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Public Input No. 166-NFPA 25-2017 [ Global Input ] Remove all references to the NFPA 25 Handbook, Water-Based Fire Protection Systems Handbook including but not limited to all or portions of: A.5.3.3, A.6.3.1, A.7.3.1, A.7.3.2, A.8.3.2, A.8.3.3, A.8.3.6.4, A.9.3, A.9.3.3, A.9.3.4, A.9.3.5, A.9.5.3 and H.1.1. Statement of Problem and Substantiation for Public Input The text of the handbook is not reviewed by the technical committee and should not be referenced by the annex. Submitter Information Verification Submitter Full Name: Robert Upson Organization: National Fire Sprinkler Association Affilliation: NFSA Engineering and Standards Committee Street Address: City: State: Zip: Submittal Date: Tue Jun 27 10:07:17 EDT 2017 Committee Statement Resolution: FR-1-NFPA 25-2017 Statement: The text of the handbook is not reviewed by the technical committee and should not be referenced by the annex. The reference to the NFPA 25 Handbook has been relocated to H.2.1 as an information reference. National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara... 1 of 308 1/24/2018, 9:15 AM

Public Input No. 166-NFPA 25-2017 [ Global Input ]...Public Input No. 166-NFPA 25-2017 [ Global Input ] Remove all references to the NFPA 25 Handbook, Water-Based Fire Protection SystemsHandbook

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  • Public Input No. 166-NFPA 25-2017 [ Global Input ]

    Remove all references to the NFPA 25 Handbook, Water-Based Fire Protection SystemsHandbook including but not limited to all or portions of:A.5.3.3, A.6.3.1, A.7.3.1, A.7.3.2, A.8.3.2, A.8.3.3, A.8.3.6.4, A.9.3, A.9.3.3, A.9.3.4, A.9.3.5, A.9.5.3and H.1.1.

    Statement of Problem and Substantiation for Public Input

    The text of the handbook is not reviewed by the technical committee and should not be referenced by the annex.

    Submitter Information Verification

    Submitter Full Name: Robert UpsonOrganization: National Fire Sprinkler AssociationAffilliation: NFSA Engineering and Standards CommitteeStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 10:07:17 EDT 2017

    Committee Statement

    Resolution: FR-1-NFPA 25-2017Statement: The text of the handbook is not reviewed by the technical committee and should not be referenced by

    the annex. The reference to the NFPA 25 Handbook has been relocated to H.2.1 as an informationreference.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

    1 of 308 1/24/2018, 9:15 AM

  • Public Input No. 3-NFPA 25-2017 [ Global Input ]

    1. Add a new paragraph 6.3.1.1.2 to read as follows:

    6.3.1.1.2 Pressure gauges maintained in accordance with 8.3.3.2.2 shall be provided for the test.2. Revise paragraph 6.3.1.6.2 to read as follows:

    6.3.1.6.2 Pressure gauges maintained in accordance with Chapter 13 shall be provided for the test.

    Additional Proposed Changes

    File Name Description ApprovedTIA_25_17_1_-_TIA_25_17_1.pdf TIA_25_17_1

    Statement of Problem and Substantiation for Public Input

    NOTE: This public input originates from Tentative Interim Amendment No. 17-1 (Log 1221) issued by the Standards Council on August 4, 2016 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the Document.

    Substantiation. The committee statement for SR-16 stated: The accuracy for the measuring devices used in the 5 year waterflow test should be comparable to that for a fire pump flow test and not just equivalent to the minimum level accepted on a sprinkler system gauge. Unfortunately, the change was made to gauges required by section 6.3.1.6.2 that apply only to the main drain test. 6.3.1.6 A main drain test shall be performed on all standpipe systems with automatic water supplies in accordance with the requirements of Chapter 13. The current change now requires a standpipe main drain test to use gauges with an accuracy of 1% whereas all other systems have a 3% allowance. Additionally, the 5-year water flow test still allows an accuracy of only 3%. Emergency Nature. The NFPA Standard contains an error or an omission that was overlooked during a regular revision process.

    Submitter Information Verification

    Submitter FullName: Tc On Inm-Aaa

    Organization: NFPA

    Affilliation: TC on Inspection, Testing, and Maintenance of Water-BasedSystemsStreet Address:City:State:Zip:Submittal Date: Tue Feb 14 12:15:45 EST 2017

    Committee Statement

    Resolution: FR-2-NFPA 25-2017Statement: NOTE: This public input originates from Tentative Interim Amendment No. 17-1 (Log 1221) issued by

    the Standards Council on August 4, 2016 and per the NFPA Regs., needs to be reconsidered by theTechnical Committee for the next edition of the Document.

    Substantiation. The committee statement for SR-16 stated: The accuracy for the measuring devicesused in the 5 year waterflow test should be comparable to that for a fire pump flow test and not justequivalent to the minimum level accepted on a sprinkler system gauge. Unfortunately, the changewas made to gauges required by section 6.3.1.6.2 that apply only to the main drain test. 6.3.1.6 A

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  • main drain test shall be performed on all standpipe systems with automatic water supplies inaccordance with the requirements of Chapter 13. The current change now requires a standpipe maindrain test to use gauges with an accuracy of 1% whereas all other systems have a 3% allowance.Additionally, the 5-year water flow test still allows an accuracy of only 3%. Emergency Nature. TheNFPA Standard contains an error or an omission that was overlooked during a regular revisionprocess.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Tentative Interim Amendment

    NFPA® 25

    Standard for the Inspection, Testing and Maintenance of Water-Based Fire Protection Systems

    2017 Edition

    Reference: 6.3.1.1.2 (New) and 6.3.1.6.2 TIA 17-1 (SC 16-8-10 / TIA Log #1221) Note: Text of the TIA was issued and approved for incorporation into the document prior to printing. 1. Add a new paragraph 6.3.1.1.2 to read as follows:

    6.3.1.1.2 Pressure gauges maintained in accordance with 8.3.3.2.2 shall be provided for the test. 2. Revise paragraph 6.3.1.6.2 to read as follows:

    6.3.1.6.2 Pressure gauges maintained in accordance with Chapter 13 shall be provided for the test. Issue Date: August 4, 2016 Effective Date: August 24, 2016

    (Note: For further information on NFPA Codes and Standards, please see www.nfpa.org/docinfo) Copyright © 2016 All Rights Reserved

    NATIONAL FIRE PROTECTION ASSOCIATION

  • Public Input No. 56-NFPA 25-2017 [ Section No. 1.1 [Excluding any Sub-Sections] ]

    This document establishes the minimum requirements for the periodic inspection, testing, and maintenanceof properly installed water-based fire protection systems and the actions to undertake when changes inoccupancy, use, process, materials, hazard, or water supply that potentially impact the performance of thewater-based system are planned or identified.

    Statement of Problem and Substantiation for Public Input

    In 1.1.3 under system types, we state this Standard "applies to fire protection systems that have been properly installed with generally accepted practices." I believe it to be important and not redundant to note this in the scope.

    Submitter Information Verification

    Submitter Full Name: David BaronOrganization: Global Fire Protection CompanyStreet Address:City:State:Zip:Submittal Date: Fri Apr 28 10:39:58 EDT 2017

    Committee Statement

    Resolution: Per NFPA 25 it is not the responsibility of the inspector to determine if the system is properly installed,it is assumed that the system has been properly installed as noted in 1.1.3.

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  • Public Input No. 112-NFPA 25-2017 [ Section No. 1.1.1 [Excluding any Sub-Sections] ]

    This standard does not address all of the inspection, testing, and maintenance of the electrical componentsof the automatic fire detection equipment used to activate preaction and deluge systems that are addressedby NFPA 72 Sprinkler system components that are interconnected with a fire alarm system shall bepermitted to be inspected, tested, and maintained simultaneously in accordance with this standardand NFPA 72 ?? .

    Statement of Problem and Substantiation for Public Input

    The current language in 1.1.1 is only applicable to deluge and preaction systems. However, 1.1.1.2 and A.1.1.1.2 imply that any inspection and/or test of an electronic device that functions as a component of both the sprinkler system and the fire alarm system must comply with both NFPA 25 and NFPA 72. The proposed changes will address all devices that are common to both NFPA 25 and NFPA 72.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 113-NFPA 25-2017 [Section No. A.1.1.1.2]

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Fri Jun 16 11:27:43 EDT 2017

    Committee Statement

    Resolution: The existing wording already allows simultaneous testing.

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  • Public Input No. 11-NFPA 25-2017 [ New Section after 1.1.2.1 ]

    1.1.2.1.1 This standard shall not apply to the inspection, testing and maintenance of dry hydrants.

    A.1.1.2.1.1 Inspection, testing and maintenance of dry hydrants is under the scope of NFPA 1142, Standardon Water Supplies for Suburban and Rural Fire Firefighting.

