Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 467 SAF-FUN (Entire Document) _______________________________________________________________________________________________ Submitter: James R. Quiter, Arup Recommendation: Change “Emergency Plan” to “Emergency Action Plan” throughout the document. (NFPA 101, Life Safety Code). Substantiation: The High Rise Building Safety Advisory Committee (HRB-SAC) recommends revising the term “emergency plan” to “emergency action plan”. The term “emergency action plan” is consistent with that used by the industry as well as the fire service. The term “emergency action plan” is also consistent with the document currently being produced by HRB-SAC, titled “Guide for the Development of Emergency Action Plans for High Rise Buildings”. Emergency action plans primarily describe the required actions and responsibilities of building occupants, staff and personnel during a fire emergency and other emergencies that may occur in a building. This includes fire drills, evacuation procedures and strategies, and the use and availability of fire protection systems. This public input was prepared by the NFPA High Rise Building Safety Advisory Committee. The HRB-SAC members are: James Quiter (Chair), Arup Geoff Craighead, Universal Protection Service Jon Magnusson, National Council of Structural Engineers Associations John Miller, Los Angeles City Fire Department Jack Murphy, Fire Safety Directors Association of Greater New York Steven Nilles, Council on Tall Buildings and Urban Habitat Jake Pauls, American Public Health Association Jim Shea, Tishman Speyer William Stewart, Metropolitan Fire Chiefs-IAFC Sally Regenhard, The Skyscraper Safety Campaign Charles Jennings (Alternate to Regenhard), The Skyscraper Safety Campaign Kristin Bigda, NFPA Staff HRB-SAC is an advisory committee established by the NFPA Standards Council to advise the association, and especially the association’s technical committees, on all safety issues related to high rise buildings. HRBSAC Ballot Results for This Input: 10 Eligible to vote 9 Affirmative Votes (C. Jennings for S. Regenhard) 1 Not Returned (S. Nilles) Public Input Response: See FR102. _______________________________________________________________________________________________ 101 75 SAF-FUN (2.1(2)) _______________________________________________________________________________________________ Submitter: Bill Galloway, Southern Regional Fire Code Development Committee Recommendation: Revise to read: 2.1(2) Where the requirements of a referenced code or standard differ from the requirements of this Code, the requirements of this the more restrictive code or standard Code shall govern. Substantiation: The way this Code statement is written, it sounds as if NFPA 101 governs over all other codes even if other codes are more restrictive. Whereas NFPA 101 is a ‘life safety’ code, other NFPA codes take in to account building protection which may have a more restrictive requirement. An example: 101:42.8.1.6 Minimum Construction Requirements. (No requirements.) –which implies that as per NFPA 101 –any construction type that will withstand the load is acceptable as there are no requirements dictating fire resistance of the structure in NFPA 101. 88A: Chapter 4 –has specific construction type requirements based on fire resistance rating of structural members. Public Input Response: The change proposed by the submitter would have the effect of removing the decision making power of the AHJ by forcing compliance with the more restrictive provisions which might have the effect of having to work outside the intent of this Code. See 1.1.6 relative to "areas not addressed." See the first revision that makes change to the "No Requirement" entries of multiple provisions related to building construction within the occupancy chapters - a subject raised by the submitter. Also see the first revision to 4.4.2.3 which is being made to help clarify the issue. Printed on 9/13/2012 1 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 113 SAF-FUN (2.3.6) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Add new text to read as follows: ASTM E 2768, Standard Test Method for Extended Duration Surface Burning Characteristics of Building Materials (30 min Tunnel Test), (2011). Substantiation: ASTM has now issued a test method, ASTM E2768, which contains the three requirements discussed in this section, namely that a product be tested in accordance with ASTM E84 or UL 723, and exhibit a flame spread index of 25 or less, show no evidence of significant progressive combustion when the test is continued for 30 minutes (i.e. an additional 20-minute period over the standard ASTM E84 duration of 10 minutes) and that the flame front not 1 progress more than 10 /2 feet (3200 mm) beyond the centerline of the burners at any time during the test. This change replaces the lengthy information about requirements with a reference to the standard. The NFPA Manual of Style does not allow requirements in definitions. Therefore this change places the requirements into a new section in Chapter 4, immediately following the requirements for noncombustible material and limited combustible material. Public Input Response: The document is not being referenced by any code requirement, so it is not permitted to appear in Chapter 2. _______________________________________________________________________________________________ 101 117 SAF-FUN (2.3.6) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Add text to read as follows: ASTM E2768, Standard Test Method for Extended Duration Surface Burning Characteristics of Building Materials (30 min Tunnel Test) (2011), to Chapter 2, in the section on Referenced ASTM Standards. Substantiation: ASTM has now issued a test method, ASTM E2768, which contains the three requirements discussed in this section, namely that a product be tested in accordance with ASTM E84 or UL 723, and exhibit a flame spread index of 25 or less, show no evidence of significant progressive combustion when the test is continued for 30 minutes (i.e. an additional 20-minute period over the standard ASTM E84 duration of 10 minutes) and that the flame front not 1 progress more than 10 /2 feet (3200 mm) beyond the centerline of the burners at any time during the test. Public Input Response: The document is not being referenced by any code requirement, so it is not permitted to appear in Chapter 2. Printed on 9/13/2012 2 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 135 SAF-FUN (2.3.6) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Revise text to read as follows: 2.3.6 ASTM Publications. ASTM International, P.O. Box C700, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959. www.astm.org ASTM C 1629/C 1629M, Standard Classification for Abuse-Resistant Nondecorated Interior Gypsum Panel Products and Fiber-Reinforced Cement Panels, 2006 (2011) . ASTM D 1929, Standard Test Method for Determining Ignition Temperatures of Plastic,2011 1996 (2001e1). ASTM D 2859, Standard Test Method for Ignition Characteristics of Finished Textile Floor Covering Materials, 2006 (2011). ASTM D 2898, Standard Test Methods for Accelerated Weathering of Fire-Retardant-Treated Wood for Fire Testing, 2010. ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2012 2010. ASTM E 108, Standard Test Methods for Fire Tests of Roof Coverings, 2011 2010a. ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials, 2012 2010b. ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 Degrees C, 2011 2009b. ASTM E 648, Standard Test Method for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source, 2010 e1. ASTM E 814, Standard Test Method for Fire Tests of Through-Penetration Fire Stops, 2011a 2010. ASTM E 1352, Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies, 2008a. ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture, 2008a(e1). ASTM E 1354, Standard Test Method for Heat and Visible Smoke Release Rates for Materials and Products Using an Oxygen Consumption Calorimeter, 2011b 2009. ASTM E 1537, Standard Test Method for Fire Testing of Upholstered Furniture, 2012 2007. ASTM E 1590, Standard Test Method for Fire Testing of Mattresses, 2012 2007. ASTM E 1591, Standard Guide for Obtaining Data for Deterministic Fire Models, 2007. ASTM E 1966, Standard Test Method for Fire-Resistive Joint Systems, 2007 (2011). ASTM E 2072, Standard Specification for Photoluminescent (Phosphorescent) Safety Markings, 2010. ASTM E 2074, Standard Test Method for Fire Tests of Door Assemblies, Including Positive Pressure Testing of Side-Hinged and Pivoted Swinging Door Assemblies, 2000 e1 (withdrawn 2007), Revised 2004. ASTM E 2307, Standard Test Method for Determining Fire Resistance of Perimeter Fire Barrier Systems Using Intermediate-Scale, Multi-Story Test Apparatus, 2010. ASTM E 2404, Standard Practice for Specimen Preparation and Mounting of Textile, Paper or VinylWall or Ceiling Coverings to Assess Surface Burning Characteristics, 2010 2008. ASTM E 2573, Standard Practice for Specimen Preparation and Mounting of Site-Fabricated Stretch Systems to Assess Surface Burning Characteristics, 2012 2007a. ASTM E 2599, Standard Practice for Specimen Preparation and Mounting of Reflective Insulation Materials and Radiant Barrier Materials for Building Applications to Assess Surface Burning Characteristics, 2011 2009. ASTM E 2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-shaped Airflow Stabilizer, at 750 Degrees C, 2009a. ASTM F 851, Standard Test Method for Self-Rising Seat Mechanisms, 1987 (2005). ASTM F 1577, Standard Test Methods for Detention Locks for Swinging Doors, 2005. ASTM G 155, Standard Practice for Operating Xenon Arc Light Apparatus for Exposure of Non-Metallic Materials, 2005a. Substantiation: Standards update. ASTM E1352 and ASTM E1353 are recommended for removal by other public input. Public Input Response: See FR105. Printed on 9/13/2012 3 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 42 SAF-FUN (2.3.7) _______________________________________________________________________________________________ Submitter: John F. Bender, UL LLC Recommendation: Revise text as follows: 2.3.7 FMGR Publications. FM Global Research, FM Global, 1301 Atwood Avenue, P.O. Box 7500, Johnston, RI 02919. www.fmglobal.com ANSI/FM 4880, American National Standard for Evaluating Insulated Wall or Wall and Roof/Ceiling Assemblies, Plastic Interior Finish Materials, Plastic Exterior Building Panels, Wall/Ceiling Coating Systems, Interior or Exterior Finish Systems, 2007. FM Approval Standard 6921, Containers for Combustible Waste, 2004. UL 300, Standard for Fire Testing of Fire Extinguishing Systems for Protection of Commercial Cooking Equipment, 2005, Revised 2010. Substantiation: Delete reference to UL 300 in this section and relocate to section 2.3.9 as ANSI/UL 300 is a UL publication. Public Input Response: See FR106. _______________________________________________________________________________________________ 101 43 SAF-FUN (2.3.9) _______________________________________________________________________________________________ Submitter: John F. Bender, UL LLC Recommendation: Revise text as follows: 2.3.9 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. www.ul.com ANSI/UL 9, Standard for Fire Tests of Window Assemblies, 2009. ANSI/UL 10B, Standard for Fire Tests of Door Assemblies, 2008, Revised 2009. ANSI/UL 10C, Standard for Positive Pressure Fire Tests of Door Assemblies, 2009. ANSI/UL 263, Standard for Fire Tests of Building Construction and Materials, 2007 2011. ANSI/UL 294, Standard for Access Control System Units, 1999, Revised 2010. ANSI/UL 300, Standard for Fire Testing of Fire Extinguishing Systems for Protection of Commercial Cooking Equipment, 2005, Revised 2010. UL 300A, Extinguishing System Units for Residential Range Top Cooking Surfaces, 2006. ANSI/UL 305, Standard for Safety Panic Hardware, 1997, Revised 2011. ANSI/UL 555, Standard for Fire Dampers, 2006, Revised 2010 2011. ANSI/UL 555S, Standard for Smoke Dampers, 1999, Revised 2010 2011. ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, 2008, Revised 2010. ANSI/UL 790, Test Methods for Fire Tests of Roof Coverings, 2004, Revised 2008. ANSI/UL 924, Standard for Emergency Lighting and Power Equipment, 2006, Revised 2009 2011. ANSI/UL 1040, Standard for Fire Test of Insulated Wall Construction, 1996, Revised 2007. ANSI/UL 1315, Standard for Safety for Metal Waste Paper Containers, 2007. ANSI/UL 1479, Standard for Fire Tests of Through-Penetration Firestops, 2003, Revised 2010. ANSI/UL 1715, Standard for Fire Test of Interior Finish Material, 1997, Revised 2008. ANSI/UL 1784, Standard for Air Leakage Tests for Door Assemblies, 2001, Revised 2009. ANSI/UL 1975, Standard for Fire Tests for Foamed Plastics Used for Decorative Purposes, 2006. ANSI/UL 1994, Standard for Luminous Egress Path Marking Systems, 2004, Revised 2010. ANSI/UL 2079, Standard for Tests for Fire Resistance of Building Joint Systems, 2004, Revised 2008. Substantiation: Add reference to ANSI/UL 300 to this section as a UL publication since it is improperly located in section 2.3.7 intended for FMGR publications. Delete ANSI approval designation from UL 1975 as UL 1975 is not ANSI approved. Update referenced standards to most recent edition as indicated. Public Input Response: See FR107. Printed on 9/13/2012 4 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 278 SAF-FUN (3.3.21.2.1) _______________________________________________________________________________________________ Submitter: Joseph H. Versteeg, Versteeg Associates Recommendation: Revise definition to read as follows: 3.3.21 .2.1* Gross Floor Area. The floor area within the inside perimeter of the outside walls of the building under consideration with no deductions for hallways, stairs, closets, thickness of interior walls, columns, elevator and building services shafts, or other features. Floor openings associated with atriums and communicating spaces are not to be included in gross floor area. Substantiation: During the ROP phase of the development of the 2012 edition, a proposal sought to clarify whether or not the open area of an atrium or communicating space be included or excluded from the gross floor area calculations. The committee voted to accept the proposal in principle and remove the wording from this section that would have included the open area. Although the intent of the committee is clear that such open areas are not to be included, the definition reads no differently due to the way I phrased the proposal (apologies) leaving Code users unaware of the end result. Public Input Response: See FR103. _______________________________________________________________________________________________ 