Technical Committee Docu mentation - NFPA

1987 Fall M e e t i n g

T e c h n i c a l C o m m i t t e e D o c u m e n t a t i o n

TCD-87-F

A Compilation of the Documented Action on Comments Received by the Technical Committees Whose Reports Have Been Published

Prior to Consideration at the NFPA Fall Meeting

Red Lion Inn Portland, Oregon

November 9-12, 1987

Please Bring to the Fall Meeting I

Copyright ~: 1987

All Rights Reserved

National Fire Protection Association, Inc. Batterymarch Park, Quincy, MA 02269

13M-9-87-TCD Printed m U.S.A.

SUPPLEMENTARY

Report of Committee on Safety to Life

J. Armand Burgun, Chairman Rogers Burgun Shahine & Deschler Architects

John F. Behrens, Vice Chairman Huntington Beach, CA

Rep. International Conference of Building Of f ic ia ls

James K. Lathrop, Secretary National Fire Protection Assn.

(Nonvoting)

John F. Berndt, Nat'l Research Council of Canada John L. Bryan, University of Maryland Wendell H. Couch, Holiday Inns, Inc.

Rep. American Hotel Motel Assn. John G. Degenkolb, Carson City, NV

Rep. Assn. of Motion Picture & Television Producers Ernest A. Emerson, State Fire Marshal, Austin, TX

Rep. Fire Marshals Assn. of North America Russell P. Fleming, Nat'l Fire Sprinkler Assn. Walter A. Haas, Underwriters Laboratories Inc. Roger A. Hage, Amoco Corp.

Rep. Building Owners and Managers Assn. Paul K. Heilstedt, Building Of f ic ia ls and Code

Administrators I n t ' l William H1etaky, The Taubman Co. Alfred J. Hogan, Cypress Gardens, FL

Rep. I n t ' l Assn. of Fire Chiefs Richard A. Hudnut, Builders Hardware Mfrs. Assn. Joseph E. Johnson, Hilton Head Island, SC

Rep. Nat'l Electrical Mfrs. Assn. Edwina Ju i l l e t , Waynesboro Community Hospital, VA

Rep. Nat'l Task Force on Life Safety and the Handicapped, Inc.

Ode Richard Keil, Joint Commission on Accreditation of Hospitals

Gerald E. Lingenfelter, American Insurance Services Group, Inc.

B i l l y R. Manning, Southern Bldg. Code Congress I n t ' l . Inc.

Jonas Morehart, Nat'l Institutes of Health Harold E. Nelson, Nat'l Bureau of Standards/Center For

Fire Research Richard R. Osman, Schirmer Engineering Corp. Reginald A. Penney, Palm Beach County F~re/Rescue

Rep. F~re Marshals Assn. of North America James R. Quiter, Roll Jensen & Assoc., Inc. Thomas V. Rodante, Calte× Petroleum Corp.

Rep. American Petroleum Inst i tute John A. Shar ry , Lawrence L ivermore L a b o r a t o r i e s Richard S. Smith, Chemical Bank o f NY

Rep. NFPA F i re Serv i ce Sect ion Wal te r 3 m i t t l e I I l , S ta te F i re Marshal , WV

Rep. F i re Marshals Assn. o f North America Robert H. Woodcock, J r . , Aetna L i f e & Casua l ty Co.

Rep. American Insurance Serv ices Group, Inc .

Alternates

Alastair J. M. Aikman, Ottawa, Ontario (Alternate to J.F. Berndt)

E. N. Cellentani, Federal Signal Corp. (Alternate to J.E. Johnson)

Charles M. Decker, NJ Dept. of Community AFFairs (Alternate to P.K. Heilstedt)

Andrew J. Fowell, Nat'l Bureau of Standards/Center for Fire Research (Alternate to H.E. Nelson)

William A. Kennedy, Palm Beach County Fire/Rescue (Alternate to R.A. Penney)

Wayne A. Kleinfelder, Underwriters Laboratories Inc. (Alternate to W.A. Haas)

John W. McCormick, Rolf Jensen & Assoc., Inc. (Alternate to J.R. Quiter)

lames A. M11ke, Columbia, MD (Al~ernatP Lo J L. Bryan)

David W. Owei~, Mobil Research & Development Corp. (Alternate to T.V. Rodante)