    Statement of Problem and Substantiation for Public Input

    In PI no 35 for the 2017 edition of NFPA 25, the TC indicate that "dry hydrants are not typically considered part of a water based fire protection system." and "NFPA 1142 already addresses ITM of these hydrant types." This PI to the 2020 edition clarifies this scope issue by inserting new language in the core text and annex pointing the user to NFPA 1142 for ITM of dry hydrants. This scope issue should be clearly called out in the front of NFPA 25 as there is confusion by some AHJs as to if NFPA 25 applies to dry hydrants.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 12-NFPA 25-2017 [New Section after 3.3.12.1]

    Submitter Information Verification

    Submitter Full Name: Anthony ApfelbeckOrganization: Altamonte Springs Building/Fire Safety DivisionStreet Address:City:State:Zip:Submittal Date: Fri Mar 03 08:12:23 EST 2017

    Committee Statement

    Resolution: FR-4-NFPA 25-2017Statement: In PI no 35 for the 2017 edition of NFPA 25, the TC indicate that "dry hydrants are not typically

    considered part of a water based fire protection system." and "NFPA 1142 already addresses ITM ofthese hydrant types." This PI to the 2020 edition clarifies this scope issue by inserting new languagein the core text and annex pointing the user to NFPA 1142 for ITM of dry hydrants. This scope issueshould be clearly called out in the front of NFPA 25 as there is confusion by some AHJs as to if NFPA25 applies to dry hydrants.

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  • Public Input No. 13-NFPA 25-2017 [ New Section after 1.3.1 ]

    1.3.1.1

    Compliance with subsequent editions of this standard shall be considered evidence of compliance with theAHJ's adopted edition of this standard.

    Statement of Problem and Substantiation for Public Input

    Contractors performing ITM services are often confronted by numerous jurisdictions in their service area that may have adopted differing editions of NFPA 25. Keeping staff trained on three, four or even five differing editions of NFPA 25 and completing the associated documentation required by differing editions is an almost an impossible expectation. These complications can also create liability exposures for contractors whey they may not utilize the specific edition of NFPA 25 that a jurisdiction had adopted. If a contractor chooses to comply with the most current published edition of NFPA 25, even though it is not adopted by the AHJ, there is no reason that the most current edition of NFPA 25 should not be accepted as evidence of compliance to an adopted previous edition of NFPA 25. This change memorializes this concept in the standard to provide liability protection to the contractor and specific guidance to the AHJ that this practice is allowed. The language in the current 1.3.1 does not go far enough in that it does not mandate subsequent edition acceptance, it only allows an AHJ to accepts subsequent editions. Most AHJ's are not going to accept the current 1.3.1 language to allow this as it requires their discretion and risk. Therefore, the language in this PI is necessary in order to move this concept forward.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 14-NFPA 25-2017 [Section No. A.1.3.1]

    Submitter Information Verification

    Submitter Full Name: Anthony ApfelbeckOrganization: Altamonte Springs Building/Fire Safety DivisionStreet Address:City:State:Zip:Submittal Date: Fri Mar 03 10:45:56 EST 2017

    Committee Statement

    Resolution: This is in accordance with Standard Council agenda item number 17-8-57.

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  • Public Input No. 18-NFPA 25-2017 [ Section No. 2.1 ]

    2.1 General.

    The documents or portions thereof listed in this chapter are referenced within this standard and shall beconsidered part of the requirements of this document.

    (1) Documents referenced in this chaper or portion of such documents shall only be applicable to theextent called for within other chapters of this standard.

    (2) Where the requirements of a reference code or standard differ from the requirements of this standard,the requirements of this standard shall govern.

    A.2.1 (1) For example, Chapter 2 references the NFPA 13 2016 edition. Such reference does not meanthat all buildings must comply with the 2016 edition of NFPA 13. The 2016 edition of NFPA 13 is onlyapplicable when specifically referenced by a section in NFPA 25.

    Statement of Problem and Substantiation for Public Input

    For the 2017 edition of NFPA 25, the TC accepted "Retroactivity" language in 2.1.1 for the first draft and then removed the language at the second draft. The issue raised originally in PI 14 25-201 still remains....AHJs, and others, are sometimes confused by the appropriate applicability of the referenced standards listed in Chapter 2. As currently written, the language in section 2.1 could be construed to adopt all of the listed reference standards and make them applicable to an existing system during the course of an NFPA 25 inspection. This is clearly not the intent. The proposed language in this PI attempts to clarify this issue by dealing with the referenced standard in the same way that NFPA 101 and NFPA 1 deals with the issue. That is, the referenced standards are only applicable when NFPA 25 specifically points the user to refer to a section in a referenced standard. The presence of a reference standard being listed in Chapter 2 does not mean the entire reference standard is adopted as part of NFPA 25. This will provide clarity to the AHJ and also potentially remove a point of liability contention that could be made against a contractor conducting an NFPA 25 inspection.

    Submitter Information Verification

    Submitter Full Name: Anthony ApfelbeckOrganization: Altamonte Springs Building/Fire Safety DivisionStreet Address:City:State:Zip:Submittal Date: Fri Mar 03 14:07:07 EST 2017

    Committee Statement

    Resolution: The proposed language addresses future editions and this has been addressed by Standard Councilagenda item 17-8-57.

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  • Public Input No. 159-NFPA 25-2017 [ New Section after 3.3.2 ]

    TITLE OF NEW CONTENT3.3.1 Automated Inspection and Testing. The performance of inspections and tests at a distant locationfrom the system or component being inspected or tested through the use of electronic devices or equipmentinstalled for the purpose.

    Statement of Problem and Substantiation for Public Input

    This term is used in the document, but not defined. This definition has been included in the most recent revision cycles of NFPA 13, NFPA 20, and NFPA 14.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 117-NFPA 25-2017 [New Section after 4.6.6.6] Section using the term.

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Mon Jun 26 22:43:52 EDT 2017

    Committee Statement

    Resolution: FR-5-NFPA 25-2017Statement: This term is used in the document, but not defined. This definition has been included in the most

    recent revision cycles of NFPA 13, NFPA 20, and NFPA 14.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 110-NFPA 25-2017 [ New Section after 3.3.10 ]

    TITLE OF NEW CONTENTDwelling Unit. One or more rooms, arranged for the use of one or more individuals living together, as in asingle housekeeping unit that normally have cooking, living, sanitary, and sleeping facilities. [13R,2016]

    Statement of Problem and Substantiation for Public Input

    The definition for Dwelling Unit from NFPA 13R is required in NFPA 25 to clarify when sprinklers are required to be inspected within residential units.

    Submitter Information Verification

    Submitter Full Name: Sandra StanekOrganization: Unifour Fire and SafetyStreet Address:City:State:Zip:Submittal Date: Tue Jun 13 14:32:12 EDT 2017

    Committee Statement

    Resolution: The term "Dwelling Unit" is not used in the standard.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

    10 of 308 1/24/2018, 9:15 AM

  • Public Input No. 29-NFPA 25-2017 [ New Section after 3.3.11 ]

    3.3.11 ExerciseTo apply physical exertion on a device or on equipment, which is limited to the extent of ascertaining itsoperational status and functionality.

    Statement of Problem and Substantiation for Public Input

    During the 2017 revision cycle, a definition for "exercise" was proposed but rejected due to the notion that a dictionary can easily be utilized to determine the meaning of exercise (as it relates to equipment) and due to the fact that "exercise" is also used with relation to applying judgment to a situation, thus creating a conflict. This new definition is being proposed again so that the committee can determine if the language is appropriate as proposed or needs to be edited and improved on. Either way, the definition is necessary. While Section 3.1 does state that where terms are not defined in NFPA 25, their ordinarily accepted meanings can be determined from the 11th edition of Merriam-Webster's Dictionary, the committee needs to be made aware that the definition of exercise, as it is used and applied in the fire sprinkler industry, does not appear there either. Therefore NFPA 25 does need to include the definition of "exercise" in Chapter 3.

    Additionally, to address the objection of other usages of "exercise" in the standard, PIs have been submitted and related to this PI to change those instances of the word "exercise" (with regard to judgment) to a synonymous term that will not conflict with the word "exercise" as it is used with reference to equipment.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 30-NFPA 25-2017 [Section No.A.5.2.2.1]

    Changing instance of "exercise" where applied tojudgment

    Public Input No. 31-NFPA 25-2017 [Section No.A.13.5.2.2]

    Changing instance of "exercise" where applied tojudgment

    Public Input No. 30-NFPA 25-2017 [Section No.A.5.2.2.1]Public Input No. 31-NFPA 25-2017 [Section No.A.13.5.2.2]

    Submitter Information Verification

    Submitter Full Name: Joe ScibettaOrganization: BuildingReportsStreet Address:City:State:Zip:Submittal Date: Mon Apr 17 12:23:52 EDT 2017

    Committee Statement

    Resolution: This definition is not resolving any known problems in the industry. It does not adequately cover thepurpose of exercise to prevent degradation from long term static conditions. It is possible to exercisea component and not ascertain a valves operation and functionality.