101 281 SAF-FUN (3.3.21.2.2 Net Floor Area) _______________________________________________________________________________________________ Submitter: Joseph H. Versteeg, Versteeg Associates Recommendation: Revise definition to read as follows: 3.3.21.2.2 Net Floor Area. The floor area within the inside perimeter of the outside walls, or the outside walls and fire walls of a building, or outside and/or inside walls that bound an occupancy or incidental use area requiring the occupant load to be calculated using net floor area under consideration with deductions for hallways, stairs, closets, thickness of interior walls, columns, or other features. Substantiation: The current definition only addresses the entire interior of a building but does not address the fact that there are often interior spaces within the overall building that require the use of new floor area for calculating occupant loads; i.e. incidental assembly uses such as conference rooms and day cares. Public Input Response: See FR108. _______________________________________________________________________________________________ 101 275 SAF-FUN (3.3.31.1 Fire Barrier) _______________________________________________________________________________________________ Submitter: Joseph H. Versteeg, Versteeg Associates Recommendation: Revise definition to read as follows: 3.3.31.1 * Fire Barrier. A continuous membrane or a membrane with discontinuities created by protected openings with a specified fire protection rating, where such membrane is designed and constructed with a specified fire resistance rating to limit the spread of fire, that also restricts the movement of smoke. Substantiation: For several editions this section has referenced 7.2.1.4(3) which does not exist. The correct reference is as shown in the proposed change. Fire barriers are not tested for the passage of smoke or products of combustion through the assembly and by including this phrase; it adds to the confusion that fire barriers are smoke barriers. Public Input Response: See FR109. Printed on 9/13/2012 5 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 3 SAF-FUN (3.3.81 Exit) _______________________________________________________________________________________________ Submitter: Kenneth E. Bush, Maryland State Fire Marshals Office Recommendation: Revise Paragraph 3.3.81 as follows: That portion of a means of egress that is separated from all other spaces of the building or structure by construction, location, or equipment as required to provide a protected way of travel to the exit discharge. Substantiation: These changes are intended to clarify the intent that exterior doors serving as exits are not required to have a fire protection rating because they are serving as required exits. Where the door opens to the exterior of the building, the protected way of travel to the exit discharge involves only travel through the door opening, and it is not intended to require special separation from other parts of the building. Specific reference was made in the Annex to limit the intent of this paragraph for designated exit purposes only, and does not preclude the requirements for fire protection ratings on doors where other conditions, such as exposures to means of egress or other parts of the building beside or above the door opening, may require the installation of a fire-rated opening protective by other code provisions. Public Input Response: See FR110. _______________________________________________________________________________________________ 101 110 SAF-FUN (3.3.107 Fire-Retardant-Treated Wood) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Revise text to read as follows: A wood product impregnated with chemical by a pressure process or other means during manufacture, which is tested in accordance with ASTM E 84,Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Burning Materials, has a listed flame spread index of 25 or less, and shows no evidence of significant progressive combustion when the test is continued for an additional 20-minute period; nor does the flame front progress more than 10.5 ft (3.2 m) beyond the centerline of the burners at any time during the test. See 4.6.15. Substantiation: ASTM has now issued a test method, ASTM E2768, which contains the three requirements discussed in this section, namely that a product be tested in accordance with ASTM E84 or UL 723, and exhibit a flame spread index of 25 or less, show no evidence of significant progressive combustion when the test is continued for 30 minutes (i.e. an additional 20-minute period over the standard ASTM E84 duration of 10 minutes) and that the flame front not 1 progress more than 10 /2 feet (3200 mm) beyond the centerline of the burners at any time during the test. This change replaces the lengthy information about requirements with a reference to the standard. The NFPA Manual of Style does not allow requirements in definitions. Therefore this change places the requirements into a new section in Chapter 4, immediately following the requirements for noncombustible material and limited combustible material. Public Input Response: See FR111 which correlates action on the term FRTW between NFPA 101 and NFPA 5000. Printed on 9/13/2012 6 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 378 SAF-FUN (3.3.155 Joint) _______________________________________________________________________________________________ Submitter: William E. Koffel, Koffel Associates, Inc. Recommendation: Add text to read: Joint. The junction where adjacent assemblies intersect without applying a static load from one element to another, with or without physical contact between the assemblies, which is created due to building tolerances, or to allow independent movement of the building in any plane caused by thermal, seismic, wind or any other loading. Substantiation: Section 8.3.6 requires the protection of certain joints. If one uses the dictionary definition of "joint", the application of the section may be far more reaching than what is intended. It should be noted that "joint" is defined in NFPA 5000 but is not defined in NFPA 101. The proposed definition is not the same as the definition in NFPA 5000; but rather, is consistent with the definition that was proposed for the International Building Code. If the Committee chooses this definition, the defintion in NFPA 5000 should be revised as well. It should be noted that Koffel Associates, Inc. provides consulting services to the Firestop Contractors International Association and we submitted a different definition to the International Building Code. I have not indicated that we are representing the FCIA for this Public Input since this is not the definition that FCIA submitted to the IBC and we were not authorized to submit this definition on behalf of the FCIA. Public Input Response: Insufficient substantiation to differ from the definition in NFPA 5000. The NFPA 5000 definition seems to be adequate. The definition, as copied from NFPA 5000, is being added to NFPA 101. _______________________________________________________________________________________________ 101 523 SAF-FUN (3.3.171 Means of Escape) _______________________________________________________________________________________________ Submitter: Norman E. Groner, John Jay College of Criminal Justice Recommendation: Revise to read: 3.3.171 Means of Escape. A feasible means of relocating people way out of or to a safer location in a building or structure that does not conform to the strict definition of means of egress but does provide an alternate way move building occupants out. Substantiation: Section 4.2.1 explains that an “additional goal [of the Code] is to provide life safety during emergencies that can be mitigated using methods comparable to those used in case of fire.” The proposed amendment extends and clarifies the definition of a means of escape by including escape from hazards by relocating people within a building as well as moving them to the exterior of the building. Relocating inside of a building is a frequently employed goal when protecting people against non-fire hazards such as severe weather, bomb threats, workplace violence, earthquakes, etc. Moreover, the logic of relocating occupants within buildings is included in section 4.8.2.1(3). The proposed change in definition will help to determine whether emergency plans satisfy the intent of 4.8..2.1(3) by ensuring that building occupants are provided with an feasible path to a safer location within a building even when that path does not meet the requirements of a means of egress. Public Input Response: The term "Means of Escape" has special meaning within NFPA 101 relative, mainly, to the escape route from residential living/dwelling units. The recommended text provides no improvement and seems not applicable to the multiple uses of the term within the Code. The current definition needs to be retained. Printed on 9/13/2012 7 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 487 SAF-FUN (3.3.206.x Penthouse (New) ) _______________________________________________________________________________________________ Submitter: Masoud Sabounchi, Advanced Consulting Engineers, Inc. Recommendation: Add a new section to read: 3.3.206.x Penthouse. Enclosed non-occupied structures above the roof where the aggregate area of the enclosed structures does not exceed 1/3 of the roof area. Penthouse shall not be used for purposes other than shelter of mechanical equipment or shelter of shaft extensions above the roof. Substantiation: Penthouse are incidental use areas intended to shelter mechanical equipment or are extensions shafts above building roof. NFPA 101 does not presently have a definition for penthouses. If the committee wishes, construction materials for penthouses can be included. For example, penthouses serving buildings of type I, II may be constructed of noncombustible and non-fire resistance rated materials. Public Input Response: The term penthouse is used only in advisory annex text associated with the definition of "occupiable story." The proposed definition would add requirements within a definition. Even if requirements could be contained within definitions, there's no justification for limiting a penthouse's area to the 1/3 criterion recommended by the submitter. _______________________________________________________________________________________________ 101 7 SAF-FUN (4.5.1) _______________________________________________________________________________________________ Submitter: M. van Zeijl, European Fire Protection Consultants B.V. Recommendation: Add new text to read as follows: 4.5.1 Multiple Safeguards. The design of every building or structure and fire protection features critical for the building or structure intended for human occupancy shall be such... Substantiation: The current wording leaves much space for interpretation and discussion about the requirement for multiple safeguards. To the opinion of this proposal author, the additional text gives some more direction. By suggesting the availability evaluation, designers are requested to consider malfunction and maintenance issues, and as such provide sufficient provisions. Public Input Response: The verbiage of 4.5.1 is intentionally broad and is not intended to be limited strictly to fire safety. Section 4.5 assists in defining the scope for multiple safeguards. _______________________________________________________________________________________________ 101 111 SAF-FUN (4.6.15) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Add new text to read as follows: 4.6.15* Fire-Retardant-Treated Wood. A listed wood product impregnated with chemical by a pressure process or other means during manufacture, which complies with the requirements of ASTM E2786. Substantiation: ASTM has now issued a test method, ASTM E2768, which contains the three requirements discussed in this section, namely that a product be tested in accordance with ASTM E84 or UL 723, and exhibit a flame spread index of 25 or less, show no evidence of significant progressive combustion when the test is continued for 30 minutes (i.e. an additional 20-minute period over the standard ASTM E84 duration of 10 minutes) and that the flame front not 1 progress more than 10 /2 feet (3200 mm) beyond the centerline of the burners at any time during the test. This change replaces the lengthy information about requirements with a reference to the standard. The NFPA Manual of Style does not allow requirements in definitions. Therefore this change places the requirements into a new section in Chapter 4, immediately following the requirements for noncombustible material and limited combustible material. Public Input Response: The proposed text is not consistent with the actions taken on the subject by the BLD/BLC and BLD/SCM technical committees for NFPA 5000. A new definition for FRTW, from NFPA 703, will be used in Chapter 3. Printed on 9/13/2012 8 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 526 SAF-FUN (4.8.2.1(3)) _______________________________________________________________________________________________ Submitter: Norman E. Groner, John Jay College of Criminal Justice Recommendation: Revise to read: (3)* Evacuation procedures, relocation and remain-in-place procedures appropriate to the building, its occupancy, emergencies, and hazards (see Section 4.3) Substantiation: Exclusive use of the term “evacuation” in the context of emergency planning does not accurately represent planning to keep people separated from fire and other “comparable” hazards. Best practice often involves moving people to safer locations in buildings and keeping them where they are already located. Public Input Response: See FR117. Printed on 9/13/2012 9 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 524 SAF-FUN (Table 4.8.2.1(3)) _______________________________________________________________________________________________ Submitter: Norman E. Groner, John Jay College of Criminal Justice Recommendation: Include 101_L524_R (PI #478) Substantiation: Section A.4.8.2.1(3) provides a list of items that should be considered when designing emergency plans. However, it does not currently provide any recommendation about how to actually design an emergency plan that is tailored to specific buildings, occupants and “comparable hazards.” The proposed addition to the section is intended to provide such guidance. The Firesafety Concepts Tree (NFPA 550) is an example of a “success tree.” The Firesafety Concepts Tree is a tool designed to help system designers (e.g., fire protection engineers and building managers) think systematically about how to protect building