Robert R. Sanders, LaQuinta Motor Inns, Inc. (Alternate to W.H. Couch)

Howard Teich, New York, NY (Alternate to E. Ju i l l e t )

R~chard Vognild, Southern Bldg. Code Congress I n t ' l , Inc. (Alternate to B.R. Manning)

E×ecutlve Committee and Subcommittee on Administration

J. Armand Burgun, Chairman Rogers, Burgun, Shahine & Deschler Architects

John F. Behrens, Vice Chalrman Huntington Beach, CA

Rep. I n t ' l Conference of Buildlng Off lc iaIs

Ron Cote', Secretary National Fire Protection Assn.

(Nonvoting)

John G. Degenkolb, Carson City, NV Rep. Assn. of Motion Picture & Television Producers

William Hiotaky, The Taubman Co. Richard A. Hudnut, Builders Hardware Mfrs. Assn. Joseph E. Johnson, Hilton Head, SC

Rep. Nat'l Electrical Mfrs. Assn. Edwina Ju i l l e t , Waynesboro Community Hospital, VA

Rep. Nat'l Task Force on Life Safety and the Handicapped, Inc.

Jonas Morehart, Nat'l Insti tutes of Health Thomas V. Rodante, Calte× Petroleum Corp.

Rep. American Petroleum Inst i tute John A. Sharry, Lawrence Livermore Laboratories

Subcommittee on

Means of Egress

John F. Behrens, Chairman Huntington Beach, CA

Rep. International Conference of Buildlng OFficials

Glenn A. Erickson, Vice Chairman Hastings, MN

Rep. Building Of f ic ia ls and Code Administrators I n t ' l


(Nonvoting)

John L. Bryan, University of Maryland Richard A. Dolby, Office of State Fire Marshal, ME

Rep. Fire Marshals Assn. of North America Walter A. Haas, Underwriters Laboratories Inc. Richard A. Hudnut, Builders Hardware Mfrs. Assn.

Rep. NFPA Committee on Fire Doors & Windows Edwina Ju i l l e t , Waynesboro Community Hospital, VA

Rep. Natl' Task Force on Life Safety and the Handicapped, Inc.

Chuck Kime, Phoenix Fire Dept. Rep. Fire Marshals Assn. of North America

Charles R. McDonald, McDonald Equipment Co. Rep. Elec. Generating Systems Mktg. Assn.

Harold E. Nelson, Nat'l Bureau of Standards/Center for Fire Research

Jake PauIs, Nat'l Research Council Canada Michael Sbaglia, American Insurance Services Group, Inc. Leslie Stru l l , Roll Jensen & ASSOC., Inc.

264

Raymond C. Tartre, H C I Corp. Rep. Door and Hardware Inst i tu te

Bertram Vogel, Schirmer Engineering Corp. Richard Vognild, Southern Bldg. Code Congress I n t ' l ,

Inc. William A. Young, Lithonia Lighting Co.

Rep. Nat'l Electrical Mfrs. Assn.

Alternates

Robert A. Bullard, Bullard Assoc., Inc. (Alternate to R.C. Tartre)

Paul K. Heilstedt, Building Of f ic ia ls and Code Administrators I n t ' l (Alternate to G. Erickson)

Norman J. Kornsand, Schirmer Engineering Corp. (Alternate to B.M. Vogel)

B i l l y R. Manning, Southern Bldg. Code Congress I n t ' l , Inc. (Alternate to R. Vognlld)

James R. Quiter, Roll Jensen & Assoc., Inc. (Alternate to L. Stru l l )

Theresa J. Rosenberg, NC Dept. of Insurance (Alternate to E. Ju i l l e t )

William D. Walton, Nat'l Bureau of Standards (Alternate to H. Nelson)

Nonvoting

Willlam A. Simms, U.S. Occupational Safety & Health Admin.

Subcommittee on

Fire Protection Features

Jonas Morehart, Chairman Nat'l Institutes of Health


(Nonvoting)

Bruce D. Anson, Rohm and Haas Co. Rep. Society of the Plastics Industry

Brock Arms, Glencoe, IL Rep. Amerlcan Society of In ter ior Designers

John F. Bender, Office of State Fire Marshal, MO Rep. Fire Marshals Assn. of North America

John F. Berndt, Nat'l Research Council of Canada Peter H, Billing, Nat'l Forest Products Assn. Delbert F. Boring, Jr., American Iron & Steel Instltute Roger T. Boyce, Systems Approach Ltd. David E. Brackett, Gypsum Assn. Edward J. Budnick, Hughes Assoc. Wells Denyes, Eastman Chemical Products, Inc.