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  • Public Input No. 12-NFPA 25-2017 [ New Section after 3.3.12.1 ]

    3.3.12.2 Dry Hydrant.An arrangement of pipe permanently connected to a water source other than a piped, pressurized watersupply system that produves a ready means of water supply for fire fighting purposes and that utilizes thedrafting (suction) capability of a fire department pump. [NFPA 1142, 20XX]

    A.3.3.12.2 The inspection, testing and maintence for dry hydrants is under the scope of NFPA 1142, WaterSupplies for Suburban and Rural Fire Fighting.

    Statement of Problem and Substantiation for Public Input

    See PI 11. This PI extracts the definition of "dry hydrant" from NFPA 1142 to provide clarity to the user as to the proper application of the scope language of NFPA 25 vs NFPA 1142 on dry hydrants. An annex pointer is also provided to this definition as an additional pointer to NFPA 1142 for the ITM of dry hydrants.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 11-NFPA 25-2017 [New Section after1.1.2.1]

    PI 12 is a definition added in relation to PI11

    Submitter Information Verification

    Submitter Full Name: Anthony ApfelbeckOrganization: Altamonte Springs Building/Fire Safety DivisionStreet Address:City:State:Zip:Submittal Date: Fri Mar 03 08:24:03 EST 2017

    Committee Statement

    Resolution: FR-42-NFPA 25-2017Statement: See PI 11. This PI extracts the definition of "dry hydrant" from NFPA 1142 to provide clarity to the user

    as to the proper application of the scope language of NFPA 25 vs NFPA 1142 on dry hydrants. Anannex pointer is also provided to this definition as an additional pointer to NFPA 1142 for the ITM ofdry hydrants.

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  • Public Input No. 160-NFPA 25-2017 [ Section No. 3.3.34 ]

    3.3.34 .1 Qualified . Person

    A competent and capable person who has met the requirements and training for a given field acceptableto the AHJ. [ 96, 2014] person who, by possession of a recognized degree, certificate, professionalstanding, or skill, and who, by knowledge, training, and experience, has demonstrated the ability toperform the work.

    A.3.3.34.1 Qualified personnel should be qualified in inspection, testing and maintenance of water-basedsystem by a nationally recognized organization.

    Statement of Problem and Substantiation for Public Input

    The current definition of "qualified" does not provide enough intent for someone performing work on these life safety systems. The proposed definition is intended to recognized a degree, certificate, professional standing, or skill from someone who, by knowledge, training, and experience, has demonstratedthe ability to perform this work.

    Submitter Information Verification

    Submitter FullName: Kenneth Schneider

    Organization: UA ITF

    Affilliation: United Association of Journeymen & Apprentices of the Plumbing &Pipe Fitting IndustryStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 05:24:45 EDT 2017

    Committee Statement

    Resolution: The determination of qualification is the purview of the AHJ.

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  • Public Input No. 75-NFPA 25-2017 [ Section No. 3.3.34 ]

    3.3.34 Qualified.

    A competent and capable person who has met the requirements and training for a given field person ableto complete the intent of a given task due to training or certification at a level acceptable to the AHJ. [ 96,2014]

    Statement of Problem and Substantiation for Public Input

    The current definition is not clear enough. It uses "competent and capable" as qualifiers but these are inherently part of qualified- i.e. someone that is not competent or capable could not be qualified. Also, the definition opens debate indicating someone qualified in fire protection (i.e. a "field") is so, for all activities. This, used alone, would indicate a person qualified to test a fire pump is qualified to interpret results, etc. The revised definition is simpler and clearer "qualified per NFPA 25 goes down to the activity level not just "a field."

    Submitter Information Verification

    Submitter Full Name: Bruce ClarkeOrganization: American International Group,Street Address:City:State:Zip:Submittal Date: Tue May 23 18:42:37 EDT 2017

    Committee Statement

    Resolution: The proposed language does not improve the current definition. The use of the word "intent" in thebody of the text is ambiguous.

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  • Public Input No. 76-NFPA 25-2017 [ Section No. 3.3.40.1 ]

    3.3.40.1 Installation Orientation.

    The following sprinklers are defined according to orientation.

    3.3.40.1.1 Concealed Pendent Sprinkler.

    A

    recessed sprinkler with cover plate. [ 13, 2016]

    sprinkler designed to be installed such that the water stream is directed downward against the deflectorthat creates a unilateral parabolic discharge pattern.

    3.3.40.1.2

    Flush

    Horizontal Sidewall Sprinkler.

    A sprinkler in which all or part of the body, including the shank thread, is mounted above the lower plane ofthe ceiling. [ 13, 2016] designed to be installed horizontally such that the water stream discharges primarilyoutward from the nearby wall in a parabolic sphere pattern with a small portion directed backward at thewall behind the sprinkler.

    3.3.40.1.3 Pendent Upright Sprinkler.

    A sprinkler designed to be installed in such a way that the water stream is directed downward upwardagainst the deflector . [ 13, 2016] to creates a unilateral parabolic discharge pattern.

    3.3.40.1.4

    Recessed Sprinkler.Upright/pendant Sidewall Sprinkler

    A sprinkler

    in which all or part of the body, other than the shank thread, is mounted within a recessed housing. [ 13,2016]

    3.3.40.1.5 Sidewall Sprinkler.

    A sprinkler having special deflectors that are designed to discharge most of the water away

    designed to be installed in the upright or pendant position per manufactures instructions against a wall suchthat the water stream discharges primarily outward from the nearby wall horizontally in a

    pattern resembling one-quarter of a sphere,

    parabolic sphere pattern with a small portion

    of the discharge

    directed backward at the wall behind the sprinkler.

    [ 13, 2016]

    3.3.40.1.6 Upright Sprinkler.

    A sprinkler designed to be installed in such a way that the water spray is directed upwards against thedeflector. [ 13, 2016]

    Statement of Problem and Substantiation for Public Input

    The same input will be submitted to NFPA 13 as, by definition several sub-parts of 3.3..40.1 are not specific to orientation. Definitions were revised for consistency and to clear up confusion on sprinklers that are hybrids/ combinations of the three main orientations. Understanding of these definitions is critical to inspections and the

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  • current definition estrangement can be confusing- esp. given flush and concealed sprinklers should not be associated as an orientation.

    Submitter Information Verification

    Submitter Full Name: Bruce ClarkeOrganization: American International Group,Street Address:City:State:Zip:Submittal Date: Tue May 23 19:05:19 EDT 2017

    Committee Statement

    Resolution: These definitions are the purview of NFPA 13 and should be addressed with the NFPA 13 TC firstand then extracted into NFPA 25.

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  • Public Input No. 78-NFPA 25-2017 [ Section No. 3.3.40.1 ]

    3.3.40.1 Installation Orientation.

    The following sprinklers are defined according to orientation.

    3.3.40.1.1 Concealed Sprinkler.

    A pendant or sidewall recessed sprinkler designed to be installed with a cover plate

    . [ 13, 2016]

    listed as part of the sprinkler assemly to operate and expose the sprinkler deflector before discharge isrequired.

    3.

    3.

    40.

    1.

    2 Flush Sprinkler.

    A sprinkler in which pendant or sidewall sprinkler designed to be installed such that all or part of the body, including the shank thread, is mounted above the lower plane of the ceiling. [ 13, 2016]

    3.3.40.

    1.

    3

    Pendent

    Recessed Sprinkler.

    A pendant sprinkler designed to be installed in such a way that the water stream is directed downwardagainst the deflector. [ 13, 2016]

    3.3.40.1.4 Recessed Sprinkler.

    A sprinkler in which all or part of the body, other than the shank thread, is mounted within a recessedhousing. [ 13, 2016]

    3.3.40.1.5 Sidewall Sprinkler.

    A sprinkler having special deflectors that are designed to discharge most of the water away from thenearby wall in a pattern resembling one-quarter of a sphere, with a small portion of the discharge directedat the wall behind the sprinkler. [ 13, 2016]

    3.3.40.1.6 Upright Sprinkler.

    A sprinkler designed to be installed in such a way that the water spray is directed upwards against thedeflector. [ 13, 2016]

    Statement of Problem and Substantiation for Public Input

    Revised to move these sprinklers types out from orientation types and better define definitions for understanding in NFPA 25 inspections.

    Submitter Information Verification

    Submitter Full Name: Bruce Clarke

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  • Organization: American International Group,Street Address:City:State:Zip:Submittal Date: Tue May 23 19:32:26 EDT 2017

    Committee Statement

    Resolution: The terms are used in the standard the definitions should remain and there was no action to relocatethese to other definition sections.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 118-NFPA 25-2017 [ New Section after 3.3.40.5 ]

    Electrically Operated SprinklersSprinklers that operate when temperatures at a nearby detector that is electrically connected to the sprinklerreach predetermined parameters as a result of a fire.