occupants from being exposed to the hazards of fire, regardless of specific scenarios. The Firesafety Concept Tree is a generic tree—it is general enough to be used to a wide range of fire scenarios. However, a success tree is of greatest value when it is specific to a specific hazard scenario in a particular building. A building-specific success tree shows how to design a system that is intended to respond effectively to a specific type of threat. In this situation, you select a scenario and use a success tree as a means to find the best ways to cope with the specific scenario. It is useful to note that the “manage exposed” branch of the Firesafety Concepts Tree can be applied to all types of hazards, not just fires. You can use the general guidance provided by this part of the tree to help solve people movement design problems involving a wide variety of threats. As an example of how the manage exposed logic of the Firesafety Concepts Tree can be applied, consider the hazard of a workplace violence scenario where an armed ex-employee seeks revenge against a boss and fellow workers. Despite the fact that this scenario differs radically from a fire, the “manage exposed” part of the tree works remarkably well. The tree presents the options of defending the exposed in place or moving them. If you defend people by leaving them where they are already located, you need to “restrict their movement and defending the place (perhaps by keeping the door to the space closed and locked and by asking people to be silent to avoid alerting the perpetrator to their location). If the “move exposed” approach is taken, then you need to “cause movement of exposed” by detecting the need (i.e., assessing their vulnerability to the perpetrator), signaling the need (e.g., telephoning people you want moved), and providing instructions (e.g., telling the people which direction to move). In addition, the tree reveals that you also need to provide a safe destination (e.g., a location out of the line-of-sight of the perpetrator). Finally, you need to provide movement means, that is, you need to establish that the capacity is adequate (e.g., it is difficult to move an auditorium full of people through a kitchen), and so forth. Public Input Response: The method proposed is like performance-based language inserted into the advisory annex related to a prescriptive requirement. The method needs further development and validation. The subject, as presented, seems too large and boundless. It will take research and development to flesh out the topic. This might best be done as a long-term project. Printed on 9/13/2012 10 Sections A.4.8.2.1(3) , A.4.8.2.1(3) (3) It is assumed that a majority of buildings will use a total evacuation strategy during a fire. It should be noted that evacuation from a building could occur for reasons other than a fire, but such other reasons are not the primary focus of the Code. As used herein, total evacuation is defined as the process in which all, or substantially all, occupants leave a building or facility in either an unmanaged or managed sequence or order. An alternative to total evacuation is partial evacuation, which can be defined as the process in which a select portion of a building or facility is cleared or emptied of its occupants while occupants in other portions mostly carry on normal activity. In either case, the evacuation process can be ordered or managed in accordance with an established priority in which some or all occupants of a building or facility clear their area and utilize means of egress routes. This is typically done so that the more-endangered occupants are removed before occupants in less-endangered areas. Alternative terms describing this sequencing or ordering of evacuation are staged evacuation and phased evacuation. Table A.4.8.2.1(3) illustrates options for extent of management and extent of evacuation. Some of the options shown might not be appropriate. As noted in Table A.4.8.2.1(3), either total or partial evacuation can include staged (zoned) evacuation or phased evacuation, which is referred to as managed or controlled evacuation. It should also be noted that the evacuation process might not include relocation to the outside of the building but might instead include relocation to an area of refuge or might defend the occupants in place to minimize the need for evacuation. Table A.4.8.2.1(3) Occupant Evacuation Strategies Extent of Management Extent of Evacuation Managed Sequence Unmanaged Sequence No evacuation No movement — remain in place upon direction No movement — remain in place per prior instruction Partial evacuation Managed or controlled partial evacuation Total evacuation Managed or controlled total evacuation n-building relocation on same floor n-building relocation to different floors ccupants of some floors leave building Unmanaged or uncontrolled partial evacuation Unmanaged or uncontrolled total evacuation The different methods of evacuation are also used in several contexts throughout the Code. Though most of the methods of evacuation are not specifically defined or do not have established criteria, various sections of the Code promulgate them as alternatives to total evacuation. The following sections discuss these alternatives in more detail: 1. Section 4.7 — Provides requirements for fire and relocation drills 2. 7.2.12 — Provides requirements for area of refuge 3. 7.2.4 — Provides requirements for horizontal exits 4. 9.6.3.6 — Provides the alarm signal requirements for different methods of evacuation 5. 9.6.3.9 — Permits automatically transmitted or live voice evacuation or relocation instructions to occupants and requires them in accordance with NFPA 72, National Fire Alarm and Signaling Code 6. 14.3.4.2.3 (also Chapter 15) — Describes alternative protection systems in educational occupancies 7. 18.1.1.2/18.1.1.3/Section 18.7 (also Chapter 19) — Provide methods of evacuation for health care occupancies 8. Chapters 22 and 23 — Provide methods of evacuation for detention and correctional occupancies, including the five groups of resident user categories 9. Chapters 32 and 33 — Provide method of evacuation for residential board and care occupancies 10. 32.1.5/33.1.5 — For residential board and care occupancies, state that “no means of escape or means of egress shall be considered as complying with the minimum criteria for acceptance, unless emergency evacuation drills are regularly conducted” 11. 40.2.5.1.2 — For industrial occupancies, states that “ancillary facilities in special-purpose industrial occupancies where delayed evacuation is anticipated shall have not less than a 2-hour fire resistance–rated 101 Log 524 (PI #478) Rec 1 separation from the predominant industrial occupancy and shall have one means of egress that is separated from the predominant industrial occupancy by 2-hour fire resistance–rated construction” The method of evacuation should be accomplished in the context of the physical facilities, the type of activities undertaken, and the provisions for the capabilities of occupants (and staff, if available). Therefore, in addition to meeting the requirements of the Code, or when establishing an equivalency or a performance-based design, the following recommendations and general guidance information should be taken into account when designing, selecting, executing, and maintaining a method of evacuation: 1. When choosing a method of evacuation, the available safe egress time (ASET) must always be greater than the required safe egress time (RSET). 2. The occupants’ characteristics will drive the method of evacuation. For example, occupants might be incapable of evacuating themselves because of age, physical or mental disabilities, physical restraint, or a combination thereof. However, some buildings might be staffed with people who could assist in evacuating. Therefore, the method of evacuation is dependent on the ability of occupants to move as a group, with or without assistance. For more information, see the definitions under the term Evacuation Capability in Chapter 3. 3. An alternative method of evacuation might or might not have a faster evacuation time than a total evacuation. However, the priority of evacuation should be such that the occupants in the most danger are given a higher priority. This prioritization will ensure that occupants more intimate with the fire will have a faster evacuation time. 4. Design, construction, and compartmentation are also variables in choosing a method of evacuation. The design, construction, and compartmentation should limit the development and spread of a fire and smoke and reduce the need for occupant evacuation. The fire should be limited to the room or compartment of fire origin. Therefore, the following factors need to be considered: 1. Overall fire resistance rating of the building 2. Fire-rated compartmentation provided with the building 3. Number and arrangement of the means of egress 5. Fire safety systems should be installed that compliment the method of evacuation, and should include consideration of the following: 1. Detection of fire 2. Control of fire development 3. Confinement of the effects of fire 4. Extinguishment of fire 5. Provision of refuge or evacuation facilities, or both 6. One of the most important fire safety systems is the fire alarm and communication system, particularly the notification system. The fire alarm system should be in accordance with NFPA 72, National Fire Alarm and Signaling Code, and should take into account the following: 1. Initial notification of only the occupants in the affected zone(s) (e.g., zone of fire origin and adjacent zones) 2. Provisions to notify occupants in other unaffected zones to allow orderly evacuation of the entire building 3. Need for live voice communication 4. Reliability of the fire alarm and communication system 7. The capabilities of the staff assisting in the evacuation process should be considered in determining the method of evacuation. 8. The ability of the fire department to interact with the evacuation should be analyzed. It is important to determine if the fire department can assist in the evacuation or if fire department operations hinder the evacuation efforts. 101 Log 524 (PI #478) Rec 2 9. Evacuation scenarios for hazards that are normally outside of the scope of the Code should be considered to the extent practicable. (See 4.3.1.) 10. Consideration should be given to the desire of the occupants to self-evacuate, especially if the nature of the building or the fire warrants evacuation in the minds of the occupants. Self-evacuation might also be initiated by communication between the occupants themselves through face-to-face contact, mobile phones, and so forth. 11. An investigation period, a delay in the notification of occupants after the first activation of the fire alarm, could help to reduce the number of false alarms and unnecessary evacuations. However, a limit to such a delay should be established before a general alarm is sounded, such as positive alarm sequence, as defined in NFPA 72, National Fire Alarm and Signaling Code. 12. Consideration should be given to the need for an evacuation that might be necessary for a scenario other than a fire (e.g., bomb threat, earthquake). 13. Contingency plans should be established in the event the fire alarm and communication system fail, which might facilitate the need for total evacuation. 14. The means of egress systems should be properly maintained to ensure the dependability of the method of evacuation. 15. Fire prevention policies or procedures, or both, should be implemented that reduce the chance of a fire (e.g., limiting smoking or providing fire-safe trash cans). 16. The method of evacuation should be properly documented, and written forms of communication should be provided to all of the occupants, which might include sign postings throughout the building. Consideration should be given to the development of documentation for an operation and maintenance manual or a fire emergency plan, or both. 17. Emergency egress drills should be performed on a regular basis. For more information, see Section 4.7 . 18. The authority having jurisdiction should also be consulted when developing the method of evacuation. Measures should be in place and be employed to sequence or control the order of a total evacuation, so that such evacuations proceed in a reasonably safe, efficient manner. Such measures include special attention to the evacuation capabilities and needs of occupants with disabilities, either permanent or temporary. For comprehensive guidance on facilitating life safety for such populations, go to www.nfpa.org. For specific guidance on stair descent devices, see A.7.2.12.2.3(2). In larger buildings, especially high-rise buildings, it is recommended that all evacuations — whether partial or total — be managed to sequence or control the order in which certain occupants are evacuated from their origin areas and to make use of available means of egress. In high-rise buildings, the exit stairs, at any level, are designed to accommodate the egress flow of only a very small portion of the occupants — from only one or a few stories, and within a relatively short time period — on the order of a few minutes. In case of a fire, only the immediately affected floor(s) should be given priority use of the means of egress serving that floor(s). Other floors should then be given priority use of the means of egress, depending on the anticipated spread of the fire and its combustion products and for the purpose of clearing certain floors to facilitate eventual fire service operations. Typically, this means that the one or two floors above and below a fire floor will have secondary priority immediately after the fire floor. Depending on where combustion products move, for example, upwards through a building with cool-weather stack effect, the next priority floors will be the uppermost occupied floors in the building. Generally, in order to minimize evacuation time for most or all of a relatively tall building to be evacuated, occupants from upper floors should have priority use of exit stairs. For people descending many stories of stairs, this priority will maximize their opportunity to take rest stops without unduly extending their overall time to evacuate a building. Thus, the precedence behavior of evacuees should be that people already in an exit stair should normally not defer to people attempting to enter the exit stair from lower floors, except for those lower floors most directly impacted by a fire or other imminent danger. Notably, this is contrary to the often observed behavior of evacuees in high-rise building evacuations where lower floor precedence behavior occurs. (Similarly, in the most commonly observed behavior of people normally disembarking a passenger airliner, people within the aisle defer to people entering the aisle, so that the areas closest to the exit typically clear first.) Changing, and generally managing, the sequence or order in which egress occurs will require effectively informing building occupants and evaluating resulting performance in a program of education, training, and drills. 