Rep. Man Made Fiber- Producers Assn. Michael Ferber, Hospital Assn. of PA Ralph Gerdes, Ralph Gerdes & Assoc. Gregory Haley, INA Loss Control Services, Inc.

Rep. American Insurance Services Group, Inc. Craig H. Kampmier, Swansea, HA Marshall A. Klein, Marshall A. Klein & Assoc., Inc. Wayne A. Kleinfelder, Underwriters Laboratories Inc. William C. Koffel, Jr . , KoFFel Assoc., Inc. Joseph G. Lesniak, Door & Hardware Inst i tute Jack A. Medovich, FairFax, VA

Rep. Fire Marshals Assoc. of North America James R. Quiter, Rolg Jensen & Assoc., Inc. William A. Schmidt, Bowie, MD

Rep. NFPA Air Cond. Comm. Thomas S. Stanton, Bendix Field Engr. Corp. Bar ry Tor rence , Torrence & Assoc.

265

A l t e r n a t e s

R. Michael Caldwell, Nat'l Forest Prod. Assn. (Alternate to P.H. Bi l l ing)

Leonard Y. Cooper, Nat'l Bureau of Standards/Center For Fire Research (Alternate to NBS Rep.)

Walter A. Haas, Underwriters Laboratories Inc. (Alternate to W.A. Kleinfelder)

John W. McCormick, Roll Jensen & Assoc., Inc. (Alternate to J.R. Quiter)

Joseph J. Messersmith, Jr . , Portland Cement Assn. (Alternate to J.P. Barris)

J. Kenneth Richardson, Nat'l Research Council of Canada (Alternate to J.F. Berndt)

Gary F. Tilson, American Iron & Steel Inst i tu te (Alternate to D. Boring)

Subcommittee on

Building Service and Fire Protection Equipment

Joseph E. Johnson, Chairman Hilton Head Island, SC

Rep. Nat'l Electrical Mfrs. Assn.


(Nonvoting)

Richard W. Bukowski, Nat'l Bureau of Standards/Center for Fire Research

Gene Cellentani, Federal Signal Corp. Rep. Nat'l Electrical MFrs. Assn.

Edward A. Donoghue, Nat'l Elevator Industry, Inc. William Durham, Chevy Chase, MD Russell P. Fleming, Nat'l Fire Sprinkler Assn. Daniel J. Fries, Largo Fire Dept., FL

Rep. Fire Marshals Assn. of North America Robert A. Hall, Guardian Industries, Inc.

Rep. NFPA Protective Signaling Systems Committee Roll H. Jensen, Roll Jensen & Assoc., Inc.

Rep. NFPA Automatic Sprinkler Committee Richard L. Klinker, Kl~nker & Assoc. Inc. Martin H. Reiss, The Gamewell Corp.

Rep. Automatic Fire Alarm Assn. John T. Wandell, Town of Palm Beach, FL

A l t e r n a t e s

Irving Mande, Edwards Co., Inc. (Alternate to R. Hall)

George Rye, Honeywell, Inc. (Alternate to G. Cellentani)

Chester W. Schirmer, Schirmer Engineering Corp. (Alternate to R. Jensen)

Walter F. Schuchard, Electro Signal Lab. (Alternate to M. Reiss)

Elmer J. Sumka, Westinghouse Elevator Co. (Alternate to E.A. Donoghue)

Subcommittee on

Assembly and Educat iona l Occupancies

John A. Shar ry , Chairman Lawrence - L ivermore L a b o r a t o r i e s


(Nonvoting)

Tim Barge, Dallas/Fort Worth I n t ' l Airport William F. Bennett, U.S.F.& G. Corp.

Rep. American Insurance Services Group, Inc. Robert W. Davis, Ervin & Davis, Architects

John G. Degenkolb, Carson City, NV Rep. Assoc. of Motion Picture & Television Producers

Donald T. Eyberg, Jr. , Ellerbe Assoc., Inc. Jerry W. Frazier, Fire Prevention Codes Administration

Lincoln, NE J. Russell H i l l , Friendly Ice Cream Corp.