    Statement of Problem and Substantiation for Public Input

    New technology has been developed for a sprinkler that is electronically operated. These sprinklers are UL listed and are on the market. There currently isn’t guidance in NFPA 25 for inspecting, testing, and maintenance of these sprinklers. The proposed language addresses very basic requirements for this new technology based on the manufacturer’s Data Sheet.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 119-NFPA 25-2017 [Section No. 5.2.1.1 [Excluding any Sub-Sections]]Public Input No. 120-NFPA 25-2017 [New Section after 5.3.1]Public Input No. 121-NFPA 25-2017 [New Section after 5.4.1.7]

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Tue Jun 20 20:27:55 EDT 2017

    Committee Statement

    Resolution: The term is not currently referenced in the standard.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 190-NFPA 25-2017 [ Section No. 3.6.2.4 ]

    3.6.2.4 * Peak Load.

    As pertains to acceptance testing in this standard is the maximum power required to drive the pump at anyflow rate from 100 percent up to 150 percent of rated capacity (flow). [20, 2016]

    Statement of Problem and Substantiation for Public Input

    Flow rates less than 100% for an acceptance test are used for curves only relating to flow not for power or Peak load. anything for Peak load would have to be at least 100% of capacity or the entire test fails.

    Submitter Information Verification

    Submitter Full Name: David BaronOrganization: Global Fire Protection CompanyStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 16:01:01 EDT 2017

    Committee Statement

    Resolution: FR-6-NFPA 25-2017Statement: As used in NFPA 25 the definition applies to annual testing not acceptance testing.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 20-NFPA 25-2017 [ Section No. 3.7.1.1 ]

    3.7.1.1 Daily Frequency.

    Occurring every day with a minimum of 18 hours and a maximum of 30 hours .

    Statement of Problem and Substantiation for Public Input

    The existing definition has no time constraints so one inspection could be completed at 23:55 and the other at 00:05 and would be compliant. Sections 3.7.1.4 through 3.7.1.8 provide a define time period for each of the note frequencies. Section 3.7.1.1 should also provide an established frequency so that the timing of the physical inspection will meet the intent of provided an inspection approximately every 24 hours.

    Submitter Information Verification

    Submitter Full Name: Tom ChristmanOrganization: Self EmployeedAffilliation: NoneStreet Address:City:State:Zip:Submittal Date: Wed Mar 22 13:10:15 EDT 2017

    Committee Statement

    Resolution: Daily is such a short time frame that it does not matter what time on each day the test getsperformed.

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  • Public Input No. 21-NFPA 25-2017 [ Section No. 3.7.1.2 ]

    3.7.1.2 Weekly Frequency.

    Occurring once per calendar week with a minimum of 6 days and a maximum of 8 days .

    Statement of Problem and Substantiation for Public Input

    The existing definition has no time constraints so one inspection could be completed at Saturday (the last day of the week) and the next one on Sunday (the first day of the next week) and the inspection would be compliant for being completed each week . Sections 3.7.1.4 through 3.7.1.8 provide a define time period for each of the note frequencies. Section 3.7.1.2 should also provide an established frequency so that the timing of the physical inspection will meet the intent of providing an inspection approximately every 7 days.

    Submitter Information Verification

    Submitter Full Name: Tom ChristmanOrganization: Self EmployeedAffilliation: NoneStreet Address:City:State:Zip:Submittal Date: Wed Mar 22 13:17:28 EDT 2017

    Committee Statement

    Resolution: Weekly is such a short time frame that it does not matter what time each week the test getsperformed.

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  • Public Input No. 22-NFPA 25-2017 [ Section No. 3.7.1.3 ]

    3.7.1.3 Monthly Frequency.

    Occurring once per calendar month with a minimum of three weeks and a maximum of 5 weeks .

    Statement of Problem and Substantiation for Public Input

    The existing definition has no time constraints so one inspection could be completed at January 31st and the next inspection on February 1st and the inspection would be compliant. Sections 3.7.1.4 through 3.7.1.8 provide a defined time period for each of the noted frequencies. Section 3.7.1.3 should also provide an established frequency so that the timing of the physical inspection will meet the intent of providing an inspection approximately every 4 weeks.

    Submitter Information Verification

    Submitter Full Name: Tom ChristmanOrganization: Self EmployeedAffilliation: NoneStreet Address:City:State:Zip:Submittal Date: Wed Mar 22 13:23:38 EDT 2017

    Committee Statement

    Resolution: Monthly is such a short time frame that it does not matter what time each month the test getsperformed.

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  • Public Input No. 64-NFPA 25-2017 [ Section No. 4.1.1.2 ]

    4.1.1.2

    Inspection, testing, and maintenance shall be performed by qualified personnel.

    4.1.1.2.1*

    The owner shall coordinate with the entity conducting the inspection, testing, and maintenance activities tominimize any water damage caused by the discharge of water.

    4.1.1.2.2

    Service personnel shall be qualified and experienced in the inspection, testing, and maintenance of fireprotection systems.

    4.1.1.2.3

    Qualified personnel shall include, but not be limited to, one or more of the following:

    (1) Personnel who are factory trained and certified for the specific type and brand of system beinginspected

    (2) Personnel who are certified by a nationally recognized fire protection certification organization

    (3) Personnel who are registered , licensed, or certified by a state or local authority

    (4) Personnel who are employed and qualified by an organization listed by a nationally recognizedtesting laboratory for the servicing of fire protection systems

    4.1.1.2.4

    Additional evidence of qualification or certification shall be permitted to be required by the AHJ.

    Statement of Problem and Substantiation for Public Input

    It would be beneficial for the end user to have guidance on acceptable qualifications for inspection, testing, and maintenance of water-based fire protection systems.

    Submitter Information Verification

    Submitter Full Name: Jason ButlerOrganization: Bernie Till and Associates LLCStreet Address:City:State:Zip:Submittal Date: Thu May 04 15:24:41 EDT 2017

    Committee Statement

    Resolution: It is the purview of the AHJ to determine and accept those that are qualified.

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  • Public Input No. 53-NFPA 25-2017 [ Section No. 4.1.1.2.1 ]

    4.1.1.2.1*

    The owner shall coordinate with the entity Where an entity other than the property owner or designatedrepresentative is conducting the inspection, testing and maintenance activities , both the property owner(or their designated representative) and maintenance activities the inspection, testing and maintenanceentity shall coordinate their efforts to minimize any water damage caused by the discharge of water.

    Statement of Problem and Substantiation for Public Input

    During the last revision cycle, this section was debated with a certified amending motion to reject it as the language appeared to place the burden of this responsibility solely on the property owner. This PI seeks to address those concerns by tweaking the language slightly. While it is true that in most cases the property owner will be the best equipped to care for this responsibility, where another entity is being utilized to carry out ITM activities, this language clarifies that the responsibility for minimizing water damage shall be a joint, coordinated effort

    Submitter Information Verification

    Submitter Full Name: Joe ScibettaOrganization: BuildingReportsStreet Address:City:State:Zip:Submittal Date: Thu Apr 20 16:38:40 EDT 2017

    Committee Statement

    Resolution: The change is not needed. This work should be coordinated between the owner and those performingthe work.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 122-NFPA 25-2017 [ Section No. 4.1.1.3 ]

    4.1.1.3 *

    Where the property owner or designated representative is not the occupant, the property owner ordesignated representative shall be permitted to delegate the authority for inspecting, testing, maintenance,and the managing of impairments of the fire protection system to a designated qualified representative.

    Statement of Problem and Substantiation for Public Input

    Some facilities that adopt NFPA 25, may not be using qualified personnel to conduct the inspecting, testing, maintenance, and managing the impairments. Section 3.3.24 has a definition for "qualified", and this should be leveraged because some contractors have sent incompetent technicians to test our systems.

    Submitter Information Verification

    Submitter Full Name: Bernard LeongOrganization: Chevron Energy Technology CompStreet Address:City:State:Zip:Submittal Date: Thu Jun 22 16:30:57 EDT 2017

    Committee Statement

    Resolution: This section does not require a reference to qualified.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 133-NFPA 25-2017 [ New Section after 4.1.2.1 ]

    TITLE OF NEW CONTENT4.1.2.1.1* The requirments of 4.1.2 and 4.2.1.1 shall not apply where water-filled piping is located inunconditioned building spaces or areas outside the building envelope and are not subject to freezing.