101 Log 524 (PI #478) Rec 3 When designing the method of evacuation for a complex building, all forms of egress should be considered. For example, consideration could be given to an elevator evacuation system. An elevator evacuation system involves an elevator design that provides protection from fire effects so that elevators can be used safely for egress. See 7.2.13 and A.7.2.12.2.4 for more information. For further guidance, see the following publications: 1. NFPA Fire Protection Handbook, 19th edition, Section 2, Chapter 2, which provides good methodology for managing exposures and determining the method of evacuation 2. NFPA Fire Protection Handbook, 19th edition, Section 13, which provides further commentary on methods of evacuation for different occupancies 3. SFPE Handbook of Fire Protection Engineering, Section 3, Chapter 13, which provides an overview of some of the research on methods of evacuation When designing the method of evacuation for a complex building, all forms of egress should be considered. For example, consideration could be given to an elevator evacuation system. An elevator evacuation system involves an elevator design that provides protection from fire effects so that elevators can be used safely for egress. See 7.2.13 and A.7.2.12.2.4 for more information. As noted in section 4.1.2 Comparable Emergencies, provisions in the Life Safety Code are also of value in safe guarding building occupants during some emergencies in addition to fires. Most building emergencies, regardless of hazard, involve considerations of where and whether to move people. Examples, of hazards that decisions about whether and where to move people include incidents of workplace violence, bomb threats, explosion (in addition to incendiary devices), earthquakes, power outages, and extreme weather events (such as tornados). Effective decision-making about where to locate people includes developing emergency action plans that help occupants decide whether to leave buildings, relocate in the building, or remain-in-place, taking into consideration the type of hazard and the characteristics of the building and its occupants. Regardless of hazard, the same basic goal applies—to the degree feasible, people should be kept separated from the hazard. Constructing success trees (also referred to goal decompositions and means-end diagrams) is a good approach to designing people movement plans for buildings. At the top of a success tree, there is a high-level abstract goal. At each lower level, there is a best available means to achieve the higher level goal. Lower level goals become less abstract—more specific, measurable and easier to implement. In the tree, each lower level goal is a means for accomplishing the higher level goal; and each higher level goal is the reason for including the lower level goals to which it is connected. In a well-constructed success tree, each high level goal is connected to the specific means needed to accomplish it. Further, each specific means is always connected to a high level goal, so the reasons for implementing any specific measure are always apparent. The following are suggested steps to building a success tree designed to protect building occupants from a specific threat in a specific building. 1. Describe the scenario. In most situations, you will want to select a challenging, but plausible scenario. 2. Define top goal of interest. A general top goal that works in most situations is: “prevent exposure of people to the _____ [insert the specific threat or hazard].” 3. Develop the paths of success for each branch to the desired degree of detail. The tree should be developed to the point where it is obvious how to accomplish the lowest level goals in the tree. 4. Define system boundaries. It is important to decide what will and will not be included in the analysis. Goals that are impractical to pursue should be excluded from the success tree. For example, you are not able to control how many persons with disabilities are in a building, so limiting the number of such persons is not a goal that should be included in the tree. However, it is usually practical to provide some assistance to persons with disabilities, and the means to provide such assistance should be included in the tree. For further guidance, see the following publications: 1. NFPA Fire Protection Handbook, 19th edition, Section 2, Chapter 2, which provides good methodology for managing exposures and determining the method of evacuation 101 Log 524 (PI #478) Rec 4 2. NFPA Fire Protection Handbook, 19th edition, Section 13, which provides further commentary on methods of evacuation for different occupancies 3. SFPE Handbook of Fire Protection Engineering, Section 3, Chapter 13, which provides an overview of some of the research on methods of evacuation 101 Log 524 (PI #478) Rec 5 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 220 SAF-FUN (6.1.8.1.4 and 6.1.8.1.5) _______________________________________________________________________________________________ Submitter: Dana Peterson, University of New Hampshire / Rep. APPA Recommendation: Revise text to read as follows: 6.1.8.1.4* Definition - Dormitory. Student Residence Facility - A building or a space in a building in which group sleeping accommodations are provided for more than 16 persons who are not members of the same family in one room, or a series of closely associated rooms, under joint occupancy and single management, with or without meals, but with or without individual cooking facilities designed principally for students attending an educational institution. 6.1.8.1.5 Definition - Apartment Building. A building or portion thereof containing three or more dwelling units with independent cooking and bathroom facilities, or a Student Residence Facility. Substantiation: The purpose of the proposed change is to clarify the classification of occupancy types especially as it applies to student residence facilities, formerly commonly referred to, and sometimes still referred to as dormitories. Currently, dormitories are listed as hotel occupancies which we feel is an incorrect designation for today's student residence facilities. The definition provided for a dormitory suggests a student lifestyle and building type of a bygone day. Today's residence halls are anything but formulaic. Many are a mix of apartments, suites, double-doubles, and single occupant rooms. These kinds of facilities make for interesting architectural arrangements of space and complex interior floor plans that don't always have intuitively obvious exit routes. Cooking facilities, both in individual rooms and communal kitchens, as well as food service facilities, are becoming increasingly more common if not the norm. A trend toward "Living and Learning" has created buildings that have increasing amounts of assembly space within them. Classrooms, recreation facilities, and movies/concert/dance venues are all becoming common place in newer facilities. That said, there are still buildings that are akin to the old-style dormitory, such as summer camps, hostels, homeless shelters, bunkhouses, and barracks, and the code should have a classification to recognize those facilities too. So our proposal recognizes dormitories as a potential hotel occupancy as well and judges the difference the same way as all other occupancies are judged, by the transient or non transient nature of the occupants. The proposal also specifically designates that non transient student residence facilities are an apartment occupancy, removing the necessity for the "dormitory" to both describe the defining features and give all-encompassing examples. Public Input Response: Even if the SAF-RES technical committee were to develop new occupancy chapters for student residential facilities, there will remain a need for the definition of the word dormitory for use with the sleeping venues in military housing, low-risk detention facilities, employee work camps, and children's summer camps, for example. _______________________________________________________________________________________________ 101 478 SAF-FUN (6.1.14.1.2) _______________________________________________________________________________________________ Submitter: James K. Lathrop, Koffel Associates, Inc. Recommendation: Revise to read: 6.1.14.1.24.1 Where exit access from an occupancy traverses another occupancy, the multiple occupancy shall be treated as a mixed occupancy. Substantiation: This paragraph is frequently being overlooked. By moving it to the beginning of the "Separated Occupancies" provisions the user is informed that the arrangement cannot be done as a separated occupancy before reading all the rest of the requirements. Public Input Response: The provision is general and needs to be retained in 6.1.14.1 as part of the roadmap the user consults before branching off to the mixed occupancies or separated occupancies requirements. The committee is adding a reference within 6.1.14.4 to remind the user to see 6.1.14.1.2. Printed on 9/13/2012 11 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 76 SAF-FUN (6.1.14.1.3) _______________________________________________________________________________________________ Submitter: Bill Galloway, Southern Regional Fire Code Development Committee Recommendation: Revise to read: 6.1.14.1.3* Where incidental to another occupancy, areas used as follows shall be permitted to be considered part of the predominant occupancy and shall be subject to the provisions of the Code that apply to the predominant occupancy: (1) Mercantile, business, industrial, or storage use when all of the following are observed: a. Incidental use area shall not exceed 10% of building story in which it is located. b. Incidental use area shall not exceed 3000 sq.ft. c. Incidental use occupant load shall not exceed 50 occupants, (2)*Nonresidential use with an occupant load fewer than that established by Section 6.1 for the occupancy threshold. Substantiation: There is no definition of ‘incidental’ in the Code as it is used in various places with various different meanings. Limiting the meaning of ‘incidental’ within this code section will clarify intent. Public Input Response: History says that determination of "incidental" uses has not been a problem. The submitter provided no substantiation that a problem exists. _______________________________________________________________________________________________ 101 139 SAF-FUN (6.1.14.3.2) _______________________________________________________________________________________________ Submitter: Richard M. DiMisa, Code Consultants, Inc. Recommendation: Revise section to read: 6.1.14.3.2 The building shall comply with the most restrictive requirements of the occupancies involved, unless separate safeguards are approved for features of fire protection; building service and fire protection equipment; and interior finish, contents, and furnishings. Substantiation: The term "separate safeguards" is not defined by the Life Safety Code which allows for various interpretations by the AHJ and an inconsistent application of the Life Safety Code. Public Input Response: The vagueness is intentional and part of the original goal as drafted by the technical committee. The submitter's list is incomplete, showing that a category-specific list will not work. The annex provides an adequate example of a means of egress-related separate safeguard, something the submitter's text would not permit. _______________________________________________________________________________________________ 101 136 SAF-FUN (6.1.14.3.3 (New) ) _______________________________________________________________________________________________ Submitter: Richard M. DiMisa, Code Consultants, Inc. Recommendation: Add a new section to read as follows: 6.1.14.3.3 The shared means of egress must meet the most restrictive egress provisions of those occupancies served by the shared means of egress. Substantiation: This new section is proposed to clarify the application of the mixed occupancy provisions. The proposed change protects the occupants of the building by applying the most restrictrive requirements for features that could affect the mixed occupancy to the entire mixed occupancy while requirements that can be applied to an individual occupancy without impacting the safety of the mixed occupancy are applied to the individual occupancy. Public Input Response: The proposed text confuses rather than clarifies. What about fire alarm systems? Sprinklers? The intended principle is currently correctly stated. Printed on 9/13/2012 12 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 477 SAF-FUN (6.1.14.4.4 and A.6.1.14.4.4 (New) ) _______________________________________________________________________________________________ Submitter: James K. Lathrop, Koffel Associates, Inc. Recommendation: Add new sections to read: 6.1.14.4.4 Each separated portion of the building shall comply with the requirements for the occupancy therein. A.6.1.14.4.4 Where a provision of the Code applies to a building, that provision applies to the entire whether treated as a separated occupancy or not. Substantiation: Section 6.1.14.4 provides all the information on separated occupancies except how one complies with the Code when using separated occupancies. Public Input Response: See FR119. _______________________________________________________________________________________________ 101 352 SAF-FUN (6.1.14.4.5 and A.6.1.14.4.5 (New) ) _______________________________________________________________________________________________ Submitter: Joshua Elvove, U.S. General Services Administration Recommendation: Add a new section to read: 6.1.14.4.5* Where permitted by Chapters 11-43, an atrium meeting the requirements of 8.6.7 shall be permitted to serve as an occupancy separation, provided the atrium separation from all adjacent areas meets both of the following requirements: 6.1.14.4.5.1 The atrium shall be separated from adjacent areas by construction that limits the transfer of smoke. 