Rep. Nat'l Restaurant Assn. Tim Holt, Nat' l School Supply & Equipment Assn. Chuck Kime, Phoenix Fire Dept., AZ

Rep. Fire Marshals Assoc. of North America Paul R. Krone, State Dept. of Education, FL Max H. Leventhal, American Repertory Theater

Rep. U.S. Inst i tute for Theatre Technology Robert J. L i t t l e , Church of Jesus Christ of Latter-day

Saints Robert D. McAninch, U n i v e r s i t y o f Kentucky Jake Pauls, N a t ' l Research Counci l Canada David L. Su t t e r , Hussey Manufac tur ing Co., Inc. S tan ley Ziemer, Stan ley Ziemer & Assoc.

Alternates

James L. Brown, N a t ' l Restaurant Assn. ( A l t e r n a t e to J.R. H i l l )

Subcommittee on

Heal th Care Occupancies

J. Armand Burgun, Chairman Rogers Burgun Shahine & Oeschler Architects

Donald W. Be l l es , Vice Chairman Donald W. Be l les & Assoc. , Inc.

James K. Lathrop, Sec re ta ry Nat iona l F i re P r o t e c t i o n Assn.

(Nonvot ing)

Arthur Bergantz, Code Consultants, Inc. William Brooks, Klinker & Assoc., Inc. Kenneth Bush, Maryland State Fire Marshals Office,

Rep. Fire Marshals Assoc. of North America Paul C. Dent, Geisinger Medical Center, PA

Rep. NFPA Health Care Section Donald R. Edge, The Edge Group

Rep. American Assn. For" Hospital Planning Kenneth S. Faulstich, Veterans Administration Robert E. Graham, Aberdeen Provlng Ground, MD Thomas Jaeger, Gage-Babcock & Assoc. , Inc.

Rep. American Health Care Assn. Fred S. Kellow, Cheyenne, WY

Rep. Assn. of Health Faci l i t ies Licensure & Cert i f icat ion Directors

William Kowgias, U.S. Dept. Health & Human Services Rockv111e, MD Rep. HHS PHS

Omer G. Lamothe, HUHANA Rep. Federa t ion o f American H o s p i t a l s

Ralph Loeb, J r . , Sher lock Smith & Adams, Inc . Rep. NFPA Committee on Health Care Faci l i t ies

Harold E. Nelson, Nat'l Bureau of Standards/Center for Fire Research

Jerry Ness, Joint Commission on Accreditation of Hospitals Kirby W. Perry, Austin, TX

Rep. American Inst i tute of Architects Llalson Emilio M. Pucillo, U.S. Dept. Health & Human

Services, NY Rep. HHS-ROFEC

J. Benjamin Roy, Jr . , Office of State Fire Marshal, DE Rep. Fire Marshals Assn. of North America

Howard Sheldon, Reliance Insurance Co. Rep. American Insurance Services Group, Inc.

Joseph G Sprague, Harwood K. Smith & Partners Rep. American Hospital Assn.

Mayer O. Zimmerman, U.S. Dept. Health & Human Services Baltimore, MD Rep. HHS-HCFA

Alternates

Don C. Bedell, Health Projects, Inc. (Alternate to T. Jaeger)

Autumn H. Blakeley, American Medical I n t ' l , Inc. (Alternate to D. Edge)

Walter A. Collins, Dept. of Health & Human Services (Alternate to W. Kowgios)

Michael Crowley, RoIF Jensen & ASSOC., Inc. (Alternate to M.E. Petersen)

R. Michael Daniel, U.S. Army Health Fac i l i t ies Planning Agency (Alternate tO R.E. Graham)

Alice L. Epstein, Johnson & Higgins ECRI (Alternate to R. Loeb)

Douglas S. Erickson, American Hospital Assn. (Alternate to O. Sprague)

J. Richard Fruth, Hayes Large Suckling Fruth & Wedge ( A l t e r n a t e to K. Perry)

Thomas D. M i l l i n , T.D. M i l l i n & Assoc. ( A l t e r n a t e to B. Roy)

Subcommittee on

Detention and Correctional Occupancies

Richard A. Hudnut, Chairman Builders Hardware Manufacturers Assn.