    Statement of Problem and Substantiation for Public Input

    The current language does not account for water-filled piping that was approved for installation in areas where temperatures fall below 40 degrees F. An allowance must be made for these situations.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 134-NFPA 25-2017 [New Section after A.4.1.2]

    Submitter Information Verification

    Submitter Full Name: Russell LeavittOrganization: Telgian CorporationAffilliation: The Home DepotStreet Address:City:State:Zip:Submittal Date: Mon Jun 26 07:23:31 EDT 2017

    Committee Statement

    Resolution: FR-7-NFPA 25-2017Statement: The current language does not account for water-filled piping that was approved for installation in

    areas where temperatures fall below 40 degrees F. An allowance must be made for these situations.

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  • Public Input No. 107-NFPA 25-2017 [ Section No. 4.1.3 ]

    4.1.3* Accessibility.

    The property owner or designated representative shall provide ready accessibility to components of water-based fire protection systems including residential dwelling units that require inspection, testing, andmaintenance.

    Statement of Problem and Substantiation for Public Input

    There have been little or no AHJ enforcement to perform 100% walk through sprinkler annual inspection of individual residential units. End users, property owners or their representatives are now posing questions about the validity of the requirement.

    Submitter Information Verification

    Submitter Full Name: Sandra StanekOrganization: Unifour Fire and SafetyStreet Address:City:State:Zip:Submittal Date: Tue Jun 13 10:00:54 EDT 2017

    Committee Statement

    Resolution: The standard clearly states that owners or designated representatives shall provide readyaccessibility. Dwelling units are just one area that is often difficult to access. Accessibility should becoordinated with owners and dwelling unit owners. Enforcement is established per local jurisdictionrequirements.

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  • Public Input No. 99-NFPA 25-2017 [ Section No. 4.1.4 [Excluding any Sub-Sections] ]

    The property owner or designated representative shall notify the authority having jurisdiction, the firedepartment, if required, and the alarm-receiving facility before testing or shutting down a system or itssupply. A confirmation of the notification shall be documented.

    Statement of Problem and Substantiation for Public Input

    This will provide proof that the authority having jurisdiction or fire department received the request and approved a system shutdown.

    Submitter Information Verification

    Submitter Full Name: Christopher ShrodekOrganization: Cleveland ClinicStreet Address:City:State:Zip:Submittal Date: Thu Jun 08 07:52:29 EDT 2017

    Committee Statement

    Resolution: The proposed requirement is vague and difficult to enforce. From an impairment perspective it isalready addressed. A need to obtain a confirmation that the notification is received is unnecessary.

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  • Public Input No. 169-NFPA 25-2017 [ New Section after 4.1.5 ]

    4.1.5.1* Noncompliance.If, during inspection or testing in accordance with this standard, conditions are identified that are in conflictwith the provisions of this standard, those conditions shall be deemed deficiencies or impairments.

    Statement of Problem and Substantiation for Public Input

    NFPA 25 defines the terms “deficiency” and “impairment”. It also recommends classification of conditions found as such, but nowhere does it state that conditions found that are not consistent with the standard are to be considered deficiencies or impairments.

    Add also annex language: A.4.1.5.1 See A.4.1.5

    Submitter Information Verification

    Submitter Full Name: Robert UpsonOrganization: National Fire Sprinkler AssociationAffilliation: NFSA Engineering and Standards CommitteeStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 10:27:50 EDT 2017

    Committee Statement

    Resolution: Where an inspection or test has been missed this does not necessarily constitute a deficiency orimpairment.

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  • Public Input No. 167-NFPA 25-2017 [ New Section after 4.1.5.1 ]

    4.1.5.1.1The property owner or designated representative shall correct, remedy, repair or replace components andequipment under recall or voluntary replacement programs.

    Statement of Problem and Substantiation for Public Input

    NFPA 25 currently contains no reference to products that are part of a recall or replacement program. This proposal clarifies that these products must be dealt with.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 168-NFPA 25-2017 [New Section after A.4.1.5.1]

    Submitter Information Verification

    Submitter Full Name: Robert UpsonOrganization: National Fire Sprinkler AssociationAffilliation: NFSA Engineering and Standards CommitteeStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 10:13:50 EDT 2017

    Committee Statement

    Resolution: FR-112-NFPA 25-2017Statement: This provides an awareness of importance of handling recalled products or components by owner

    maintenance personnel , designated representative or contractors as well as a process foraddressing such deficiencies when discovered.

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  • Public Input No. 79-NFPA 25-2017 [ Section No. 4.1.5.2 ]

    4.1.5.2

    Corrections and repairs shall be performed by qualified maintenance personnel or a qualifiedcontractor personnel acceptable to the AHJ .

    Statement of Problem and Substantiation for Public Input

    Revised wording simplifies interpretation and correlates with 4.1.1.2. This also allows more alignment with various jurisdictional requirements- some corrections can be done by maintenance and some require contractors but, they must be qualified by definition.

    Submitter Information Verification

    Submitter Full Name: Bruce ClarkeOrganization: American International Group,Street Address:City:State:Zip:Submittal Date: Tue May 23 19:48:37 EDT 2017

    Committee Statement

    Resolution: The committee wishes to retain qualified maintenance personnel and qualified contractor.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 205-NFPA 25-2017 [ Section No. 4.1.9 ]

    4.1.9 General Information Sign.

    4.1.9.1

    A

    The general information sign(s) required by NFPA 13 shall be provided with a permanently markedweatherproof metal or rigid plastic

    information

    sign

    shall be placed at the system control riser supplying an antifreeze loop, dry system, preaction system, orauxiliary system control valve

    , secured with corrosion-resistant wire, chain, or other acceptable means, regardless of date of systeminstallation .

    4.1.9.2

    Each sign shall be secured with a corrosion-resistant wire, chain, or other approved means and shallindicate at least the following information:

    (1) Location of the area served by the system

    (2) Location of auxiliary drains and low-point drains for dry pipe and preaction systems

    (3) The presence and location of antifreeze or other auxiliary systems

    (4) The presence and location(s) of heat tape

    Such signs shall be placed at each system control riser, antifreeze loop, and auxiliary system control valve.

    Statement of Problem and Substantiation for Public Input

    Adding the word General to match NFPA 13 and referencing the installation standard will clarify the signs name, intended use, placement and required information. This will also help combine 5.2.7 and 5.2.8 and 5.2.8 (annex) material referenced in additional public input 206. Additionally, to keep congruent with the Hydraulic Design Information Sign in NFPA 25, A.4.1.9.2 brings in the Sample General Information Sign from NFPA 13. The sample signs in Annex demonstrate the required components of the sign from NFPA 13 without eating precious space within the body of NFPA 25.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 206-NFPA 25-2017 [Sections 5.2.7, 5.2.8]Public Input No. 207-NFPA 25-2017 [Section No. A.5.2.8]Public Input No. 208-NFPA 25-2017 [New Section after A.4.1.7]

    Submitter Information Verification

    Submitter Full Name: Wilton MarburgerOrganization: Myers Risk Services, Inc.Street Address:City:State:

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  • Zip:Submittal Date: Wed Jun 28 14:25:45 EDT 2017

    Committee Statement

    Resolution: FR-29-NFPA 25-2017Statement: This clarifies that if a general information sign is present the sign requirements per NFPA 25 are

    achieved and an extra information sign is not required.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 161-NFPA 25-2017 [ Sections 4.3.1, 4.3.2, 4.3.3 ]

    Sections 4.3.1, 4.3.2, 4.3.3

    4.3.1 *

    Records shall be made for all inspections, tests, and maintenance of the system and its components andshall be made available to the authority having jurisdiction upon request .

    4.3.1.1

    Records shall be maintained by the property owner .

    4.3.1.1 .2 *

    Records shall be permitted to be stored and accessed electronically.

    4.3. 1.1.3

    Records shall be made available to the authority having jurisdiction upon request.

    4.3. 2

    Records shall indicate the following:

    (1) The procedure/activity performed (e.g., inspection, test, or maintenance)

    (2) The organization that performed the activity

    (3) The required frequency of the activity

    (4) The results and date of the activity

    (5) The name and contact information of the qualified contractor or owner, including lead person for activity

    4.3.3 *

    Records shall be maintained by the property owner.

    Statement of Problem and Substantiation for Public Input

    Organized for ease of use and in accordance with manual of style.

    Submitter Information Verification

    Submitter Full Name: Russell LeavittOrganization: Telgian CorporationAffilliation: The Home DepotStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 07:28:04 EDT 2017

    Committee Statement

    Resolution: FR-8-NFPA 25-2017Statement: Organized for ease of use and in accordance with manual of style.

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  • Public Input No. 149-NFPA 25-2017 [ New Section after 4.6.6 ]

    4.7* Frequencies Based on Building Type and Occupancy

    4.7.1* Different frequencies for performing inspections, testing, and maintenance shall be allowed asdescribed in individual chapters 5 through 13.