6.1.14.4.5.2 Doors separating the atrium from adjacent areas shall be equipped with latching hardware and be self or automatic closing. A.6.1.14.4.5 In order to take advantage of this design option, the atrium must be enclosed on all sides on all levels. The occupancy classification for the atrium should be based upon the use of the atrium. The boundary for individual occpancies that abut the atrium would be along the wall where those occupancies are physically separated from the atrium. Substantiation: The intent of this public input is to provide designers the option of considering an atrium as part of an occupancy separation, where two or more occupancies permit this type of configuration, provided the atrium meets all the provisions of 8.6.7 and is physically separated from adjacent spaces in order to delimit the atrium from adjacent spaces. The latter provision increases the level of safety for atriums as compared to what is currently permitted by 8.6.7 when atriums serve as equivalent to 2 vertical opening protection. The proposed language has been revised from what was submitted during the 2012 cycle, based upon concerns raised by the FUN TC during ROC. Requiring the atrium to be physically separated from adajcent spaces removes the concern where occupancies converage at a single point along the atirum and provides a physical location for determining unique occupancy requirements and for calculating dimensional measurements (e.g., smoke compartment size and travel distance). Requiring atrium separation doors be equipped with positive latching hardware and self or automatic closing doors ensures the atrium smoke management system performs as intended. The annex note provides guidance on what the atrium occupancy classification should be and where occupancies begins and end. Note: this is meant to be the minimum requirement. I'm also submitting companion public inputs to the assembly, educational, day care, health care, ambulatory health care, and business occupancy chapters for their respective consideration stating that "An atrium separation meeting the requirements of 6.1.14.4.5 shall be permitted to serve as an occupancy separation". Hence, there needs to be a place holder in Chapter 6 for them to refer to. Public Input Response: See FR122 which addresses using atrium walls as part of the separation that creates separated occupancies on a story-by-story basis. The submitter has not substantiated how an atrium can be used to create side-by-side separated occupancies as the atrium provisions are related to the protection of vertical openings. Printed on 9/13/2012 13 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 81 SAF-FUN (11.8.3 (New) ) _______________________________________________________________________________________________ Submitter: Bill Galloway, Southern Regional Fire Code Development Committee Recommendation: Add a new section to read: 11.8.3 All new vertical exit stair enclosures shall be smokeproof enclosures in accordance with 7.2.3 . Substantiation: Smoke proof enclosures for exit stairways are currently required life safety features for high rise buildings in NFPA 5000 (33.3.3.1) as well as the IBC. Inclusion of this requirement in NFPA 101 for high rise buildings will bring NFPA 101 into agreement with requirements in associated standards. Public Input Response: Such change would need a technical reason other than a reference to correlation between NFPA 5000 and NFPA 101. The provision would have financial impact of buildings subject to NFPA 101 but not NFPA 5000 that has not been justified. _______________________________________________________________________________________________ 101 164 SAF-FUN (41.1 (New) ) _______________________________________________________________________________________________ Submitter: Joe Scibetta, BuildingReports Recommendation: Add new text to read as follows: Chapter 41 (New) Animal Housing Facilities. 41.1 Animal housing facilities shall comply with NFPA 150, Standard on Fire and Life Safety in Animal Housing Facilities. Substantiation: With the 2012 edition of NFPA 101, the last remaining references to animals were removed from the definition of storage occupancies in Chapters 3 and 42. Removing animals from the list of storage materials in storage occupancies was a good decision and is in keeping with one of the fundamental principles of NFPA 150, namely that "animals are sentient beings with a value greater than that of simple property". (NFPA 150 A.1 .1.1). However, with the removal of those references from the 2012 edition, animals are no longer addressed in the Life Safety Code. As the title of NFPA 150 indicates, protection of property and life are both addressed in the Animal Housing standard. Therefore, following the pattern of NFPA 1, Chapter 35, which is dedicated to Animal Housing Facilities and points the reader to NFPA 150 for further information on protection of property, this proposal calls for the current Chapter 41 of NFPA 101, now in reserve, to be likewise dedicated to Animal Housing Facilities and point the reader of the Code to NFPA 150 for further information regarding life safety in those types of occupancies. Since there are life safety requirements unique to NFPA 150, the Life Safety Code should point the reader to that document for the life safety requirements specific to animal housing facilities. Animal housing facilities are a unique occupancy type and now that they have been rightfully deleted from Storage Occupancies, they do not fall under any of the other current occupancy types in NFPA 101. Public Input Response: The submitter asks for something outside the scope of NFPA 101. NFPA 101 intends to protect human life. Animals safety need not be mentioned in NFPA 101. Humans, such as workers, in animal housing facilities are adequately protected by the requirements of NFPA 101. Printed on 9/13/2012 14 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 91 SAF-FUN (43.7.1) _______________________________________________________________________________________________ Submitter: Bill Galloway, Southern Regional Fire Code Development Committee Recommendation: Revise text as follows: 43.7.1 Change of Use. 43.7.1.1 A change of use that does not involve a change of occupancy classification shall comply with the requirements applicable to the new use in accordance with the applicable existing occupancy chapter, unless the change of use creates a hazardous contents area as addressed in 43.7.1.2 or the change of use is to a residential occupancy where the occupants are primarily of a transient nature as addressed by 43.7.1.3. 43.7.1.2 . . . .No change. 43.7.1.3 A change of use that does not create a change of occupancy classification but that involves a change of use to a residential occupancy where the occupants are primarily of a transient nature shall comply with the requires for automatic sprinkler, detection and alarm systems applicable to new construction for the occupancy created by the change (see Chapters 26 and 28.) Substantiation: The current provisions of 43.7.1 and Table 43.7.3 don’t address the added hazard created when a non-transient residential occupancy undergoes a change of use to a transient residential occupancy. (I.e. Apartment to Hotel or lodging or rooming house) When this type of change of use occurs, the introduction of transient occupants creates an additional hazard that is equivalent to a change of occupancy classification going from low hazard to a higher hazard as defined by table 43.7.3. This code change will address this added hazard by ensuring that automatic sprinklers, detection and alarms are provided to protect the transient occupants. The submitter is asked to see FR150 that revises annex text A.43.7.3 as that change might address some of his concern. Public Input Response: There is no indication from the provisions applicable to residential occupancies that transient nature needs to be treated differently from non-transiency of occupants for any given occupancy type. If there were, Chapter 26 for lodging/rooming, would have specific criteria for transient occupants and other criteria for non-transient occupants. _______________________________________________________________________________________________ 101 492 SAF-FUN (43.7.1.2(2)) _______________________________________________________________________________________________ Submitter: Lennon Peake, Koffel Associates, Inc. Recommendation: Revise to read: (2) For existing health care occupancies protected throughout by an approved, supervised automatic sprinkler system 2 2 in accordance with 9.7.1.1(1), where a change in use of a room or space not exceeding 250 ft (23.2 m ) results in a room or space that is described by 19.3.2.1.5(7), the requirements for new construction shall not apply, provided that the enclosure meets the requirements of 19.3.2.1.2 through and 19.3.2.1.43. Substantiation: The current language permits a room or space in a sprinkler protected health care occupancy to be converted to a storage room without meeting the requirements for new construction for a 1-hour fire-resistance rated enclosure. Currently, Section 43.7.1.2(2) requires the room to be separated from other spaces by a smoke partition (Section 19.3.2.1.2), doors must be self-closing or automatic-closing (Section 19.3.2.1.3), and doors in rated enclosures are permitted to have nonrated, factory-, or field applied protective plates extending not more than 48 in. (1220 mm) above the bottom of the door (Section 19.3.2.1.4). Section 19.3.2.1.2 permits the room to be separated from other spaces by a non fire-rated smoke partition, therefore the requirements of Section 19.3.2.1.4 for doors in rated enclosures does not apply. The height of protective plates is not limited on non fire protection rated hazardous area doors. The substantiation for the language entering the code via the 2011 ROP/ROC stated the storage room would be enclosed in smoke resisting walls and doors provided with self of automatic closing hardware, however no mention was made to the height of the protective plate. Public Input Response: See FR123. Printed on 9/13/2012 15 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 92 SAF-FUN (43.7.2.1(3) (New) ) _______________________________________________________________________________________________ Submitter: Bill Galloway, Southern Regional Fire Code Development Committee Recommendation: Add a new 43.7.2.1 (3) as follows: (3) Requirement for automatic sprinkler, detection and alarm requirements applicable to new construction for residential occupancies created by the change. (See Chapters 24, 26, 28 and 30.) Substantiation: Table 43.7.3 and the provisions of 43.7.2.1 do not currently provide for fire sprinkler and alarm applicable to new construction when a change of occupancy occurs from an assembly, day car, ambulatory health care, mercantile, business, industrial or storage to a residential occupancy. These types of changes of occupancy create a significantly increased risk to the occupants of the residential occupancies as the protection provisions for sprinklers and alarms are not required as if it was new construction. The SRFCD believes that it is very reasonable to mandate this basic level of sprinkler and alarm protection when a change of use is made from a non-residential occupancy to a residential occupancy. The submitter is asked to see FR150 that revises annex text A.43.7.3 as that change might address some of his concern. Public Input Response: The change is not needed as the subject is adequately covered by 43.7.2.1(2). The submitter's first statement is incorrect. Where a change of occupancy from assembly occupancy, for example, to any of the residential occupancies, such change occurs within the same hazard category and the alarm and sprinkler provisions applicable to new construction apply. So, that which the submitter intends is already part of the Code requirements. _______________________________________________________________________________________________ 101 455 SAF-FUN (43.10.5.4(2)) _______________________________________________________________________________________________ Submitter: Robert J. Davidson, Davidson Code Concepts, LLC Recommendation: Revise to read: (2) Fixed An existing installation of fixed wired glass set in a steel frame or other approved glazing is present on one side of the transom. Substantiation: As currently worded a new installation of wired glass in steel frames could be installed when the intent is to allow the continued use of an existing installation of wired glass. Calling out one type of product for use is proprietary and wired glass in and of itself is no longer considered an acceptable product for new installation unless tested and listed as a fire-rated glazing material. The proposed change will allow the continued use of an existing installation of wired glass in steel frames. The change will also provide for correlation with the language found at NFPA 101 Sections 7.2.6.2 , 8.3.3.9, 8.3.3.11(1) and 13.3.1(5)(c) where the language provides for continued use of "existing" installations of wired glass. Public Input Response: The committee intends to continue to permit wired glass to be installed in this rare case of a historic building undergoing a change of occupancy. Note that glazing in transoms is typically located above the impact zone for which there is concern relative to occupant injury involving wired glass. Printed on 9/13/2012 16 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 386 SAF-FUN (A.1.1.5) _______________________________________________________________________________________________ Submitter: Wayne D. Holmes, HSB Professional Loss Control Recommendation: Revise to read: A.1.1.5 Life safety in buildings includes more than safety from fire. Although fire safety has been the long-standing focus of NFPA 101, its widely known title, Life Safety Code, and its technical requirements respond to a wider range of concerns, including, for example, crowd safety. While the Life Safety Code addresses considerations other than fire, it specifically does not address safety for occupants or emergency responders where hazardous materials might be present. The applicable buidling code, fire code, or other applicable codes may have more stringent means of egress requirements or protection level requirements where hazardous materials might be present in amounts exceeding maximum allowable quantities. Users of the Life Safety Code are advised to consult NFPA 5000, Building Construction Code, NFPA 1, Fire Code, NFPA 400, Hazardous Materials Code, or other applicable codes for for requirements that might be more stringent than those of the Life Safety Code. Substantiation: The Life Safety Code addresses Hazard of Contents, Means of Egress, and protection requirements only in terns of fire properties. Other codes, such as NFPA 