darkness due to problems that arise with infants, toddlers, and small children when the iightin[g fails. The lack of lights increases the difficulty staff has in maintmning proper supervismn. It also compounds problems of maintaining order if evacuation is required. Infants in beds, toddlers on the floor, and small children able to move around in the dark would ~resent a challenge. Even where adults are involved, the failure of normal lighting creates a fear of what might be going on. If care and movement of adults that are incapable of serf-preservation is involved, the lack of lighting can be a real problem. In many areas where daylight savings time is used, a facility may have no problems part of the year, but will have several months when darkness occurs early in the morning or earlier in the evening. That was why I was asking that the wording be changed. Actions of staff to safeguard those in their care is greatly compromised dur ingper iods of darkness. It is an issue the code should better address. It is different than issues in schools where older children are involved. COMMITYEE ACTION: Reject. COMM/TrEE STATEMENT: See the Committee Statement for the rejection of Comment 101-$05 (Log #'251) on 10-2.9. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITIT~ ACTION:



101- 474 - (30-2.11.1 (c) and 21-2.2.3(c)): Accept in Principle SUBMITTER= Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-849, 101-611 RECOMMENDATION: We suggest that the two technical committees or the Correlating Committee review these proposals and ensure consistency between these requirements. - SUBSTANTIATION: The Chapter 30 Committee accepted a proposal submitted to them that was rejected by the Chapter 22 committee that were almost identical. There needs to be

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correlation between these items to ensure consistency in text and enforcement. COMMITTEE ACTION: Accept in Principle.

No further action needed. COMMrI*I'EE STATEMENT: The SAF-END Committee took the action that was appropriate for daycare occupancies when it prepared the ROP. The submitter seems to be concerned that the SAF-BCF Committee did not take a similar action for board and care occupancies. This is outside the control of the SAF-END committee. NUMBER OF COMMrI'FEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- 475 - ($0-3.5): Reject SUBMITITJI: Kenneth E. Isman, Nat'l Fire Sprinkler Assn. COMMENT ON PROPOSAL NO: 101-855 RECOMMENDATION: Accept Proposal 101-855 as submitted. SUBSTANTIATION: Loss of a day-care center would be terrible tragedy for any community. We have the affordable technology to prevent the situation. We should use the technology available. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter s substantiation seems to be addressing a property protection, and not a life safety, issue. See the committee statement for rejection of Proposal 101-855. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMrITEE ACTION:


EXPLANATION OF NEGATIVE: ENDTHOFF: My negative vote on Comment 101-313 (Log #241)

and 101-475 (Log #249) is because I disagree with the level of safety the code provides without fire sprinklers. Sprinklers can be installed without raising the cost of construction by properly applying the trade-ups m both the Life Safety Code and the building code. I believe the time is right to offer a higher level of protecuon and stop avoiding our responsibilities.

TROTTER: I stand on my remarks from the 1999 November Association Technical Committee ROP and support the statements made by Mr. Gene Endthoff, regardless of or lack of technical justification or statistics. It is time for the Life Safety Code to take the sprinkler advantage.

• (Log #373a) Committee: SAF-END

101- 476 - ($0-5.2.2 Exception, 31-5.2.2 Exception): Reject SUBM1TTER: Art Black, Carmel Fire Protection Assoc. COMMENT ON PROPOSAL NO: 101-859 RECOMMENDATION: Accept proposal as printed in the November 1999 (F99) ROP. SUBSTANTIATION: I serve as Chair of the NFPA Technical Committee on Carbon Monoxide and Fuel Gas Detectors (NFPA 720). I submitted this comment in response to the request from the Technical Correlating Committee on Safety to Life

At the ROP mee t ingfor the Technical Committee on Carbon Monoxide and Fuel Gas Detectors held in San Diego, California, the committee reviewed the Life Safety Code proposals referencing NFPA 720, Recommended Practice for Installation of Household Carbon Monoxide Warning Equipment.

While there was no official vote taken, the committee members present indicated that the reference to NFPA 720 in the appendix m both the proposals was appropriate. COMM1TIT~ ACTION: Reject. COMMITTEE STATEMENT: See the Committee Acdon on Comment 101-478 (Log #110a). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- 477 - ($0-5.2.2 Exception and $1-5.E2 Exception): TCC NOTE: The Technical Correlating Commiuee on Safety to Life (SAF-AAC) directs that the action on this comment be changed to aAccept in Principle. Reject Proposal 101-859." The SAF-END committee was pleased that the SAF-BSF committee supported the SAF-END's right to address the subject as done in theROP, but in the action on Comment 101-478 (Log #110a) the SAF-END committee reversed itself and rejected Proposal 101-859. Thus, for correlation purposes the action on Comment 101-477 (Log #110) needs to be changed, SUBMrUrER: Technical Correlating Committee on Safety tO Life COMMENT ON PROPOSAL NO: 101-859 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-BSF, which has primary responsibility for the building service systems provisions of NFPA 101, review Proposal 101-859 for correlation. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Retain the language of the Proposal. COMMITTEE STATEMENT: It is within the scope of SAF-END to modify the reference to NFPA 54 for these specific occupancies if there is sufficient technicaijustification to do so. If SAF-END addresses the comments from SAF-AAC there are no further correlation issues within NFPA i01. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 14 VOTE ON COMMITTEE ACTION:


BROWN: Having read the documentat ion on this proposal, and on the subsequent comments, I agree with the SAF-END action to ~Reject the Proposal" as outlined in their action on Comment 101- 479 (Log #357a). This also correlates with their actions on Comment 101.476 (Log #373a) and Comment 101.478 (Log #110a). I also agree with the statement provided by the Chair of the Technical Committee on National Fuel Gas Code (NFPA 54) substantiating his Comment that Proposal #101-859 (Log # CP763) should be rejected. Of importance to consider is the fact that NFPA 720 is a "Recommended Practice", not a Standard. I believe there is still a considerable amount of work and research that needs to be completed before 720 is released as a NFPA Standard. In the public interest, mandating CO detectors before there is a recogmzed NFPA installation standard should not be considered. It should be noted, the technical committee that is developing 720 has initiated the process through the Standards Council to have the scope of 720 to include fuel gas detectors, and address occupancies in addition to households. The SAF-BSF Committee Statement on Comment 101-477 (Log #110) affirms that the SAF-END is allowed to modify the requirements of NFPA 101, Chapters 1 through 7, as it applies to specific occupandes under their scope, *if there is sufficient technical justification to do so." Though it may seem the proposed change is a good idea, no documentation was presented that shows there is a problem with gas space heaters when installed under the requirements of NFPA 54.