(Nonvoting)

Walter G. Bailey, Federal Bureau of Prisons Robert A. Boyle, Edwards & Daniels Assoc., Inc. Robert R. Brink, Brinks Locking Systems, Inc.

Rep. Door & Hardware Inst i tute Wayne G. Carson, Carson Assoc. A. Larry Iseminger, Jr . , State Fire Marshals Office, MD

Rep. Fire Marshals Assoc. of North America Thomas Jaeger, Gage Babcock & Assoc., Inc. William E. Koffel, Jr. , Koffel Assoc., Inc. George B. Kramer, Kane County Sher i f f ' s Dept., IL

Rep. National Sheriffs Assn. E. Eugene Mi l ler , C.M. Security Products Harold E. Nelson, Nat'l Bureau of Standards/Center for

Fire Research Antonino Nobile, Folger Adam Co. Robert M. Norris, VA Dept. of Corrections William E. Prindle, I I , Prindle Assoc., Inc. Hardy Rauch, American Correctional Assn. Joseph Schumacher, City of Aurora Fire Dept., CO Wayne S. Smith, State Fire Marshals OFfice, TX

Rep. f i r e Marshals Assn. of North America

A l t e r n a t e s

Robert O. Carter, Folger Adam Co. (Alternate to A. Nobile)

Dave Doxzen, Frederick County Sheriffs Dept., MD (Alternate to G. Kramer)

Edward L. Earles, Federal Bureau of Prisons (Alternate to W. Bailey)

Jef f Shibe, Nat'l Bureau of Standards/Center for Fire Research (Alternate to H. Nelson)

266

Subcommittee on

Residential Occupancies

Irwin A. Benjamin, Chairman Benjamin/Clarke Assoc., Inc.

(Deceased March 1987)


(Nonvoting)

Samuel L. Beach, Holiday Inn, Inc. Peter H. B i l l ing, Nat'l Forest Products Assn. Howard Boyd, Nashville, TN

Rep. Fire Marshals Assoc. of North America Harry L. Bradley, State Fire Marshals Office, MD

Rep. Fire Marshals Assoc. of North America Peter G. Christie, TAA, Inc. Andrew J. Fowell, Nat'l Bureau of Standards/Center

for Fire Research Paul K. Heilstedt, Building OFficials and Code

Administrators I n t ' l Marshall A. Klein, Marshall A. Klein & Assoc., Inc. Norman A. Koplon, Atlanta Dept. of Bldgs., GA Michael F. LaFfey, Prudential Insurance Co. of America Alfred J. Longhitano, Gage-Babcock & Assoc., Inc. Joseph J. Messersmith, Jr . , Portland Cement Assn. Donald L. Moore, U.S. Dept. of Housing & Urban

Development Jerry Ness, Joint Commission on Accreditation of Hospitals John Scarff, Marriott Corp.

Rep. American Hotel Motel Assn. Bertram Vogel, Schirmer Engineerlng Corp. Mayer D. Zimmerman, Baltimore, MD

A l t e r n a t e s

Carl Baldassarra, Schirmer Engineering Corp. (Alternate to B. Vogel)

Kenneth Bush, State Fire Marshals Office, HD (Alternate to H. Bradley)

R. Michael Caldwell, Nat'l Forest Products Assn. (Alternate to P.H. B1lllng)

Wendall Couch, Holiday Inns, Inc. (Alternate to S. Beach)

Charles M. Decker, NO Dept. of Community Affairs (Alternate to P.K. Heilstedt)

Walter Smittle, I I I , State Fire Marshals OFfice, WV (Alternate to H. Boyd)

Subcommittee on

Board and Care Fac i l i t ies

Edwina Ou~llet, Chairman Waynesboro Community Hospital

Rep. Nat'l Task Force on Life Safety & the Handicapped Inc.


(Nonvoting)

Peter H. B i l l ing, Nat'l Forest Products Assn. Harry L. Bradley, State Fire Marshals Office, MD

Rep. Fire Marshals Assn. of North America Faye J. Chiles, Dept. of Mental Health & Mental

Retardation, TN L. Darl Cross, State Fire Marshals Office, WV

Rep. Fire Marshals Assn. of North America Paul R. Daraghy, Colorado Dept. of Health Phil ip C. Pavro, Favro-HcLaughlin & Assoc.