1, NFPA 400, NFPA 5000, and the UBC define High Hazard Occupancies in terms of amounts of hazardous materials present. Because of the hazard to occupants in the event of release of hazardous materials, the other codes have much more restictive limits on allowable travel distances than does the Life Safety Codes. In those situations, buildings which meet the allowances of the Life Safety Code might not comply with the other codes. Some Athorities Having Juisdiction assume that the Life Safety Code is all-encpmassing.and do not recognize the difference between the Life Safety Code and other codes. As a result they specify that buildings with Means of Egress that complies with the Life Safety Code can be considered to be in compliance with building code Means of Egress. For example, the U. S. Department of Energy (DOE) life safety criteria states that for DOE buildings "compliance with the Life Safety is considered to satisfy the exit requirements of the applicable building code." As a result, facilities that contain significant amounts of hazardous materials might not be provided with means of egress for occupants commensurate with the level of hazard present while still being in compliance with the Life Safet Code. The purpose of this proposed revision to A-1.1.5 is to alert readers to the fact that the Life Safety Code does not address all hazards of contents. The provisions of the Life Safety Code might not provide an adequate level of safety where hazardous materilals are present in significant amounts. Readers are advised to consult other codes which may have more stringent means of egress and protection requirements. Public Input Response: The text as proposed by the submitter is confusing. Why has the submitter singled out hazardous materials? The committee believes the subject does not warrant such attention. NFPA 101 can be adequately enforced without reliance on the proposed text. In the substantiation, the first statement is incorrect. The proposed text is inconsistent with 4.1.2 and A.4.1.2. Printed on 9/13/2012 17 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 490 SAF-FUN (A.1.1.5) _______________________________________________________________________________________________ Submitter: Norman E. Groner, John Jay College of Criminal Justice Recommendation: Revise to read: A.1.1.5 Life safety in buildings includes more than safety from fire. Although fire safety has been the long-standing focus of NFPA 101, its widely known title, Life Safety Code, and its technical requirements respond to a wider range of concerns, including, for example, crowd safety. Code requirements that contribute to the safe movement of people during fire emergencies may also assist in responding to many other hazards that require decision about where people can be most safely located. Life Safety Code requirements that contribute to limiting the spread of smoke also have the potential to limit exposures to many airborne toxic and biological hazards. Substantiation: The added text clarifies the annex by providing examples where code provisions may help safeguard building occupants threatened by non-fire "comparable" hazards associated to section 1.1.5* Considerations Not Related to Fire. Public Input Response: See FR124 relative to the submitter's proposed first sentence. The second proposed sentence is troublesome as there is no assurance of expertise relative to toxicity and biohazard. _______________________________________________________________________________________________ 101 3a SAF-FUN (A.3.3.8.1) _______________________________________________________________________________________________ Submitter: Kenneth E. Bush, Maryland State Fire Marshals Office Recommendation: Add a new sentence to Paragraph A.3.3.81 as follows: It is not the intent of this paragraph to require a fire protection rating for exit doors which discharge directly to the exterior of the building. Substantiation: These changes are intended to clarify the intent that exterior doors serving as exits are not required to have a fire protection rating because they are serving as required exits. Where the door opens to the exterior of the building, the protected way of travel to the exit discharge involves only travel through the door opening, and it is not intended to require special separation from other parts of the building. Specific reference was made in the Annex to limit the intent of this paragraph for designated exit purposes only, and does not preclude the requirements for fire protection ratings on doors where other conditions, such as exposures to means of egress or other parts of the building beside or above the door opening, may require the installation of a fire-rated opening protective by other code provisions. Public Input Response: The committee notes that the proposed annex was intended to be tied to the definition of Exit in 3.3.81. Definitions don't "require" anything, so the text, as proposed, is not appropriate. _______________________________________________________________________________________________ 101 275a SAF-FUN (A.3.3.31.1 Fire Barrier) _______________________________________________________________________________________________ Submitter: Joseph H. Versteeg, Versteeg Associates Recommendation: Revise text to read as follows: A.3.3.31.1 A fire barrier might be vertically or horizontally aligned, such as a wall or floor assembly. Although the continuity of a fire barrier will often limit the transfer of smoke. it must not be confused with either a smoke barrier or smoke partition. Substantiation: For several editions this section has referenced 7.2.1.4(3) which does not exist. The correct reference is as shown in the proposed change. Fire barriers are not tested for the passage of smoke or products of combustion through the assembly and by including this phrase; it adds to the confusion that fire barriers are smoke barriers. Public Input Response: See FR125. Printed on 9/13/2012 18 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 502 SAF-FUN (A.3.3.88.2) _______________________________________________________________________________________________ Submitter: John A. Rickard, Katus, LLC Recommendation: Revise to read: A.3.3.88.2 Limited Care Facility. Limited care facilities and residential board and care occupancies both provide care to people with physical and mental limitations. However, the goals and programs of the two types of occupancies differ greatly. The requirements in this Code for limited care facilities are based on the assumption that these are medical facilities, that they provide medical care and treatment, and that the patients are not trained to respond to the fire alarm; that is, the patients do not participate in fire drills but, rather, await rescue. (See Section 18.7.) The requirements for residential board and care occupancies are based on the assumption that the residents are provided with personal care and activities that foster continued independence, that the residents are encouraged and taught to overcome their limitations, and that most residents, including all residents in prompt and slow homes, are trained to respond to fire drills to the extent they are able. Residents are required to participate in fire drills. (See Section 32.7.) Persons with Alzheimer's and related illnesses may be located in a nursing home, limited care facility, or board and care facility. For such persons, it is the level of care provided, not the medical diagnosis, that matters for the purposes of determining whether the facility should meet the requirements for limited care. Where personal care is provided but medical or custodial care is not, the limited care definition does not typically apply. It is the intent of this definition that it not apply to persons not receiving medical or custodial care, provided they are able to assist in their own evacuation, regardless of their medical diagnosis. Substantiation: There has been a great deal of disagreement across the country as to whether facilities serving persons with Alzheimer's and related dementia-type illnesses should be considered limited care or residential board and care. Although prior editions of NFPA 101 relied on evacuation capability to determine this, the current means is the type of care provided. This removes the burden of determining when a resident's evacuation capability has changed from the authority having jurisdiction. Coincidental with this change, the requirements for large board and care facilities were enhanced to accommodate residents for whom evacuation is difficult but who live in facilities that provide personal care only. The added language merely clarifies the current intent, which is that the level of care provided be the basis for determining the facility requirements, not the medical diagnosis. Public Input Response: See FR126. Printed on 9/13/2012 19 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 93 SAF-FUN (A.3.3.188.1) _______________________________________________________________________________________________ Submitter: Bill Galloway, Southern Regional Fire Code Development Committee Recommendation: Revise text: A.3.3.188.1 Ambulatory Health Care Occupancy. It is not the intent that occupants be considered to be incapable of self preservation just because they are in a wheelchair or use assistive walking devices, such as a cane, a walker, or crutches. Rather, it is the intent to address emergency care centers that receive patients who have been rendered incapable of self-preservation due to the emergency, such as being rendered unconscious as a result of an accident or being unable to move due to sudden illness. It is not the intent that the term ‘anesthesia’ be limited to ‘general anesthesia’. Procedures using ‘regional’ and ‘dissociative’ anesthesia may also render a patient incapable of self-preservation. Substantiation: Dental offices administer nitrous oxide (a dissociative anesthesia) more frequently than general anesthesia to create a "conscious sedation". The effects of nitrous oxide can take as long as 5 minutes to dissipate after the gas is stopped. Side effects such as confusion, sleepiness, hypnosis, forgetfulness, and hallucinations are typical. Although the patient may be conscious during treatment, the sedation created by the administration of nitrous oxide makes that patient "incapable of self-preservation", and assistance from others in a time of emergency happening during treatment may be necessary. Public Input Response: The submitter's proposed first sentence is addressed by a separate first revision. The proposed second sentence would confuse relative to NFPA 99's four levels of anesthesia. _______________________________________________________________________________________________ 101 385 SAF-FUN (A.3.3.188.8.2) _______________________________________________________________________________________________ Submitter: Wayne D. Holmes, HSB Professional Loss Control Recommendation: Add text: A.3.3.188.8.2 High Hazard Industrial Occupancy. A high hazard industrial occupancy includes occupancies where gasoline and other flammable liquids are handled, used, or stored under such conditions that involve possible release of flammable vapors; where grain dust, wood flour or plastic dust, aluminum or magnesium dust, or other explosive dusts are produced; where hazardous chemicals or explosives are manufactured, stored, or handled; where materials are processed or handled under conditions that might produce flammable flyings; and where other situations of similar hazard exist. Chapters 40 and 42 include detailed provisions on high hazard industrial and storage occupancies. Substantiation: The High Hazard Industrial Occupancy is unique among all occupancies in the Life Safety Code. While other occupancy chapters address Hazard of Contents, only Chapter 40 includes a High Hazard Occupancy. In addition to addressing the Hazard of Content, the High Hazard Industrial Occupancy is characterized by High Hazard Materials and High Hazard Operations. Some code users may erronously determine industrial occupancy sub-classifications based solely on Hazard of Contents. The intent of the proposed additional text in A.3.3.188.8 is to alert users of the code that High Hazard Industrial Occupancies are characterised by high hazard materials or high hazard operations in addition to Hazard of Contents. Public Input Response: The text received by the committee was all text that is currently in NFPA 101. The submitter's substantiation refers to "proposed additional text" but the committee did not receive such text. Printed on 9/13/2012 20 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 7a SAF-FUN (A.4.5.1 and Table A.4.5.1 (New) ) _______________________________________________________________________________________________ Submitter: M. van Zeijl, European Fire Protection Consultants B.V. Recommendation: Add new text to read as follows: A.4.5.1 For all design features, an availability evaluation should be performed. This evaluation should review the required availability in relation to ineffectiveness due to malfunction and (planned) maintenance. Below table shows some typical evaluation examples. ******Insert Table A.4.5.1 Here****** Substantiation: The current wording leaves much space for interpretation and discussion about the requirement for multiple safeguards. To the opinion of this proposal author, the additional text gives some more direction. By suggesting the availability evaluation, designers are requested to consider malfunction and maintenance issues, and as such provide sufficient provisions. Public Input Response: The provision of 4.5.1 represents a fundamental requirement that imposes no prescriptive requirement on the Code user. Rather, the text serves as the basis behind specific requirements found elsewhere in the Code. The technical committees keep the fundamental requirements in mind as they craft new provisions or revise existing ones. It is the committee's intent that 4.5.1 remain general in nature. The terms introduced by the submitter are not defined. No basis is provided for the rankings introduced. _______________________________________________________________________________________________ 101 112 SAF-FUN (A.4.6.15 (New) ) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Add new text to read as follows: A.4.6.15 A material complying with ASTM E2786 needs to be tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Burning Materials, and exhibit a flame spread index of 25 or less, show no evidence of significant progressive combustion when the test is continued for an additional 20-minute period (with a total test duration of 30 minutes) and