JARDIN: Although there is no correlation problem, this requirement does present a scope concern. The Code, according to m scope, addresses life safety from fire. Given, in certain circumstances, carbon monoxide poisoning may be a real threat to many, it does not pose a threat to life safety from fire. Hence, I encourage the TCC to contemplate the need for CO detector mandates within NFPA 101.


101- 478 - ($0-5.2.2 Exception and 31-5.2.2 Exception): Accept in Principle SUBMrrTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-859 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-END:

(1) further justify its proposed use of NFPA 720 outside the scope of that document, and

(2) explain the inadequacies of the current text that requires the gas space heaters to be installed per the requirements ofNFPA 54. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

[ Reject Proposal 101-859. COMMITTEE STATEMENT: See the substantiation submitted by the Chair of the NTPA Technical Committee on National Fuel Gas Code in Comment 101-479 (Log #357a).

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AFFIRMATIVE: 14 N O T RETURNED: 1 Ewing

(Log #~57a) Commit tee : SAF-END

101- 479 - (~0-5.2.2 Except ion and M-5.2.2 Except ion) : Accept SUBMITTER: Mike Go tham, Nor thwest LP Gas Co. COMMENT ON PROPOSAL NO: 101-859

[ RECOMMENDATION: Reject t he proposal . S U B S T A N T I A T I O N : I serve as Chair of the NFPA Technica l Commi t t ee on National Fuel Gas Code (NFPA 54). I submi t t ed this c o m m e n t in response to the reques t f rom the Technical Correlat ing Commi t t ee on Safety to Life.

NFPA 54, Nat ional Fuel Gas Code, conta ins no r e q u i r e m e n t for CO detectors. The National Fuel Gas Code has venti lat ion r equ i r emen t s a n d combus t ion air r equ i r emen t s as well as o ther provisions which ensure tha t pe rmi t t ed installations are safe. The substant ia t ion d o c u m e n t s no n e e d e d level o f safety. Indeed, vent free hea ters (gas-fired) are requ i red to be equ ipped (by t he appropr ia te ANSI Z21 s tandard) with an oxygen deple t ion sensor (ODS) pilot which shu t s the un i t down before it begins p r o d u c i n g CO. The National Fuel Gas Code permi t s hea te rs so equ ipped a n d in l imited i npu t rat ings to be installed even in ba th rooms a n d bedrooms . ODS-equ ipped vent-free hea te rs have enjoyed a superb safety record - especially in relat ion to CO prob lems - s ince their in t roduct ion. T h e p roposed CO detec tors are simply n o t necessary for safety. The p roposed r e q u i r e m e n t shou ld be deleted. A suitable al ternate course may be to have the Except ion read: "Unvented gas space hea te rs equ ipped with an oxygen deple t ion sensor, built in accordance with the appropr ia te ANSI Z21 s t anda rd a n d instal led in compl iance with NFPA 54, National Fuel Gas Code." C O M M I T r E E ACTION: Accept . NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON C O M M I T T E E ACTION:

AFFIRMATIVE: 14 N O T RETURNED: I Ewing

(Log #220) Commit tee : SAF-END

101- 480 - (30-7.1 a n d M-7.1): Accept in Principle SUBMITTER= George M. Lanier , Rome Fire Dept. , GA COMMENT ON PROPOSAL NO: 101-868 RECOMMENDATION: Recons ider t he proposal with revisions. Change the titles o f 30-7.1 a n d 31-7.1 to "Fire Emergence, ResDonse Plans a n d Emergengy E m'ess and Relocat ion Drills ~.

Revise 30-7.1.1" and $1-7.1.1" a n d A-30-7.1.1 a n d A-$1-7.1.1 to read as p resen ted b e l o ~

Revise 30-7.1.1" a n d $1-7.1.1" to read as follows: "The faciliw shall have a comprehens ive writ ten fire emergency

re snonse nlan. Conies of the t~lan shall be m a d e available t o all cmniovees . All emnlovees shail be neriodicallv ins t ruc ted a n d kent i n fo rmed with resnec t to the dut ies-of their nosi t ion u n d e r the nlan. Emergency egress a n d relocat ion ~ drills, b ~ e d on t he writ ten fire e m e ~ e n c v resnonse plan. shall be conduc ted no t less t han once per m o n t h per shift. :]'he writ ten n l an a n d drills shall be des igned in coopera t ion with local authori t ies . Responsibil i ty for :kc ~l:.-::~'~g a.-~ the deve l onmen t of the written

the conduc t o f drills shall be assigne~i only to c o m p e t e n t site adminis t ra tors . ~: : ~ : ' . . . :m~:r: c~::~fic~ tz c : : : d : :

"~e~gT'gg0-7.1.1 and A-S1-7.1.1 to read as follows: ~ r h e requ i rements are of necessity genera l in scope, as it is

apprec ia ted tha t they apply to all types of day-care occupancies as well as condi t ions o f occupancies , such as t r uan t day-care occupancies; occupancies for the menta l ly hand icapped , the vision impmred , hea r i ng impaired, or speech impaired; adu l t day-care; care of infants; a n d day-care occupancies . It is fully recognized tha t no one code can m e e t all the condi t ions of ' the various bui ldings involved, a n d it will be necessary for site adminis t ra tors , t h r o u g h the writ ten fire emergency response plan. to issue s u p p l e m e n t s to these r equ i r emen t s , however, g u t all s u p p l e m e n t s shou ld be consis tent with these requ i rements . Additionally, it is r e c o m m e n d e d tha t fire safety be a par t of the educat ional p rograms of the occupancy for clients.