Arnold G. Gangnes, Gangnes/Klappenbach Architects Rep. President's Committee on Mental Retardation

Solomon Goldberg, New Jersey Dept. of Health Rep. Assoc. of Health Fac i l i ty Licensure & Cert i f icat ion Directors

Norman E. Groner, Santa Cruz, CA Walter A. Haas, Underwriters Laboratories Inc. Gregory Haley, Cigna Loss Control, Inc.

Rep. American Insurance Services Group, Inc. Thomas M. Jung, N.Y. State Office of Mental Retardation

& Developmental Disabi l i t ies William E. Koffel, Jr . , Koffel Assoc., Inc.

Rep. American Health Care Assn. Bernard H. Levin, Nat'l Bureau of Standards/Center for

Fire Research Robert C. Murray, Mission Rd. Develop. Ctr.

Rep. Nat'l Assn. of Priv. Res. Fac. For the Mentally Retarded

Peter SaJevic, Snelling Park Place Rep. Assn. of Res. Resources in HN

James Shipley, City of Alexandria Code Enforcement, VA Jack L. Taylor, The United Methodist Homes of NJ

Rep. American Assoc. of Homes For the Aging Bertram Vogel, Schirmer Englneering Corp. Mayer D. Zimmerman, U.S. Dept. of Health & Human

Services, Baltimore, HD Rep. HHS-HCFA

A l t e r n a t e s

R. Hichael Caldwell, Nat'l Forest Products Assn. (Alternate to P.H. Bi l l ing)

Bob L. Fesler, Nat'l Heritage Inc. (Alternate to W.E. KoFFel, Jr.)

Harold E. Nelson, Nat'l Bureau of Standards/Center For Fire Research (Alternate to B.M. Levin)

Subcommlttee on

M e r c a n t i l e and Business Occupancies

W i l l i am H io taky , Chairman The Taubmaq Co.

Ron Cote' Nat iona l F i re P r o t e c t i o n Assn.

(Nonvot ing)

David M. Banwarth, Prince George's County Fire Dept., MD E. Joseph Bocci, Nat'l Park Service, Washington, DC Delbert F. Boring, Jr., American Iron & Steel Institute Timothy Callahan, Fire Protection Consultants, Inc. Warren F i e l d i n g , T r a v e l e r s Insurance Co.

Rep. American Insurance Serv ices Group, Inc . Russel l P. Fleming, N a t ' l F i re S p r i n k l e r Assn. Roger A. Hage, Amoco Corp.

Rep. Building Owners & Managers Assn. Clifford S. Harvey, Boulder Fire Dept., C0

Rep. Fire Marshals Assn. of North America Richard F. La t t ey , Duxbury, HA

Rep. A l l i a n c e o f American Insu re rs Thomas D. H i l l i n , O f f l c e o f Sta te F i re Marshal , LA

Rep. F i re Marshals Assn. o f North America R.R. Osman, Schirmer Engineer ing Corp. Ed Schu l tz , Code Consu l tan ts , Inc.

Alternates

Carl F. Baldassarra, Sch~rmer Engineering Corp. (Alternate to R.R. Osman)

Gary F. Tilson, American Iron & Steel Instltute (Alternate to O. Boring)

267

Subcommittee on

Industr ial , Storage and Miscellaneous Occupancies

Thomas V. Rodante, Chairman Caltex Petroleum Corp.

Rep. American Petroleum Inst i tute

Gregory W. Thomas, Vice Chairman Liberty Mutual Insurance Co.

Rep. Alliance of American Insurers

Ron Cote' National Fire Protection Assn.

(Nonvoting)

Kenneth E. Berg, The FPE Group Oelbert F. Boring, American Iron & Steel Inst i tute Howard M. Bucci, Rockwell I n t ' l Hartford Operations Carol A. Caldwell, Lawrence Livermore Nat' l Laboratory Morris V. Gurnell, Lithonia, GA

Rep. Impell Corp. Bruce Hisley, Nat'l Fire Academy

Rap. Fire Marshals Assn. of North America Thomas P. O'Connor, U.S. Dept of Energy Evan R. Quarton, Johnson & Higglns Andrew P. Scitt ine, AT&T Technologies

Rap. NFPA Industrial Fire Protection Section

A l t e r n a t e s

Leo E. Keenan, Sundstrand Corp. ( A l t e r n a t e to A.P. S c i t t i n e )

David W. Owen, Mobil Research & Development Corp. (Alternate to T.V. Rodante)

Gary F. Tilson, American Iron & Steel Inst i tute (Alternate to D. Boring)

This l i s t represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred.