    4.7.2* The use of section 4.7 is at the discretion of the building owner or the designated representative.4.7.3* Before different frequencies can be used, the system shall be evaluated as described in section4.1.7 to determine if changes have occurred in the occupancy, hazard, water supply, storage commodity,storage arrangement, building modification, or other condition that affects the installation criteria of thesystem.

    4.7.3.1 An evaluation shall be performed at least every five years thereafter to continue to use frequenciesbased on building type and occupancy.

    Statement of Problem and Substantiation for Public Input

    A NFPA 25 task group was appointed to consider adding new allowances for different frequencies based on building type and occupancy. The task group has determined that this alternate approach for inspecting, testing, and maintaining water-based fire protection systems has some merit but should be based on data to prove any different frequencies are warranted. The task group also agrees that this alternate approach should be simple to understand and apply. A series of PIs were submitted on behalf of the task group to introduce this concept to NFPA 25 and to begin gathering data to support any related changes to the standard.Submitted on behalf of the Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies task group.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 150-NFPA 25-2017 [New Section after A.4.6.6.4.2]Public Input No. 151-NFPA 25-2017 [New Section after 5.1.1.2]Public Input No. 152-NFPA 25-2017 [New Section after 6.1.1.2]Public Input No. 153-NFPA 25-2017 [New Section after 7.1.1.2]Public Input No. 154-NFPA 25-2017 [New Section after 8.1.1.2]Public Input No. 155-NFPA 25-2017 [New Section after 9.1.1.2]Public Input No. 156-NFPA 25-2017 [New Section after 10.1.1.2]Public Input No. 157-NFPA 25-2017 [New Section after 11.1.1.2]Public Input No. 158-NFPA 25-2017 [New Section after 13.1.1.2]

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Mon Jun 26 19:46:44 EDT 2017

    Committee Statement

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  • Resolution: CI-9-NFPA 25-2017Statement: A NFPA 25 task group was appointed to consider adding new allowances for different frequencies

    based on building type and occupancy. The task group has determined that this alternate approachfor inspecting, testing, and maintaining water-based fire protection systems has some merit butshould be based on data to prove any different frequencies are warranted. The task group alsoagrees that this alternate approach should be simple to understand and apply. A series of PIs weresubmitted on behalf of the task group to introduce this concept to NFPA 25 and to begin gatheringdata to support any related changes to the standard.

    Submitted on behalf of the Building Type and Occupancy Based Inspection, Testing, andMaintenance Frequencies task group.

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  • Public Input No. 123-NFPA 25-2017 [ Section No. 4.6.6.4.1 ]

    4.6.6.4.1

    Automated testing equipment that flows water flow for a test shall be permitted to circulate water or flowwater overboard except as required in 4.6.6.4.2.

    Statement of Problem and Substantiation for Public Input

    In some systems, especially on ships or offshore or near jetties, it is common to flow the fire water (sea water) overboard. This should also include where fire water is taken from lakes, where it is flowed back to the source of supply, circulating the water is ideal for fire water storage tanks.

    Submitter Information Verification

    Submitter Full Name: Bernard LeongOrganization: Chevron Energy Technology CompStreet Address:City:State:Zip:Submittal Date: Thu Jun 22 16:54:50 EDT 2017

    Committee Statement

    Resolution: This section does not limit discharging of water it only states that circulation is an option.

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  • Public Input No. 170-NFPA 25-2017 [ Section No. 4.6.6.4.1 ]

    4.6.6.4.1

    Automated testing equipment that flows water flow for a test shall verifies flow alarm operation shall bepermitted to circulate water except as required in 4.6.6.4.2.

    Statement of Problem and Substantiation for Public Input

    Section 1.3.1* states that It is not the intent of this standard to limit or restrict the use of other inspection, testing, or maintenance programs that provide an equivalent level of system integrity and performance to that detailed in this standard. If testing verifies that the flow alarm is operating it should be allowed according to the purpose of this standard.Section 1.3.2 provides the authority having jurisdiction the ability to approve alternative testing programs. The AHJ can still require an actual waterflow test at any time, this just provides an alternative if approved by the AHJ. The purpose of the waterflow test is to ensure the ability of the waterflow switch to initiate an alarm, not to prove availability of the water supply. If the product is Listed for the purpose for which it is intended to be used, it should be allowed to be used for that purpose.

    Submitter Information Verification

    Submitter Full Name: Robert UpsonOrganization: National Fire Sprinkler AssociationAffilliation: NFSA Engineering and Standards CommitteeStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 10:55:27 EDT 2017

    Committee Statement

    Resolution: This section is not limited to flow alarm devices.

    National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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  • Public Input No. 117-NFPA 25-2017 [ New Section after 4.6.6.6 ]

    TITLE OF NEW CONTENT4.6.6.6.1 Devices and equipment utilized to perform automated inspection and testing procedures that arenot subjected to system pressure or are not integral to the operation of the system during a fire event shallnot be required to be listed.

    Statement of Problem and Substantiation for Public Input

    Many devices and equipment that can be used for automated inspection and testing are not listed for the purpose and don’t need to be. Devices such as cameras, thermocouples, tachometers, and vibration sensors that could be used for NFPA 25 inspections and tests shouldn’t require any special listing for fire protection systems. Other devices such as pressure transducers, solenoid valves, and flow meters are not integral to the operation of the system and shouldn’t require any special listing for fire protection systems, just like gauges and drain valves. This exception correlates with language proposed for NFPA 13, 14, and 20.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 159-NFPA 25-2017 [New Section after 3.3.2]

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Fri Jun 16 11:54:42 EDT 2017

    Committee Statement

    Resolution: FR-19-NFPA 25-2017Statement: Many devices and equipment that can be used for automated inspection and testing are not listed for

    the purpose and don’t need to be. Devices such as cameras, thermocouples, tachometers, andvibration sensors that could be used for NFPA 25 inspections and tests shouldn’t require any speciallisting for fire protection systems. Other devices such as pressure transducers, solenoid valves, andflow meters are not integral to the operation of the system and shouldn’t require any special listing forfire protection systems, just like gauges and drain valves. This exception correlates with languageproposed for NFPA 13, 14, and 20. The annex note was added for clarity.

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  • Public Input No. 127-NFPA 25-2017 [ Section No. 4.6.6.8 ]

    4.6.6.8

    Failure of a component or system to pass an automated test shall result in an audible supervisory signal ortrouble signal .

    Statement of Problem and Substantiation for Public Input

    Having a test failure result in a supervisory condition means another point has to be monitored by the fire alarm/sprinkler monitoring panel. This adds additional cost to the building owner. If the result of a failed test is a trouble condition on the same point/zone of the device being tested, there is no additional cost to the building owner. The point/zone shall remain in a trouble condition until a successful test is completed.The failure of a manual test does not currently result in a supervisory condition, why should the failure of an automated test result in one..

    Submitter Information Verification

    Submitter Full Name: Michael HenkeOrganization: Potter Electric Signal CompanyStreet Address:City:State:Zip:Submittal Date: Fri Jun 23 15:36:11 EDT 2017

    Committee Statement

    Resolution: A supervisory signal is a higher priority signal.

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  • Public Input No. 57-NFPA 25-2017 [ Section No. 4.9.6 ]

    4.9.6* Electrical Safety.

    Legally required

    All appropriate manufacturer, OSHA, NFPA 70E, as well as any legally required safety precautionsshall be

    taken

    followed when inspecting, testing , or maintaining

    electric controllers for motor-driven fire pumps

    any fire pump controller or electrically energized equipment .

    Statement of Problem and Substantiation for Public Input

    This paragraph in chapter 4 should be more inclusive. Manufacturers may have specific instructions for specific equipment meant to protect the people working on that equipment that may not be "legally required" but important and necessary for personal safety while working on their equipment. This statement should not be limited to electric controllers for motor driven fire pumps in this chapter. Also, if this Standard is adopted or applied outside of the USA there may not be any "legally required" precautions.

    Submitter Information Verification

    Submitter Full Name: David BaronOrganization: Global Fire Protection CompanyStreet Address:City:State:Zip:Submittal Date: Fri Apr 28 10:47:20 EDT 2017

    Committee Statement

    Resolution: FR-20-NFPA 25-2017Statement: The proposed change to the body of the standard sets a minimum requirement to utilize the

    provisions of NFPA 70E as a

    baseline for protective measures required when working on electric controllers for motor-driven firepumps. The additional

    language added to the Annex provides reinforcing directive that every electric motor-driven fire pumpcontroller

    installation is different and that the calculation of incident energy, the resultant labeling and therequired PPE for such will

    be different for each. Equivalent was added to address areas around the globe where NFPA 70E isnot used.

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  • Public Input No. 151-NFPA 25-2017 [ New Section after 5.1.1.2 ]

    TITLE OF NEW CONTENT5.1.1.3 Table 5.1.1.3 shall be allowed to be used to determine different frequencies for the routineinspection, testing, and maintenance of sprinkler systems based on building type and occupancy.