~'ire emergency re snonse n lans n e e d to be writ ten a n d m a d e ~vallable to all employees, i nc lud ing t empora ry or subst i tute staff. so evervone knows what is e x n e c t e d o f h i m or he r du r in g a fire emergency. The e lements n e e d e d in the writ ten n lan sh-ould be identif ied by the site adminis t ra tor in coordina t ion with the fire author i ty having Jurisdiction. T h e in ten t o f the nrovision is to stress the need fo r a written v lan of act ion tha t is based on a ore- fire evaluation o f the facility.- This nre-fire evaluation may indicate ~tle need to establish writ ten a t r reements with o the r facilities such as nea rby schools, churches , fire stat ions, etc. to act as t emnora rv shel ters for clients, or writ ten a~reemen t s with ambulance , bus. or taxi services to vrovide t camvor ta t ion of clients to shel ters or homes.

T h e facility, fire emergency resnonse n lan may be a m o d u l e of a facility disaster v lan wlaich covers o ther emergenc ie s such as. b u t is n o t l imited to. tornadoes , floods, ear thnuakes , terror is t attacks, etc. Dl.le to the fact fire is an immedia te in terna l threat , the fire emenzencv n l an nor t ion of the overall disaster n l an needs to be glearly identif ied-for ranid reference. T h e fire author i ty may also be a first r e snonde r for emergenc ies o the r t h a n fire. however, o ther a~encies w i ~ emergency re sponse resnonsibil i t ies shou ld be i n d u d e d in ore -emergency n lann ing . -Such agencies may include. be t are n o t l imited to~ law enforcement , emenzeney m a n a g e m e n t . bui ld ing utility services, a n d a rea medical services.

Wri t ten fire emergency response: p lans shou ld i n d u d e in format ion for emnlovees abou t m e t h o d s a n d devices available for a ler t ing occupant~ o f a fire emergency. Employeg~ shou ld know how the fire d e n a r t m e n t is to be alerted. Even where au tomat ic ~vstems are expected to alert the fire deva r tmen t , the writ ten p lan shou ld nrovide for back-up aler t ing p rocedures by ~taff.

In day-care fadlities, t he n r o n e r sa feguard ing of clients du r ing a fire emenzencv reoui res n r o m n t a n d e~fective respqnse by the facility emnlovees in accordance with the fire emergency resnonse nlan. Dudes covered u n d e r the n lan shou ld be ass igned b y - posi t ion ra ther t han by employgg name . This i~ t9 ~nsure, tha t in the absence o f an emvlovee, the dut ies o f the nosi t ion will be n e r f o r m e d by the subst i tute or t empora ry emnioy~;g assimaed to the, posit ion. T e m n o r a r v or subst i tu te employees shou ld be ins t ructed regard ing t h e l r duties u n d e r the n lan for the posi t ion to which they are assigt~ed prior to a s suming t he posit iqn.

T h e basic r e snonse o f emnlovees to a fire emergency shou ld include, bu t are n o t l imited to. removal o f client~ i a immed ia t e dange r to areas 9 f safety as set for th in the plan. the t ransmission of the annronr ia t e fire a la rm simaal t,¢ alert o the r bu i ld ing occupants . methocls o f u s ing bui ld ing features to conf ine the fire an d its byproducts to the r o o m or area of origin, the control o f act ions a~cl behaviors of clients d u r i n g removal or evacuat ion activities an d at n r e d e t e r m i n e d sa£e assembly areas, a n d p rocedures to follow t9 have clients t ransrmrted to o the r ~cilitie~ or plac, cgl with family m e m b e r s shou ld r e tu rn to the facility, no t be possible,

The writ ten n lan shou ld stress the impor t ance o f havimt emnlovees, especially m a n a g e m e n t staff, cooperaf;¢ and coordinat~ w i ~ the fire c[enarmaent m a n a g e m e n t on the scene. Th e nerson in charge of the f~:ilitv a t the t ime of the emenzenc? / shou ld foe resnonsible for n romnt lv r e n o r f n g , to the fire officer in charge. in format ion ret~ardin~ the locat ion o f the fire. s tatus of e l ien~ an d staff, act ions taken by staff vr ior to fire d e n a r t m e n t arrival, an d o ther informat ion tha t may be d g e m e d in~nortant or as m ay be reoues ted by the officer.

T-he writ ten n lan shou ld state clearly the facility, policy regard ing the act ions sta~ff shou ld take or n o t take to ext intmish a fire. In general , o ther emer~tencv act ions focused on the safet, abardin~t of clients shou ld have vriot:itv. T h e nrovis ions of $0-7.1.9 (M-7_1.9) a n d A-g0-7.1.9 tA-M--7.I.9~- s h m d d - b e cons idered for drills. In an actual f'vre emergency , where a fire is very small a n d smoke condi t ions are light, or where a fire is on or is an immedia te th rea t to a client, exf in~mishment act ion may he war ran ted so long as o the r staff is anal]able to carry ou t o the r e m e m e n c v ac t i o n s se t for th u n d e r the vlan. Staff needs to be t ra ined in tlae use of nortable fire ext inguishers tha t are _ nrovided, as well as the opera t ion of fire nro tec t ion systems reou i r ing mat~ual action.

The written fire emergency, response p lan m u s t incort>orate the, e m e ~ e n c y e ~ e ~ and relocation drill p rocedures as set for th in

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$0-7.1 (31-7.1L with appronriate supplements issued by the site administrator." SUBSTANTIATION: The proposed changes stress the need for day-care facilities to develop a comprehensive written fire emergency response plan to be used for the pre-fire training of staff and for use during a fire related emergency. Without a written plan, the odds increase of things going wrong during an actual fire emergency. COMMITTEE ACTION: Accept in Principle.