have a flame front that does not progress more than 10.5 ft (3.2 m) beyond the centerline of the burners at any time during the test. Substantiation: ASTM has now issued a test method, ASTM E2768, which contains the three requirements discussed in this section, namely that a product be tested in accordance with ASTM E84 or UL 723, and exhibit a flame spread index of 25 or less, show no evidence of significant progressive combustion when the test is continued for 30 minutes (i.e. an additional 20-minute period over the standard ASTM E84 duration of 10 minutes) and that the flame front not 1 progress more than 10 /2 feet (3200 mm) beyond the centerline of the burners at any time during the test. This change replaces the lengthy information about requirements with a reference to the standard. The NFPA Manual of Style does not allow requirements in definitions. Therefore this change places the requirements into a new section in Chapter 4, immediately following the requirements for noncombustible material and limited combustible material. Public Input Response: The proposed text is not consistent with the actions taken on the subject by the BLD/BLC and BLD/SCM technical committees for NFPA 5000. A new definition for FRTW, from NFPA 703, will be used in Chapter 3. Reference to ASTM E 2768 is not needed, so explanatory annex text on the test standard also is not needed. Printed on 9/13/2012 21 Maintenance or Repair Shutdown Resulting Redundancy Low Not required Low Not required High (start failure) Not relevant 2nd pump High (power grid failure) Not relevant Diesel engine Low Yes (outside opening hours) Not required Low Yes (inside opening hours) Yes via bypass Underground main Low Yes (longer period) Yes, via sectionalized ring Emergency lighting High (battery failure) Not relevant Yes. via projection Item Description Fire separation Fire door Malfunction Expectance Low (if maintained properly) Low (if maintained properly) Fire water pump Alarm check valve ROP / A2014 / NFPA 101/ Log # 7 / Table A.4.5.1 /Rec Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 9 SAF-FUN (A.4.8.2.1(3)) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise the last paragraph to read as follows: For further guidance, see the following publications: (1) SFPE Engineering Guide to Human Behavior in Fire, which provides information on occupant characteristics, response to fire cues, decision making in fire situations, and methods for predicting evacuation times. (2) (existing item #1) (3) (existing item #2) (4) (3) SFPE Handbook of Fire Protection Engineering, Section 3, Chapters 11-13, which provides an overview of some of the research on methods of evacuation, and methods for predicting evacuation times. Substantiation: The SFPE Engineering Guide to Human Behavior in Fire describes all of the factors that contribute to the evacuations decisions that people might make and the time that it would take for them to evacuate once they decide to do so. As such, it should be included in this list of referenced publications. There are actually three chapters in the SFPE Handbook that are relevant to evacuation plans, so item (3) is proposed to be revised to reference the two that are not presently included. Public Input Response: Via a separate first revision, the referenced documents, listed at the very end of the lengthy annex text, are being revised. Printed on 9/13/2012 22 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 469 SAF-FUN (A.4.8.2.1(3)) _______________________________________________________________________________________________ Submitter: James R. Quiter, Arup Recommendation: ***INSERT Table A.4.8.2.1(3) HERE*** Substantiation: The table entry for “No Evacuation” is not accurate and is more appropriately and commonly referred to as “Shelter in Place”. The table should be updated to reflect the commonly used terminology in the field. This public input was prepared by the NFPA High Rise Building Safety Advisory Committee. The HRB-SAC members are: James Quiter (Chair), Arup Geoff Craighead, Universal Protection Service Jon Magnusson, National Council of Structural Engineers Associations John Miller, Los Angeles City Fire Department Jack Murphy, Fire Safety Directors Association of Greater New York Steven Nilles, Council on Tall Buildings and Urban Habitat Jake Pauls, American Public Health Association Jim Shea, Tishman Speyer William Stewart, Metropolitan Fire Chiefs-IAFC Sally Regenhard, The Skyscraper Safety Campaign Charles Jennings (Alternate to Regenhard), The Skyscraper Safety Campaign Kristin Bigda, NFPA Staff HRB-SAC is an advisory committee established by the NFPA Standards Council to advise the association, and especially the association’s technical committees, on all safety issues related to high rise buildings. HRBSAC Ballot Results for This Comment: 10 Eligible to vote 9 Affirmative Votes (C. Jennings for S. Regenhard) 1 Not Returned (S. Nilles) Public Input Response: See separate first revision where Table A.4.8.2.1(3) is being revised. Printed on 9/13/2012 23 Table A.4.8.2.1(3) Occupant Evacuation Strategies Managed Sequence Unmanaged Sequence Shelter in place (Remain-in-place) No Evacuation No-movement – Remain in place Shelter-In-Place upon direction No-movement – Remain in place Shelter-In-Place per prior instruction Partial Evacuation Managed or controlled partial evacuation Unmanaged or uncontrolled partial evacuation Total Evacuation 101 Log #469 Rec PI #423 In-building relocation on same floor In-building relocation to different floors Occupants of some floors leave building Managed or controlled total evacuation Unmanaged or uncontrolled total evacuation Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 468 SAF-FUN (A.4.8.2.3 (New) ) _______________________________________________________________________________________________ Submitter: James R. Quiter, Arup Recommendation: Add a new section to read: A.4.8.2.3 Emergency action plans are a critical component of assuring life safety in buildings. Life safety is the result of an interaction of technical and social systems within the building and in the community. Gathering information to evaluate the performance and effectiveness of emergency action plans is important for verifying system performance and as a basis for improvement. Such reports should be retained by the building and used to inform the process for revision of the building emergency action plan. Following any drill or actual emergency or reported emergency occurring in the building, an after action report should be prepared by building management to document the function of the building's life safety hardware, procedures, and occupant emergency organization. For ordinary drills and reported emergencies, a short form should be completed. The purpose of this short form is to identify areas of success and areas for improvement. For actual emergencies in the building, where there is major occupant movement, damage, or casualties, a long form should be used. The long form includes specific questions concerning the event, as well as performance of life safety systems. It also identifies improvements in areas such as training, maintenance, interaction with local emergency response organizations, or occupant management. The reports from these significant events shall be shared with the local emergency response organization. Substantiation: Currently, the Code does not contain adequate guidance on after action reporting. As the proposed language states, emergency action plans are a critical component for assuring life safety in buildings. A lot of time, effort, and coordination is required to put together an emergency action plan that is specific to the building. Emergency action plans vary from building to building and address the specific characteristics and hazards of that particular building. Thus, it is important to have means in place to review these plans after emergencies and ensure they are working effectively and are updated where necessary. This public input was prepared by the NFPA High Rise Building Safety Advisory Committee. The HRB-SAC members are: James Quiter (Chair), Arup Geoff Craighead, Universal Protection Service Jon Magnusson, National Council of Structural Engineers Associations John Miller, Los Angeles City Fire Department Jack Murphy, Fire Safety Directors Association of Greater New York Steven Nilles, Council on Tall Buildings and Urban Habitat Jake Pauls, American Public Health Association Jim Shea, Tishman Speyer William Stewart, Metropolitan Fire Chiefs-IAFC Sally Regenhard, The Skyscraper Safety Campaign Charles Jennings (Alternate to Regenhard), The Skyscraper Safety Campaign Kristin Bigda, NFPA Staff HRB-SAC is an advisory committee established by the NFPA Standards Council to advise the association, and especially the association’s technical committees, on all safety issues related to high rise buildings. HRBSAC Ballot Results for This Comment: 10 Eligible to vote 9 Affirmative Votes (C. Jennings for S. Regenhard) 1 Not Returned (S. Nilles) Public Input Response: See FR129. Printed on 9/13/2012 24 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 10 SAF-FUN (A.5.1.1) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: The performance option of this Code establishes acceptable levels of risk to occupants of buildings and structures as addressed in Section 1.1. 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 are needed to develop solutions that meet the provisions of Chapter 5. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings provides a framework for these assessments. Other useful references include the Australian Fire Engineering Guidelines and the British Standard Firesafety Engineering in Buildings. Substantiation: Update reference to current edition (the title was shortened in the second edition.) Public Input Response: See FR131. _______________________________________________________________________________________________ 101 11 SAF-FUN (A.5.1.6) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise the first sentence to read as follows: For guidance on reviewing performance-based designs, see the SFPE Enforcer's Code Official's Guide to Performance-Based Design Review. Substantiation: Provide the correct title. This is an editorial change. Public Input Response: See FR132. _______________________________________________________________________________________________ 101 12 SAF-FUN (A.5.2.2) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise the first two paragraphs under "Methods 1" as follows: Method 1. The design team can set detailed performance criteria that ensure that occupants are not incapacitated by fire effects. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings describes a process of establishing tenability limits. The guide references D. A. Purser, “Assessment of Hazards to Occupants from Smoke, Toxic Gasses, and Heat Toxicity Assessment of Combustion Products,” Chapter 2/6, SFPE Handbook of Fire Protection Engineering, which describes a fractional effective dose (FED) calculation approach, which is also contained in NFPA 269, Standard Test Method for Developing Toxic Potency Data for Use in Fire Hazard Modeling. FED addresses the effects of carbon monoxide, hydrogen cyanide, carbon dioxide, hydrogen chloride, hydrogen bromide, and anoxia. It is possible to use the test data, combined with laboratory experience, to estimate the FED value that leads to the survival of virtually all people. This value is about 0.8. Substantiation: Update references to the current edition. Public Input Response: See FR133. Printed on 9/13/2012 25 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 13 SAF-FUN (A.5.5) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: 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 need to 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 of Buildings outlines a process and identifies tools and references that can be used at each step of this process. Substantiation: Update reference to the current edition. Public Input Response: See FR134. _______________________________________________________________________________________________ 101 14 SAF-FUN (A.5.6) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise section on "validation" to read as follows: Verification and Validation. Models undergo limited validation. Most can be considered demonstrated only for the experimental results they were based on or the limited set of scenarios to which the model developers compared the model’s output, or a combination of both. Models should undergo verification and validation to ensure that they are appropriate for their intended use. "Verification" is a check of the math used in the models. "Validation" is a check of the physics used in the model. The SFPE Guidelines for Substantiating a Fire Model for a Given Application provides a process for verifying and validating models. The Society of Fire Protection Engineers has a task group that independently evaluates computer models. In January 1998, they finished their first evaluation and had chosen a second model for evaluation. Until more models can be independently evaluated, the model user has to rely on the available documentation and previous experience for guidance regarding the appropriate use of a given model. (Remainder of section unchanged) Substantiation: Modern methods for evaluating fire models recognize that there are two aspects of model evaluation: verification and validation. Verification ensures that the model is working as designed; that the equations are being properly solved. It essentially is a check of the mathematics. Validation is a check of the physics – are the equations an appropriate description of the fire scenario? The revised text would make reference to the SFPE Guidelines for Substantiating a Fire Model for a Given Application, which were written as a method to provide confidence to model users and AHJs that models are being used appropriately. The text regarding SFPE's computer model evaluation task group was deleted because the task group was disbanded. Public Input Response: See FR135. _______________________________________________________________________________________________ 101 19 SAF-FUN (A.5.6) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise first paragraph to read as follows: The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings outlines a process for evaluating whether trial designs meet the performance criteria during the design fire scenarios. Additional information on reviewing the evaluation of a performance-based design can be found in the SFPE Enforcer’s Code Official's Guide to Performance-Based Design Review. Substantiation: (1) Update reference to the current edition and (2) provide correct title of the document. Public Input Response: See FR135. Printed on 9/13/2012 26 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 15 SAF-FUN (A.5.6.3.3) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: A.5.6.3.3 Procedures used to develop required input data need to preserve the intended conservatism of all scenarios and assumptions. Conservatism is only one means to address the uncertainty inherent in calculations and does not eliminate the need to consider safety factors, sensitivity analysis, and other methods of dealing with uncertainty. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings SFPE Guidelines for Substantiating a Fire Model for a Given Application outlines a process for identifying and treating uncertainty. Substantiation: The SFPE Guidelines for Substantiating a Fire Model for a Given Application provide much more comprehensive methods for treating uncertainty and other sources of inaccuracy associated with the use of fire models. Public Input Response: See FR136. _______________________________________________________________________________________________ 101 16 SAF-FUN (A.5.6.4) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise last sentence to read as follows: Computer fire models should be evaluated to ensure that they are appropriate for their intended use for their predictive capability in accordance with the SFPE Guidelines for Substantiating a Fire Model for a Given Application ASTM E 1355, Standard Guide for Evaluating the Predictive Capability of Deterministic Fire Models. Substantiation: The process described in ASTM E-1355 has only been used a small number of times, and many of the evaluations took a person-year or more to conduct. Indeed, SFPE's application of this process to DETACT-QS, which is one of the simplest fire models in existence, took thousands for person-hours to complete. Clearly, this methodology is impractical for individual project use. The SFPE Guidelines for Substantiating a Fire Model for a Given Application were written specifically for individual uses of fire models. The Engineering Guide to Substantiating a Fire Model for a Given Application provides a framework for determining and documenting the suitability of a fire model for use in a specific application. The framework in the guide is applicable to all types of fire models, ranging from algebraic calculations to zone or lumped parameter models to CFD or field models. The guide addresses: ● Definition of the problem that is intended to be solved using modeling ● Selection of a candidate model ● Model verification and validation ● Uncertainty analysis Public Input Response: See FR137. _______________________________________________________________________________________________ 101 17 SAF-FUN (A.5.8.1) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise first sentence to read as follows: The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings describes the documentation that should be provided for a performance-based design. Substantiation: Update reference to current edition. Public Input Response: See FR138. Printed on 9/13/2012 27 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 221 SAF-FUN (A.6.1.8.1.4) _______________________________________________________________________________________________ Submitter: Dana Peterson, University of New Hampshire / Rep. APPA Recommendation: Delete the following text: A.6.1.8.1.4 Dormitory. Rooms within dormitories intended for the use of individuals for combined living and sleeping purposes are guest rooms or guest suites. Examples of dormitories include college dormitories, fraternity and sorority houses, and military barracks. Substantiation: The purpose of the proposed change is to clarify the classification of occupancy types especially as it applies to student residence facilities, formerly commonly referred to, and sometimes still referred to as dormitories. Currently, dormitories are listed as hotel occupancies which we feel is an incorrect designation for today's student residence facilities. The definition provided for a dormitory suggests a student lifestyle and building type of a bygone day. Today's residence halls are anything but formulaic. Many are a mix of apartments, suites, double-doubles, and single occupant rooms. These kinds of facilities make for interesting architectural arrangements of space and complex interior floor plans that don't always have intuitively obvious exit routes. Cooking facilities, both in individual rooms and communal kitchens, as well as food service facilities, are becoming increasingly more common if not the norm. A trend toward "Living and Learning" has created buildings that have increasing amounts of assembly space within them. Classrooms, recreation facilities, and movies/concert/dance venues are all becoming common place in newer facilities. That said, there are still buildings that are akin to the old-style dormitory, such as summer camps, hostels, homeless shelters, bunkhouses, and barracks, and the code should have a classification to recognize those facilities too. So our proposal recognizes dormitories as a potential hotel occupancy as well and judges the difference the same way as all other occupancies are judged, by the transient or non transient nature of the occupants. The proposal also specifically designates that non transient student residence facilities are an apartment occupancy, removing the necessity for the "dormitory" to both describe the defining features and give all-encompassing examples. Public Input Response: Even if the SAF-RES technical committee were to develop new occupancy chapters for student residential facilities, there will remain a need for the definition of the word dormitory for use with the sleeping venues in military housing, low-risk detention facilities, employee work camps, and children's summer camps, for example. _______________________________________________________________________________________________ 101 137 SAF-FUN (A.6.1.14.3.2) _______________________________________________________________________________________________ Submitter: Richard M. DiMisa, Code Consultants, Inc. Recommendation: Delete the following text: A.6.1.14.3.2 For example, a common path of travel that occurs wholly in a business tenant space, in a multiple occupancy building containing assembly and business occupancies, should not have to meet the assembly occupancy common path of travel limitation. Substantiation: This annex material is proposed to be deleted and replaced by the proposed annex material for the proposed section 6.1.14.3.3. Public Input Response: The annex is needed. The current annex text is an applicable example. Printed on 9/13/2012 28 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 138 SAF-FUN (A.6.1.14.3.3 (New) ) _______________________________________________________________________________________________ Submitter: Richard M. DiMisa, Code Consultants, Inc. Recommendation: Add a new section to read as follows: A.6.1.14.3.3 A shared means of egress is that portion of the exit access, exit, and exit discharge which serves mixed ocupancies. For example, the travel distance measurement may be 300 feet for a business occupancy in a fully sprinklered building; however, once the travel distance is located in a corridor which also serves assembly occupants (the shared means of egress), the travel distance must not exceed 250 feet to the nearest exit. Substantiation: The proposed change protects the occupants of the building by applying the most restrictive requirements for features that could affect the mixed occupancy to the entire mixed occupancy while requirements that can be applied to an individual occupnacy without impacting the safety of the mixed occupancy are applied to the individual occupancy. Public Input Response: The change requested by the submitter is not needed as the Code text on shared means of egress will not be changed. Can't have annex material to a nonexistent main body provision. _______________________________________________________________________________________________ 101 114 SAF-FUN (C.1) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Add new text to read as follows: ASTM E2768, Standard Test Method for Extended Duration Surface Burning Characteristics of Building Materials (30 min Tunnel Test), (2011). Substantiation: ASTM has now issued a test method, ASTM E2768, which contains the three requirements discussed in this section, namely that a product be tested in accordance with ASTM E84 or UL 723, and exhibit a flame spread index of 25 or less, show no evidence of significant progressive combustion when the test is continued for 30 minutes (i.e. an additional 20-minute period over the standard ASTM E84 duration of 10 minutes) and that the flame front not 1 progress more than 10 /2 feet (3200 mm) beyond the centerline of the burners at any time during the test. This change replaces the lengthy information about requirements with a reference to the standard. The NFPA Manual of Style does not allow requirements in definitions. Therefore this change places the requirements into a new section in Chapter 4, immediately following the requirements for noncombustible material and limited combustible material. Public Input Response: The document will not appear in Annex A text, so it cannot appear in Annex C which lists those references mentioned in Annex A text. Printed on 9/13/2012 29 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 134 SAF-FUN (C.1.2.6) _______________________________________________________________________________________________ Submitter: Marcelo M. Hirschler, GBH International Recommendation: Revise text to read as follows: C.1.2.6 ASTM Publications. ASTM International, P.O. Box C700, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959. www.astm.org ASTM C 1629/C 1629M, Standard Classification for Abuse-Resistant Nondecorated Interior Gypsum Panel Products and Fiber-Reinforced Cement Panels, 2006 (2011) . ASTM D 2859, Standard Test Method for Ignition Characteristics of Finished Textile Floor Covering Materials, 2006 (2011). ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2012 2010. ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials, 2012 2010b. ASTM E 814, Standard Test Method for Fire Tests of Through-Penetration Fire Stops, 2011a 2010. ASTM E 1352, Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies, 2008a. ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture, 2008a(e1). ASTM E 1355, Standard Guide for Evaluating the Predictive Capability of Deterministic Fire Models, 2012 2005a. ASTM E1472, Standard Guide for Documenting Computer Software for Fire Models, 2007 (Withdrawn 2011) ASTM E 1537, Standard Test Method for Fire Testing of Upholstered Furniture, 2012 2007. ASTM E 1590, Standard Test Method for Fire Testing of Mattresses, 2012 2007. ASTM E 1966, Standard Test Method for Fire-Resistive Joint Systems, 2007 (2011). ASTM E2030, Standard Guide for Recommended Uses of Photoluminescent (Phosphorescent) Safety Markings , 2009a ASTM E 2174, Standard Practice for On-Site Inspection of Installed Fire Stops, 2010a e1 2009. ASTM E 2238, Standard Guide for Evacuation Route Diagrams, 2002 (withdrawn 2011). ASTM E 2280, Standard Guide for Fire Hazard Assessment of the Effect of Upholstered Seating Furniture Within Patient Rooms of Health Care Facilities, 2009 2003. ASTM E 2307, Standard Test Method for Determining Fire Resistance of Perimeter Fire Barrier Systems Using Intermediate-Scale, Multi-Story Test Apparatus, 2010. ASTM E2393, Standard Practice for On-Site Inspection of Installed Fire Resistive Joint Systems and Perimeter Fire Barriers, 2010a. ASTM E 2484, Standard Specification for Multi-Story Building External Evacuation Controlled Descent Devices, 2008. ASTM E 2513, Standard Specification for Multi-Story Building External Evacuation Platform Rescue Systems, 2007. ASTM F 1637, Standard Practice for Safe Walking Surfaces, 2010 2009. ASTM F 1870, Standard Guide for Selection of Fire Test Methods for the Assessment of Upholstered Furnishings in Detention and Correctional Facilities, 2011 2005. Substantiation: Standards update. ASTM E1352 and ASTM E1353 are recommended for removal by other public input. Public Input Response: See FR139. Printed on 9/13/2012 30 Report on Public Input – June 2014 NFPA 101 _______________________________________________________________________________________________ 101 18 SAF-FUN (C.1.2.11) _______________________________________________________________________________________________ Submitter: Morgan J. Hurley, Society of Fire Protection Engineers Recommendation: Revise text to read as follows: SFPE Publications. Society of Fire Protection Engineers, 7315 Wisconsin Avenue, Suite 620E 1225 W, Bethesda, MD 20814. www.sfpe.org SFPE Computer Software Directory. SFPE Enforcer’s Code Official's Guide to Performance-Based Design Review, 2004. SFPE Engineering Guide — Evaluation of the Computer Fire Model DETACT-QS, 2002. SFPE Engineering Guide to Human Behavior in Fire, 2003. SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings, 1998, 2007. SFPE Guidelines for Peer Review in the Fire Protection Design Process, 2009. SFPE Guidelines for Substantiating a Fire Model for a Given Application, 2011. Substantiation: Update references to current edition and add new reference cited in other proposals. Public Input Response: See FR140. _______________________________________________________________________________________________ 101 58 SAF-FUN (C.1.2.12) _______________________________________________________________________________________________ Submitter: John F. Bender, UL LLC Recommendation: Revise text as follows: C.1.2.12 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096. www.ul.com UL Fire Resistance Directory, 2010 2012. ANSI/UL 263, Standard for Fire Tests of Building Construction and Materials, 2003, Revised 2007 2011. ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, 2008, Revised 2010. ANSI/UL 1040, Standard for Fire Test of Insulated Wall Construction, 1996, Revised 2007. ANSI/UL 1479, Standard for Fire Tests of Through-Penetration Firestops, 2003, Revised 2010. ANSI/UL 1715, Standard for Fire Test of Interior Finish Material, 1997, Revised 2008. UL 1975, Standard for Fire Tests for Foamed Plastics Used for Decorative Purposes, 2006. ANSI/UL 2079, Standard for Tests for Fire Resistance of Building Joint Systems, 2004, Revised 2008. Substantiation: Updated referenced standards to most recent edition as indicated. Public Input Response: See FR141. Printed on 9/13/2012 31
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