    5.1.1.3.1 The requirements of 4.7 shall also apply.5.1.1.3.2 The use of Table 5.1.1.3 is at the discretion of the owner.

    Additional Proposed Changes

    File Name Description Approved

    Sample_Tables_for_Chapters_5_6_7_8_9_10_11_and_13.docx Sample table for chapter 5 is included

    Statement of Problem and Substantiation for Public Input

    A NFPA 25 task group was appointed to consider adding new allowances for different frequencies based on building type and occupancy. The task group has determined that this alternate approach for inspecting, testing, and maintaining water-based fire protection systems has some merit but should be based on data to prove any different frequencies are warranted. The task group also agrees that this alternate approach should be simple to understand and apply. A series of PIs were submitted on behalf of the task group to introduce this concept to NFPA 25 and to begin gathering data to support any related changes to the standard.Submitted on behalf of the Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies task group.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 149-NFPA 25-2017 [New Section after 4.6.6] Base requirement in chapter 4Public Input No. 150-NFPA 25-2017 [New Section after A.4.6.6.4.2] Annex text for base requirementPublic Input No. 152-NFPA 25-2017 [New Section after 6.1.1.2]Public Input No. 153-NFPA 25-2017 [New Section after 7.1.1.2]Public Input No. 154-NFPA 25-2017 [New Section after 8.1.1.2]Public Input No. 155-NFPA 25-2017 [New Section after 9.1.1.2]Public Input No. 156-NFPA 25-2017 [New Section after 10.1.1.2]Public Input No. 157-NFPA 25-2017 [New Section after 11.1.1.2]Public Input No. 158-NFPA 25-2017 [New Section after 13.1.1.2]

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Mon Jun 26 20:15:07 EDT 2017

    Committee Statement

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  • Resolution: CI-10-NFPA 25-2017Statement: A NFPA 25 task group was appointed to consider adding new allowances for different frequencies

    based on building type and occupancy. The task group has determined that this alternate approachfor inspecting, testing, and maintaining water-based fire protection systems has some merit butshould be based on data to prove any different frequencies are warranted. The task group alsoagrees that this alternate approach should be simple to understand and apply. A series of PIs weresubmitted on behalf of the task group to introduce this concept to NFPA 25 and to begin gatheringdata to support any related changes to the standard.

    Submitted on behalf of the Building Type and Occupancy Based Inspection, Testing, andMaintenance Frequencies task group.

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  • Sample tables to be expanded to describe different frequencies based on building type and occupancy.  Table 5.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Hangers/Braces/Supports  5.2.3  Annually  Every ??? years Pipe and Fittings  5.2.2  Annually  Every ??? years 

     Table 6.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Cabinets  6.2.1  Annually  Every ??? years Hose Connection  6.2.1  Annually  Every ??? years 

     Table 7.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Hose Houses  7.2.2.7  Quarterly  Every ??? months Monitor Nozzles  7.2.2.6  Semiannually  Every ??? months 

     Table 8.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Diesel Pump System  8.2.2(4)  Weekly  Every ??? weeks Electric Pump System  8.2.2(3)  Weekly  Every ??? weeks 

     Table 9.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Catwalks and ladders  9.2.5.1  Quarterly  Semiannually Support structure  7.2.5.1  Quarterly  Semiannually 

     Table 10.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Drainage  10.2.8  Quarterly  Semiannually 

     Table 11.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Discharge device location (spray nozzle) 

    11.2.5  Monthly  Bi‐monthly 

    Discharge device position (spray nozzle) 

    11.2.5  Monthly  Bi‐monthly 

     Table 13.1.1.3 Building Type and Occupancy Based Inspection, Testing, and Maintenance Frequencies 

    Item  Reference  Normal Frequency  BT&O Based Frequency Inspection       Control valves (sealed)  13.3.2.1  Weekly  Monthly Control valves (locked)  13.3.2.1.1  Monthly  Quarterly Control valves (elec superv)  13.3.2.1.2  Quarterly  Semiannually 

  • Public Input No. 23-NFPA 25-2017 [ Section No. 5.1.1.2 ]

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  • 5.1.1.2

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  • Table 5.1.1.2 shall be used to determine the minimum required frequencies for inspection, testing, andmaintenance.

    Table 5.1.1.2 Summary of Sprinkler System Inspection, Testing, and Maintenance

    Item Frequency Reference

    ? Inspection

    Control valves

    Chapter 13Fire department connections

    Chapter 13Gauges (wet and deluge systems) Quarterly Chapter 13Gauges (dry and preaction systems) Monthly/quarterly Chapter 13Hanger/braces/supports Annually 5.2.3Heat tracing Per manufacturer’s requirements 5.2.7Hydraulic design information sign Annually 5.2.6Information signs Annually 5.2.8, 5.2.9Internal piping condition

    Chapter 14Pipe and fittings Annually 5.2.2Sprinklers Annually 5.2.1Sprinklers (spare) Annually 5.2.1.4Supervisory signal devices (except valve supervisory switches) Quarterly5X .2X .5XSystem valves

    Chapter 13Valve supervisory signal devices Quarterly 5.2.5Waterflow alarm devices Quarterly 5.2.5

    ? Test

    Antifreeze solution Annually 5.3.4Control valves

    Chapter 13

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  • Gauges 5 years Chapter 13Main drain

    Chapter 13

    Sprinklers At 50 years and every 10 yearsthereafter5.3.1.1.1, 5.3.1.1.1.1,5.3.1.1.1.2

    Sprinklers At 75 years and every 5 yearsthereafter 5.3.1.1.1.5

    Sprinklers (dry) 10 years and every 10 yearsthereafter 5.3.1.1.1.6

    Sprinklers (extra high or greater temperaturesolder type) 5 years 5.3.1.1.1.4

    Sprinklers (fast-response) At 20 years and every 10 yearsthereafter 5.3.1.1.1.3

    Sprinklers (harsh environments) 5 years 5.3.1.1.2Supervisory signal devices (except valvesupervisory switches)

    Chapter 13System valves

    Chapter 13Valve supervisory signal devices

    Chapter 13Waterflow alarm devices (Mechanical) Quarterly 5.3.3.1Waterflow alarm devices (vane and pressure switch type) Semiannually 5.3.3.2

    ? Maintenance

    Low-point drains (dry pipe and preaction systems)

    Chapter 13Sprinklers and automatic spray nozzles protecting commercial cooking equipment andventilation systems Annually 5.4.1.7

    Valves (all types)

    Chapter 13

    ? Investigation

    Obstruction

    Chapter 14

    Statement of Problem and Substantiation for Public Input

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  • Table 5.1.1.2, Inspection, Supervisory signal devices (except valve supervisory switches) are noted as being inspected quarterly with a reference of Section 5.2.2. Section 5.2.5 addresses hydraulic name plates not supervisory switches. 5.2.5* Hydraulic Design Information Sign. The hydraulic design information sign shall be inspected annually to verify that it is provided, attached securely to the sprinkler riser, and is legible. Insert the appropriate section to be referenced for the required inspection. May be prudent to check all of the references in the table.

    Submitter Information Verification

    Submitter Full Name: Tom ChristmanOrganization: Self EmployeedAffilliation: NoneStreet Address:City:State:Zip:Submittal Date: Wed Mar 22 13:31:52 EDT 2017

    Committee Statement

    Resolution: FR-43-NFPA 25-2017Statement: Table 5.1.1.2, Inspection, Supervisory signal devices (except valve supervisory switches) are noted

    as being inspected quarterly with a reference of Section 5.2.2. Section 5.2.5 addresses hydraulicname plates not supervisory switches. 5.2.5* Hydraulic Design Information Sign. The hydraulic designinformation sign shall be inspected annually to verify that it is provided, attached securely to thesprinkler riser, and is legible. Insert the appropriate section to be referenced for the requiredinspection. May be prudent to check all of the references in the table. Editorial revisions.

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  • Public Input No. 108-NFPA 25-2017 [ Section No. 5.2.1.1 [Excluding any Sub-Sections] ]

    Sprinklers All sprinklers shall be inspected from the floor level annually.

    Statement of Problem and Substantiation for Public Input

    There have been little or no AHJ enforcement to perform a 100% walk through annual inspection of sprinkler heads within individual residential units. End users, property owners or their representatives are now posing questions to us about the validity of the requirement.

    Submitter Information Verification

    Submitter Full Name: Sandra StanekOrganization: Unifour Fire and SafetyStreet Address:City:State:Zip:Submittal Date: Tue Jun 13 10:15:07 EDT 2017

    Committee Statement

    Resolution: Access to residential units is a local and state issue.The standard already requires all sprinklers to beinspected from the floor except for those that are permitted to be admitted from the inspection, see5.1.1.3 and 5.1.1.4.