Insert a new $0-7.1 and $1-7.1 before the new $0-7.1 and $1-7.1 being created by Proposal 101-867; and renumber $0-7.1/31-7.1 through $0-7.4/31-7.4 to become $0-7.2/31-7.2 through 30-7.5/31-7.5.

30-7.1"/$1-7.1" Fire Emergency Response Plans. The facility shall have a comprehensive written fire emergency response plan. Copies of the plan shall be made available to all employees. All employees shall be periodically instructed and kept reformed with respect to the duties of their position under the plan.

A-$0-7.1/A-$1-7.1 The reqm'rements are of necessitygeneral in scope, as it is appreciated that they apply to all types o f day-care occupancies as well as conditions of occupancies, such as t ruant day-care occupancies; occupancies for the mentally handicapped, the vision impaired, hearing impaired, or speech impaired; adult day-care; care of infants; and day-care occupancies. It is fully recognized that no one code can meet all the conditions of the various buildings involved, and it will be necessary for site administrators, through the written fire emergency response plan, to issue supplements to these requirements, however, all supplements should be consistent with these requirements. Additionally, it is recommended that fire safety be a part of the educat ionalprograms of the occupancy for clients.

Fire emergency response plans need to be written and made available to all employees, including temporary or substitute staff, so everyone knows what is expected of him or her during a fire emergency. The elements needed in the written plan should be identified in coordination with the authority having jurisdiction.

The facility fire emergency response plan may be a module of a facility disaster plan which covers other emergencies.

The proper safeguarding of clients during a fire emergency requires prompt and effective response by the facility employees in accordance with the fire emergency response plan. Duties covered under the plan should be assigned by position rather than by employee name. This is to ensure, that in the absence of an employee, the duties of the position will be performed by the substitute or temporary employee assigned to the position. Temporary or substitute employees should be instructed regarding their duties under the plan for the position to which they are assigned prior to assuming the position.

Written fire emergency response plans should include, but are not limited to, information for employees about methods and devices available for alerting occupants of a fire emergency. Employees should know how the fire depar tment is to be alerted. Even where automatic systems are expected to alert the fire department, the written plan should provide for back-up alerting procedures by staff. Other responses of employees to a fire emergency should include removal of clients in immediate danger to areas of safety as set forth in the plan, methods of using building features to confine the fire and its byproducts to the room or area of origin, the control of actions and behaviors of clients during removal or evacuation activities and at predetermined safe assembly areas.

The written plan should state clearly the facility policy regarding the actions staff should take or not take to extinguish a fire.

The written fire emergency response plan needs to incorporate theemergency egress and relocation drill procedures as set forth in 30-7.2 ($1-7.2). COMMITTEE STATEMENT: The Committee Action adopts most of what the submitter requested. It splits the requirements applicable to fire emeregency response plans from that applicable to emergency egress and relocation drills. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 14 NOT RETURNED: 1 E w i n g


101- 481 - ($0-7.3.4 and 31-7.3.4): Reject SUBMITTER: George M. Lanier, Rome Fire Dept., GA COMMENT ON PROPOSAL NO: 101-869 RECOMMENDATION: Recommend reconsideration of action to delete $0-7.$ and $1-7.3.4. Rather than deleting the provisions, add an exception to read as follows:

Exception: Where automatic sprinkler protection is provided. SUBSTANTIATION: I agree v~th Mr. Trotter's basic negative response, however, I feel that in sprinkler protected structures the risk of spread from a waste container fire is minimized. I would agree that there have been few problems, however, with small children having access to lighters and matches at home, why risk fires in waste containers should they bring them to school? Also, smoking by staff and visitors in some areas is still a potential risk due to careless discard. This has been a long standing provision. I feel we should retain it at least in unsprinklered facilities. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: See the substantiation for Proposal 101-869. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12 NEGATIVE: 2 NOT RETURNED: I Ewing

EXPLANATION OF NEGATIVE: BARTLE'I~: "No data has been provided to show that the

removal of non combustible waste containers will improve life safety. In fact, the continued use of non combustible waste containers will help retard fire spread in the event of a fire within the container, thus permitting more time for evacuation and therefore improving the margin of life safety."

TROTTER: It seems today that many proposals, comments and committee actions are statistic driven. At thts time, there is no substantiating data collected or presented to maintain current code language regarding wastebaskets and other waste containers to be made of noncombustible or other approved materials. However, the printed remarks of Mr. George M. Lanier and the Southern Regional Fire Code Development Committee acknowledge the associated hazard of combustible waste receptacles in day-care occupancies. The Tennessee Fire Code Development has also expressed their support to maintain the $0-7.$.4 and $1-7.$.4 requirements. I am sorry but I do not have the date or substantiating data as to when or why this issue became a requirement. However, the technical committee evidendy believed that there did exist a life safety hazard from fire in day-care occupancies as a result of a wastebasket or other waste container fire. Therefore, I believe that the same risk is present today and the existing code language should remain.


101- 482 - ($0-7.$.4 and 31-7.$.4): Reject SUBMITrER: Southern Regional Fire Code Dev. Committee COMMENT ON PROPOSAL NO: 101-869 RECOMMENDATION: Reconsider the Committee Action and reject the proposals. SUBSTANTIATION: We agree with the negatives comments of Trotter. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See the substantiation for Proposal 101-869. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: BARTLETr: "No data has been provided to show that the

removal of non.combustible waste containers will improve life aafety. In fact, the continued use of non combustible waste containers will help retard fire spread in the event of a fire within the container, thus permitting more time for evacuation and therefore improving the margin of life safety."

TROTTER: It seems today that many proposals, comments and committee actions are statistic driven. At this dme, there is no substantiating data collected or presented to maintain current code language regarding wastebaskets and other waste containers to be made of noncombustible or other approved materials. However, the printed remarks of Mr. George M. Lanier and the Southern

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Regional Fire Code Development Committee acknowledge the associated hazard of combustible waste receptacles in day-care occupancies. The Tennessee Fire Code Development has also expressed their support to maintain the $0-7,$.4 and $1-7.$.4 requirements. I am sorry but I do not have the date or substantiating data as to when or why this issue became a requirement. However, the technical committee evidendy believed that there did exist a life safety hazard from fire in day-care occupancies as a result of a wastebasket or other waste container fire. Therefore, I believe that the same risk is present today and the existing code language should remain.


101- 483 - (Chapter $1): Accept in Principle SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-872 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-END revise its reference to "single-station smoke detectors" so as to use the term "smoke alarms for correlation with NFPA 72 and other chapters of NFPA 101. For example, see 51-6.5.4.5 where such a change is needed.

Further, SAF-AAC takes the opportunity to use this note to flag that a similar change needs to be made to 30-6.3.4.2. Although no ~rrOposal was generated on this paragraph, SAF-END should feel

ee to make the change during ROC-preparation for correlation purposes. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

Revise 30-6.3.4.3 (not 30-6.3.4.2) to change the word "detectors" to "alarms" so as to read:

"Single-station smoke alarms in accordance with...". Revise 3I-6.3.4.3 to change the word "detectors" to "alarms" so as

to read: "Single-station smoke alarms in accordance with...". Revise the exception to $1-6.3.4.3 so that in three places the word

"detectors" is replaced with the words "smoke alarms". COMMITTEE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- 484- (31-1.6): Reject SUBMrrrER: Craig V. Mayer, Pleasanton, CA COMMENT O N PROPOSAL NO: 101-872 RECOMMENDATION: Change the information in the ~Level of exit discharge" row of Table $1-1.6 for nonsprinklered buildings from "Any type" to "I(443), I(332), II(222), II(111), 1I(000), III(211), IV(2HH), V(111)". SUBSTANTIATION: Table 31-1.6.1 in the 1997 edition of the Life Safety currently requires fire sprinkler protection for day-care on the "floor of exit d ischa~e" in Type III(200) and Type V(000) construction when the chents are younger than 6 or "non capable of serf-preservation". The proposed Table $1-1.6 would permit an identical day-care to exist without fir sprinkler protection. It would then be possible to have an unlimited number of infants and toddlers in an uusprinklered combustible structure. (NFPA 150 would not permit such a structure to be used as a stable for horses.) The technical committee has not provided any substantiation for deleting these sprinkler requirements that first appeared in the 1973 edition.

T h e Technical Committee's substantiation states the changes to Table $1-1.6.1, "...reflect the results of the committee's deliberations of three years al~o when Table $0.1.6.1 for new day- care occupancies was revised. This statement is incorrect. Table $0-1.6.1 in the 1997 edition is identical to Table 10-7.1.6.1 in the 1994 edition. (See my related comment on Proposal 101-838 that discusses the misleading substantiation for the changes to the table that occurred in the 1994 edition.)

The changes proposed by the committee three years ago (1996 Fall Meeting ROP, Proposal 101-587) were to this same table for existing day-care centers. Then as now, the substantiation for that proposal did not mention reducing sprinlder requirements or provide any justification for such a deletion. It stated that most of the changes resulting from the separation of day-care from the

chapters on educational occupancies were, "...almost entirely editorially (sic) in nature." It did identify a few noneditorial changes, but made no mention of reducing sprinkler requirements. I challenged the lack of substantiation for that proposal in Item 101-485 in the 1996 Fall Meeting Report on Comments (ROC). My comment was accepted and these sprinkler requirements were retained in the 1997 edition. The committee statement published in the 1996 Fall Meeting ROC implied their proposal at that time deleted these sprinkler requirements because of an "oversight".

Please don ' t let a few members of the technical committee slip these changes through this time. If those individuals had technical reasons to support their continuing efforts to delete these sprinkler requirements, they would not have to hide them in changes to entire chapters and could address the deletion of sprinkler requirements in their substantiation. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: See the Committee Statement associated with the rejection of Comment 101-470 (Log #305) which addresses the same subject for Chapter 30 and how the issue was processed for the 1997 edition of the Code. Chapter 31, applicable to existing day-care occupancies, now needs to be changed for correlation. See the ROP substantiation for Proposal 101-872, especially the second paragraph. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITI'EE ACTION:



101- 485 - (32-7.2 Access Openings and $-2): Accept SUBMITrER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-877 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-IND clarif~ its action. The committee action refers to a "current" definition m Section $-2 that doesn' t exist. If the definition of Emergency Access Openings is to appear in $2-7.2, then do not repeat it in entirety in Section g-2. Rather, the entry in Section $-2 should read: "Emergency Access Openings. (See $2-7.2.)" Also, the appendix note should be appended to the $2-7.2 definition, not to Section $-2. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept.

I Add the following to $-2: "Emergency Access Openings. (See 32-7.2.)"

COMMITTEE STATEMENT: The Committee concurs with the action of the TCC to add the reference as noted above in 3-2 and retain the current appendix note for $2-7.2 access opening (d). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITrEE ACTION:


(Log #341c) Committee: SAF-IND

101- 486 - (Section $2-8): Hold SUBMITFER: Peter W. Szerlag, Arlington, MA COMMENT ON PROPOSAL NO: 101-2 RECOMMENDATION: I do not know where these two items might fit into NFPA 101. [Note: This comment has been assigned to SAF-FUN, SAF-FIIL SAF-BSF and SAF-IND.]

1. Every door shall have knockout panels at the bot tom to allow a fire hose to be run through the door while retaining the fire control and smoke control attributes/capabilities of the door.