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  • Public Input No. 119-NFPA 25-2017 [ Section No. 5.2.1.1 [Excluding any Sub-Sections] ]

    Sprinklers shall be inspected from the floor level annually. annually or at a frequency described by themanufacturer’s Data Sheet . .

    Statement of Problem and Substantiation for Public Input

    New technology has been developed for a sprinkler that is electronically operated. These sprinklers are UL listed and are on the market. There currently isn’t guidance in NFPA 25 for inspecting, testing, and maintenance of these sprinklers. The proposed language addresses very basic requirements for this new technology based on the manufacturer’s Data Sheet.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 118-NFPA 25-2017 [New Section after3.3.40.5]

    Definition of Electrically OperatedSprinkler

    Public Input No. 120-NFPA 25-2017 [New Section after 5.3.1]Public Input No. 121-NFPA 25-2017 [New Section after5.4.1.7]

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Tue Jun 20 20:30:54 EDT 2017

    Committee Statement

    Resolution: This would put a burden on the inspector to have all the cutsheets for the sprinklers in a facility.

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  • Public Input No. 142-NFPA 25-2017 [ Section No. 5.2.1.1 [Excluding any Sub-Sections] ]

    Sprinklers shall be inspected from the floor level annually. The coverplates of a concealed s prinklers shallbe removed to expose the sprinkler for inspection and then replaced after the inspection.

    Statement of Problem and Substantiation for Public Input

    There is no possible way to comply with 5.2.1.1.1 (1) through (6) with a coverplate attached. In addition there is no way to even determine that there is a sprinkler above the plate if the coverplate was simply glued to the ceiling.

    Submitter Information Verification

    Submitter Full Name: John DeutschOrganization: Shambaugh SonStreet Address:City:State:Zip:Submittal Date: Mon Jun 26 12:33:19 EDT 2017

    Committee Statement

    Resolution: The removal of cover plates from concealed sprinklers is unreasonable. NFPA 25 requires inspectionof sprinklers from the floor and the removal of cover plates would require additional equipment toreach the sprinklers. Sprinklers in concealed spaces do not need to be inspected.

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  • Public Input No. 143-NFPA 25-2017 [ Section No. 5.2.1.1 [Excluding any Sub-Sections] ]

    Sprinklers shall be inspected from the floor level annually. The coverplates of concealed sprinklers need not beremoved for inspection.

    Statement of Problem and Substantiation for Public Input

    The standard is silent on the removal of coverplates and leaves the decision up to the inspector. One might assume that in order to comply with 5.2.1.1 that it is obvious that the coverplate must be removed which cannot be done from the floor as indicated in 5.2.1.1. This revision simply clarifies what I believe is presently the norm. Coverplates are not being removed.

    Submitter Information Verification

    Submitter Full Name: Jack ThackerOrganization: Shambaugh & SonAffilliation: NFSAStreet Address:City:State:Zip:Submittal Date: Mon Jun 26 12:42:05 EDT 2017

    Committee Statement

    Resolution: FR-126-NFPA 25-2017Statement: There may be conditions where you might need to remove concealed sprinklers and other instances

    where you may not.

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  • Public Input No. 191-NFPA 25-2017 [ New Section after 5.2.1.1.3 ]

    TITLE OF NEW CONTENTConcealed fire sprinklers installed in drywall or suspended cielings shall be considered installed in aconcealec space and therfore only require visual inspection of the coverplate assembly for any items listedin 5.2.1.1.1.

    Type your content here ...

    Statement of Problem and Substantiation for Public Input

    5.2.1.1 states sprinklers shall be inspected from floor level annually, however the actual concealed sprinkler is not visible from the floor unless the cover plate is removed. It would be impossible to inspect these heads without removing the cover plate, however I do not believe the intent was ever to require that the cover plates to actually ever be removed. This simply will clarify that visually inspecting the sprinkler assembly in this case satisfies the inspection requirement.

    Submitter Information Verification

    Submitter Full Name: David BaronOrganization: Global Fire Protection CompanyStreet Address:City:State:Zip:Submittal Date: Tue Jun 27 16:10:13 EDT 2017

    Committee Statement

    Resolution: FR-126-NFPA 25-2017Statement: There may be conditions where you might need to remove concealed sprinklers and other instances

    where you may not.

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  • Public Input No. 206-NFPA 25-2017 [ Sections 5.2.7, 5.2.8 ]

    Sections 5.2.7, 5.2.8

    5.2.7 General Information Sign.

    The information sign required by 4.1.9 shall be inspected annually to verify that it is provided, securelyattached, and legible.

    5.2.8 * General Information Sign.

    The general information sign required by NFPA 13 shall be inspected annually to verify that it is provided,securely attached, and legible.

    Statement of Problem and Substantiation for Public Input

    5.2.8 and A.5.2.8 serve no useful purpose if 4.1.9 is tied back to NFPA 13. Additionally, adding the word General to 5.2.7 makes this section uniform with 4.1.9 and NFPA 13.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 205-NFPA 25-2017 [Section No. 4.1.9]Public Input No. 207-NFPA 25-2017 [Section No. A.5.2.8]

    Submitter Information Verification

    Submitter Full Name: Wilton MarburgerOrganization: Myers Risk Services, Inc.Street Address:City:State:Zip:Submittal Date: Wed Jun 28 14:32:45 EDT 2017

    Committee Statement

    Resolution: FR-29-NFPA 25-2017Statement: This clarifies that if a general information sign is present the sign requirements per NFPA 25 are

    achieved and an extra information sign is not required.

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  • Public Input No. 93-NFPA 25-2017 [ New Section after 5.2.8 ]

    TITLE OF NEW CONTENT5.2.8.1 The sign shall include the following information:

    (1) Name and location of the facility protected

    (2) Occupancy classification

    (3) Commodity classification

    (4) Presence of high-piled and/or rack storage

    (5) Maximum height of storage planned

    (6) Aisle width planned

    (7) Encapsulation of pallet loads

    (8) Presence of solid shelving

    (9) Flow test data

    (10 Presence of flammable/combustible liquids

    (11) Presence of hazardous materials

    (12) Presence of other special storage

    (13) Location of auxiliary drains and low point drains on dry pipe and preaction systems

    (14) Original results of main drain flow test

    (15) Name of installing contractor or designer

    (16) Indication of presence and location of antifreeze or other auxiliary systems

    (17) Where injection systems are installed to treat MIC or corrosion, the type of chemical, concentration ofthe chemical, and where information can be found as to the proper disposal of the chemical.

    [ 13 :25.6.2]

    Statement of Problem and Substantiation for Public Input

    The standard should state all required information. One should not have to go back to NFPA 13 for the details of the General Information Sign

    Submitter Information Verification

    Submitter Full Name: Sandra StanekOrganization: Unifour Fire and SafetyStreet Address:City:State:Zip:Submittal Date: Tue May 30 15:51:11 EDT 2017

    Committee Statement

    Resolution: FR-29-NFPA 25-2017Statement: This clarifies that if a general information sign is present the sign requirements per NFPA 25 are

    achieved and an extra information sign is not required.

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  • Public Input No. 120-NFPA 25-2017 [ New Section after 5.3.1 ]

    5.3.2 Electrically Operated Sprinklers

    5.3.2.1 Electrically operated sprinklers shall be tested in accordance with the manufacturer’s Data Sheet.5.3.2.2 The testing of the electronic actuation and supervision shall be in accordance with themanufacturer’s Data Sheet and NFPA 72.

    Statement of Problem and Substantiation for Public Input

    New technology has been developed for a sprinkler that is electronically operated. These sprinklers are UL listed and are on the market. There currently isn’t guidance in NFPA 25 for inspecting, testing, and maintenance of these sprinklers. The proposed language addresses very basic requirements for this new technology based on the manufacturer’s Data Sheet.

    Related Public Inputs for This Document

    Related Input RelationshipPublic Input No. 118-NFPA 25-2017 [New Section after 3.3.40.5] DefinitionPublic Input No. 119-NFPA 25-2017 [Section No. 5.2.1.1 [Excluding any Sub-Sections]]

    Inspectionrequirement

    Public Input No. 121-NFPA 25-2017 [New Section after 5.4.1.7]

    Submitter Information Verification

    Submitter Full Name: Terry VictorOrganization: TycoSimplexGrinnellStreet Address:City:State:Zip:Submittal Date: Tue Jun 20 20:34:46 EDT 2017

    Committee Statement

    Resolution: This technology should be presented to the installation standards prior to the ITM standard. Chapter4, 4.1.1.1 already states that the manufacturers data sheets need to be consulted. Currentlymanufacturers data sheets are not available online.

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  • Public Input No. 176-NFPA 25-2017 [ Section No. 5.3.1.1.1 [Excluding any Sub-Sections]

    ]

    Where sprinklers have been in service installed for 50 years, they shall be replaced or representativesamples from one or more samp