2. Every high rise building shall have smoke exhaust equipment on every floor (above the seventh floor) which can be remotely activated by the fire department via radio remote control. SUBSTANTIATION: Item 1 - serf evident

Item 2 - This item mirrors the recent FAA allowance of fire detection and fire suppression systems on planes which are interconnected via spread spectrum radio finks. COMMrITEE ACTION: Hold. COMMITTEE STATEMENT: The committee only acted on the second part of this comment. The first part is the responsibility of another technical committee and should be addressedby them. The second part of this comment inttoduces new material which should be held for the next revision cycle. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12

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N F P A 101 - - F99 R O C

VOTE ON COMM1TFEE ACTION: AFFIRMATIVE: 11 NOT RETURNED: 1 Holmes


101- 487 - (A-1-3, A-3-2 Building, Existing): Accept in Principle SUBMITTER= Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-886 RECOMMENDATION: Move to current A-I-$ (which has been renumbered A-1-4 by the action on Proposal 101-3), first

~. a~raph, the material being deleted from A-5-2 Building, isling, so as to read:

A-1-3 It is the intent of this section that a building, addition, or alteration design to meet the requirements of a prior edition of the Code be required to meet those requirements for the life of the building. Requirements for existing buildings in this edition of the Code would apply if those requirements are more resa-ictive. Itis intended that the initial assessment of the building, when new. should he based on new occuoancv reauirements for the edition of the Code ill effect on the date of o'lan aDnroval. Subseauent i~¢~ments of the buildin~ should be b-a(sed on new occuoancv reouirements of that sameedition of the Code for the life of the

SUBSTANTIATION: Per committee statement to proposal 101- 886, this language was deleted from A-5-2 because it related to application, not definition. This comment moves the sentences to

lication where it belongs. EE ACTION: Accept in Principle.

Move to current A-l-3 (which has been renumbered A-l-4 by the i action on Proposal 101-$), first paragraph, the material being ! deleted from A-$-2 Building, Existing, so as to read:

A-1-3 It is the intent of this section that a building, addition, or alteration design to meet the requirements of a prior edition of the Code be required to meet those reguirements for the life of the building. I~ is intended that the initial assessment of the building. w~en new. should be based on new occunancv reauirements for the edition of the Code in effect on the date of plan anoroval. $~sqauen t assessments of the buildin~ should-be base-d on new occupancy, re(luirements of that same edition of the Code for the

Requirements for existing buildings in this edition of the Code would apply if those requirements are more restrictive. COMMITTEE STATEMENT: The Committee Action accomplishes what the submitter suggested but reorganizes the order of the sentences for clarity. This should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 488 - (A-1-$.15.2): Reject SUBMITrER= Philip R. Jose, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-884 RECOMMENDATION: Add the following as a new paragraph to apj~endix A-1-3.1 $.2:

his section is not intended to require redundant emergency lighting to be tested and maintained in accordance with the requirements of 5-9.$ where the primary emergency lighting equipment is installed and tested in accordance with all requirements of Section 5-9." SUBSTANTIATION: To permit the use of backup lighting without having to purchase 1 1/2 hour duration lights or meet the monthly test frequency. COMMII~I'EE ACTION: Reject. CO MIIq'EE STATEMENT: The submitter's proposed language still is not needed. See the Committee Statement for rejection of Proposal 101-884 in the ROP. NUMBER OF COMMITgF~ MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 12


101- 489 - (A-1-9.2): Accept in Principle SUBMITTER: Martin H. Reiss, The RJA Group, Inc. COMMENT ON PROPOSAL NO: 101-885 RECOMMENDATION: Accept original proposal as new A*I-g.2 with the words ~a basis" changed to "one option ~. Also add the sentence: "Other options to performance-based design are in Chapter 3". SUBSTANTIATION: This will provide guidance to the authority having jurisdiction and allow h im/her to compare a code compliant design with an equivalent design directly. Many authorities having jurisdiction are doing this when they have this guidance. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-34 (Log #176) on A-1-9.2. COMMITTEE STATEMENT: The action on the referenced comment should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 12 VOTE ON COMMITI'EE ACTION:

AFFIRMATIVE: 12


101- 490 - (A-5-2.2.3.3): Reject SUBMITrER= Lawrence G. Perry, Building Owners and Managers Assn. Int'l (BOMA) COMMENT ON PROPOSAL NO: 101-895 RECOMMENDATION: Delete the entire parenthetical reference to a specific ASTM standard:

"...acceptable as slip resistant ~t^- ~c~cfi~c~ b)" Y~.'I~.~ F!~g7 95 , , e ~ a ^ . a n- - . . : . ^ cA. ¢~¢^ XAr̂ IL:---- e....c . . . . ~ provide adequate slip resistance." SUBSTANTIATION: (Note: ff deletion of the entire parentheticalphrase is ruled to be beyond the permitted scope of a comment to this proposal, then this proposal seeks to simply delete the added text, which references a specific ASTM standard).

The proposal implies that a reference to a specific ASTM standard is he lpful because the referenced standard includes definitions of the terms "slip resistant" and ~slip resistance'. If the Committee feels that these definitions are helpful, the definitions should simply be added to the appendix. By referencing the ASTM standard, the Committee is implying an endorsement or recommended use of the entire standard. There are several standards on slip resistance currently available, and at least one additional one under development.

Adding any implied reference to a standard on slip resistance solely for stair treads appears inconsistent - if this information is essential, it should be equally addressed for all walking surfaces, COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The words "as described by ASTM F1657" do not imply endorsement and recommended use of the entire standard. It is helpful appendix material. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 27 VOTE ON COMMITTEE ACTION:


(Log #115) Committee: SAF-FU R

101- 491 - (A-6-5.3.1.5, A-6-5.4.1, and A-6-5.5.1 (New)): Accept in Principle SUBMI11"ER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-906 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUR reconsider the proposal's references to 5-6.7 and A-5-6.7 given that those paragraphs will not be created because Proposal 101-15 is being rejected. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

Revise the new paragraph being added to A-6-5.3.1.5 to read: ~I'he test results from NFPA 255, Standard Method of Test of

Surface Burning Characteristics of Building Materials, are suitable for classiiicationpurposes but should not be used as input into fire models because they are not generated in the appropriate :==~=:¢-=g units suitable for en~neer ing calculations. Actual test

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N F P A 101 - - F 9 9 R O C

results, for heat, smoke and combustion product release, from NFPA 265, Standard Method of Fire Test for Evaluating Room Fire Growth Contributions of Textile Wall Coverings, might be suitable for use as input into lure models for performance-based design.




101- 492 - (A-6-6.1, A-6-6.2, A-6-6.3, A-6-6.4, and A-6-6.7 (New)): Accept in Principle SUBMITTER= Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-910 RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-FUR reconsider the proposal's five references to $-6.7 and A-3-6.7 given that those p~. ~ p h s will not be created because Proposal 101-13 is being rejected. SUBSTANTIATION: See the above recommendation. COMMITTEE ACTION: Accept in Principle.

| Delete "See 3-6.7 and A-3-6.7 from A-6-6.1, A-6-6.2, A-6-6.3, A-6-6.4, and A-6-6.7. In A-6-6.1 and A-6-6.2 revise to read:

[ "...not generated in the appropriate : :~n=c . - 'ng units suitable for I engineering calculations."

COMMITI'EE STATEMENT: The Committee Action should meet the submitter's intent. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 15 VOTE ON COMMITTEE ACTION:



101- 493 - (A-8-4.1.3, A-9-4.1.3): Reject SUBMFFrER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-333 RECOMMENDATION: Reject proposal 101-333. SUBSTANTIATION: The two negatives address most of the reasons. This is not appropriate even for an appendix note. It does nothing more than cut down some more trees. If needed, have staff put it in the LSC Handbook. COMMITIT~ ACTION: Reject. COMMITTEE STATEMENT: The information provided by the Appendix is useful, especially in view of the expansion of the Appendix material being made by Comment 101-289 (Log #cc252). NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITTEE ACTION:


EXPLANATION OF NEGATIVE: GERDES: I believe that this material should be deleted from the

code. The evaluation is a un iqueper formance issue which goes beyond the typical prescriptive code. I question the scope and depth of the analysis and whether such evaluation can be completed without adequate and validated informational sources. The Code will establish a high level performance issue that one cannot resolve. Identifying all possible scenarios itself could be a career. The potential liability for owners and designers is tremendous.

MILLER: Even though there are some important factors to be considered, this proposal ~oes well beyond the scope of this document to many areas mat have no science, engineering basis, or answers. It is a list of items that in many instances, if there were definitive answers to, no one would know what to do with the answers and their impact in relation to specific design of a building.


101- 494 - (A-12-3.4.3.1): Reject SUBMITrER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-919 RECOMMENDATION: Accept the appendix note as proposed. SUBSTANTIATION: Given activity to accept to submltter's concept within Code - Section 12-3.4.3.1 this appendix note or modification should be acceptable. COMMIaq'EE ACTION: Reject. COMMITTEE STATEMENT: See Comment 101-335 (Log #381), Comment 101-334 (Log #378), and Comment 101-332 (Log #147) - all on 12-3.4.3.1. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 18 VOTE ON COMMITTEE ACTION:



101- 495 - (A-21-1.1.1): Accept in Principle TCC NOTE: The Technical Correlating Committee on Safety to Life (SAF-AAC) notes that Mr. Lathrop, in his C o m m e n t on Affh'mative, opines that readers should not have to go look for a co!~y of a formal interpretation to understand the committee action. SAF-AAC advises that the recommended text appears - in entirety - in the ROP in Proposal 101-925a. SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-925a RECOMMENDATION: The Technical Correlating Committee on Safety to Life (SAF-AAC) requests that SAF-RES consider the action taken by SAF-AAC on this proposal; revise the wording as necessary; and retire F.I. 101-948. SUBSTANTIATION: See the above recommendation. COMMITrEE ACTION: Accept in Principle.

I ccept Proposal with the following revision: Delete the quotation marks around "a person or couple (2 people)

and the children which they raise." COMMITTEE STATEMENT: This statement was copied directly from Question No. 1 of the Formal Interpretation request. The quotation marks are not necessary in the text of the appendix. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 24 VOTE ON COMMITrEE ACTION:


COMMENT ON AFFIRMATIVE: LATHROP: The revision needs to be included in the Committee

Action. Readers of the ROC should not have to go find an F.I. to understand what is going on.

(Log #CC,501) Committee: SAF-BCF

101- 496- (A-23-1.$): Accept SUBMrrTER: Technical Committee on Board and Care Facilities COMMENT ON PROPOSAL NO: CP852 RECOMMENDATION: A-23-1.3 Evacuation Capability. The evacuation capability of the residents and staff is a function of both the ability of the residents to evacuate and the assistance provided by the stale It is intended that the evacuation capability, be determined by the procedure acceptable to the authority having jurisdiction. It is also intended that the timing of drills, the rating of residents, and similar actions related to determining the evacuation capability be performed by persons approved by or acceptable to the authority having jurisdiction. The evacuation capabili~ can be determined by the use of the definitions in 22-1.$, the apphcation of NFPA 101A, Guide on Alternative Approaches to Life Safety, Chapter 5, or a program of drills (timed).

Where drills are used in determining evacuation capability, it is suggested that the facility conduct and record fire drills six times per year on a bimonthly basis, with a minimum of two drills conducted during the night when residents are sleeping, and that the fadlity conduct the drills in consultation with the authority having jurisdiction. Records should indicate the time taken to reach a point of safety, date and time of day, location of simulated fire origin, the escape paths used, and comments relating to residents who resisted or failed to participate in the drills.

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I Translation of drill times to evacuation capability may be determined as (1) 3 min or less, prompt; (2) over 3 min, but not in excess of 13 min, slow;, and (3) more than 13 rain, impractical.

Evacuation capability in all cases is based on the time o f day or night when evacuation of the facility would be most difficult (e.g., sleeping residents or fewer staff present).

Where the facility management does not furnish an evacuation capability determination acceptable to the authority having jurisdiction, the evacuation capability should be classified as impractical. However,

Evacuation capability determination may should be considered slow if the following conditions are met:

(a) All residents are able to travel to centralized dining facilities without continuous staff assistance, and

(b) There is continuous staffing whenever there are residents in the facility. SUBSTANTIATION: Committee Proposal 101-926 intended for both A-22-1.$ and A-25-1.3 to be modified. However, the paragraph reference in the text of the recommendation was only for A-22-1.$. This comment addresses the intent of the committee in the proposal. COMMITTEE ACTION: Accept. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 16 VOTE ON COMMITTEE ACTION:

AFFIRMATIVE: 16

(Log #CC550) Committee: SAF-MER

101- 497 - (A-26-2.3.2): Accept ] TCC NOTE: The Technical Correlating Committee on Safety to I Life (SAF-AAC) notes that the second sentence o f A-26-2.3.2 (i.e., ] ~lt is the intent o f this provision. . . ' ) , shown in the ] recommendat ion f ield below, should appear in the strikethrough ] format because it is meant to be deleted.

SUBMITIT_~ Technical Committee on Mercantile and Business Occupancies COMMENT O N PROPOSAL NO: 101-775 RECOMMENDATION: Revise A-~6-2.3.2 to read:

A-26-2.3.2 It is not the intent of this provision to apply to noncorridor or nonpassageway areas of the exit access such as the spaces between rows of desks created by office layout or low height partitions. It is the intent of this provision to require the all corridors and passageways be at least 44 in. (112 cm) in width (wider if serving an occupant load of more than 220 persons) regardless of occupant load served (i.e. small number of persons). SUBSTANTIATION: The deletion of the second sentence is for a correction of an omission. Proposal 101-775 (Log #CP915) revised the requirements for the minimum width of a corridor. This revision eliminates a potential conflict with the main body of the text. COMMITTEE ACTION: Accept. N U M B E R OF COMMYIWEE MEMBERS ELIGIBLE TO VOT]~ 19 VOTE ON COMMITTEE ACTION:


PART II


102- 1 - (Entire Document): Reject SUBMITTER: James IL Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 102-1 RECOMMENDATION: Reject the proposal, remove from NFPA 101 all material transferred to NFPA 101 in this Report on Proposals (egress provisions previously moved to NFPA 101 would stay in NFPA 101). SUBSTANTIATION: This is a MAJOR mistake. The building codes refer to NFPA 102. By moving the material into NFPA 101, much of which has nothing to due to the scope of NFPA 101, this will all be for nothing. We all know that the building codes will not refer to NFPA 101. To use NFPA 102 as a pawn m this battle is a disservice to the industry. This might look good on someone's master plan but it does nothing for safety issues involved. Keep NFPA 102 as it is with the egress provisions in NFPA 101. Reenter NFPA 102 into the next code cycle and reconsider all proposals. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: The submitter's substantiation is non-persuasive. With the withdrawal of NFPA 102, material with which the SAF-AXM committee has expertise will be transferred to NFPA 101. The material being deleted, so that it will not appear in NFTA 101, addresses construction subjects that the SAF-AXM committee is not prepared to maintain. The proposal to withdraw NFPA 102 was done with full knowledge that the construction requirements might need to be p ickedup by some other organization. N U M B E R OF COMMrlTEE MEMBERS ELIGIBLE TO VOTE: VOTE ON COMMITIT.E ACTION:

AFFIRMATIVE: 19 NEGATIVE: 1 NOT RETURNED: 3 Cich, Conner, Maddox

EXPLANATION OF NEGATIVE: SUTTER: This is in support of my negative vote on this item, I

certainly agree with the submitter that NFPA 102 should be

~ reserved. I feel that the interests of the users of this document are e'm~ poorly met by its incorporation into NTPA 101. NYPA 102 had long been regarded as the authority on the design,

construction, operation, and maintenance of folding and telescoping seating and bleachers and grandstands. At one time, it incorporated everything from design loads to egress requirements. It dealt with safety to life in relation to fire, storm, collapse and crowd behavior. Anyone having questions concerning equipment covered by this standard could turn to it and find his answers. It had been a compact document, concise and to the point. To my mind, trouble started when the sections dealing with means of egress were eliminated from the 1992 edition. The intention of Proposal 102-1 (Log #CP1) is to dismantle totally NFPA 102, entrust the structural provisions to the model codes, and spread the remainder th rough the Life Safety Code, in spite of the fact that the Life Safety Code specifically deals only with safety from fire. In my opinion, the results of dismantling NFPA 102 will be:

-Elimination of a valuable design and operating tool for those involved with bleachers, grandstands and folding telescopic seating.

-Introduction of a labyrinth of rules and regulations through which the designers, builders and operators of this specific type of equipment must wade before being able to collect all the data pert inent to their projects.

-Or (heaven forbidl) discontinued use of NFPA I01, and more heavily reliance on the model building code.

One of the dangers of being on a committee such as NFPA 101 and having intimate knowledge of the document with which one works is the possibility of believing that the document is a goal in itself. Equally important is the usability of the document. I believe that the pragmatic approach of handling the subject matter of NFPA 102 by discarding some and dispersing the rest among the various chapters of NFPA 101 serves more the purposes of the committee than the needs of the people trying to design, build, and operate by it. Rather, than dispense with NFPA 102, I would recommend that consideration be given to restoring it to its pre- 1992 scope and content. The pubh"c would be better served.

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Documents

~ Chair SAF-FUR · NFPA 101 -- F99 ROC Technical Committee on Board and Care Facilities (SAF-BCF) (Chapters 22 and 23) Philip C. Favro, Chair Favro Assoc., CA [SE]