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

Part I of this Supplementary Report was prepared by the Technical Committee on Safety to Life, and proposes for adoption a Supplementary Report which documents i ts action on the public comments received on i ts Report on NFPA lOl-lg85, Code for Safety to Life from Fire in Buildings and Structures, published in the Technical Committee Reports for the 1987 Fall Meeting.

Part I of this Supplementary Report has been submitted to le t te r ballot of the Technical Committee on Safety to Life which consists of 29 voting members; of whom 24 voted af f l rmat ively, 2 negatively (Messrs. Fleming and Smittle), 1 abstained (Mr. Johnson), and 2 ballots were not returned (Messrs. Heilstedt and Penney).

Mr. Fleming voted negatively stating: "My negative vote is based on the fact that several

proposals or parts thereof were i n i t i a l l y rejected by the Committee for good reason, then revived during the public comment period. As such, these changes did not receive adequate public input, nor was suf f ic ient new information provided to overturn the original reason for rejection:

Comment 101-372 (Log #94) on Proposal I01 597. Comment 101-400 (Log #603) on Proposal I01-674. qomment I01-389 (Log #604) on Proposal I01-712. In each of the above proposals, Exception NO. 2 was

i n i t i a l l y rejected because sprinkler system design and ins ta l la t ion c r i t e r i a is outside the scope of NFPA 101. As such, the Committee did not generate public review or comment as to the technical merits of the exception to NFPA 13. There is some concern as to

whether some of the criteria is sound, such as the al lowance o f a combined domest ic and s p r i n k l e r s e r v i c e l i n e or s to rage f a c i l i t y s i zed For 125 percen t o f the s p r i n k l e r demand. In s i t u a t i o n s such as a 3 - s t o r y h o t e l , the domest ic demand migh t we l l exceed the sprinkler demand, rendering the sprinkler Supply inadequate at times of peak domestic demand.

Comment 101-87 (Loq #242) a~d Comment I01-88 (Log #285) on Proposal 101-207.

The Committee i n i t i a l l y rejected the proposal on the basis that requirements for interconnection of smoke detectors were outside the Scope of NFPA I01. While the new wording does not speci f ica l ly require interconnection, the net ef fect is the same. Economical s i n g l e s t a t i o n smoke d e t e c t o r s have been o f va lue , however, e s p e c i a l l y in NFPA 74 d w e l l i n g s . From a t e c h n i c a l s t a n d p o i n t , a problem can be a n t i c i p a t e d in de te rm in ing "background no ise l e v e l s . "

Mr. S m i t t l e voted n e g a t i v e l y s t a t i n g : " I vote af f i rmat ively with the exception of my

comment regarding the Committee's continued authorization for use of 13D Residential Sprinklers in occupancies outside the scope of 13D is not appropriate. The requirements For 13D is for one and two family dwellings and not For Board and Care occupancies or Lodging and Rooming Houses. Also, the application of time regarding the evacuation of occupants is not proper. This changing environment of occupants could conceivably result in i ts c lassi f icat ion being changed from slow to impractical and vice versa within a Few months."

(Note that since Mr. Smittle voted af f i rmat ively with exception that his ballot is recorded as negative.)

Mr. Johnson submitted the Following comment with his "not voting" bal lot .

" I am abstaining because I do not agree with the action of the Technical Committee on Safety to Life in reversing i ts previous 21 to 7 written ballot acceptance of i ts own TCR Proposals, I01-454 (Log #1004), I01-455 (Log #I005) and lOl-45G (Log #100G), which were based upon TCR Proposal lOI-451 (Log #931) submitted by the Board For the Coordination of Model Codes (BCMC) of the Council of American Building Of f ic ia ls (CABO), a l l of which addressed f i r e detection i n new hea l t h care occupancies.

The r e v e r s a l o f the 21 to 7 TCR w r l t t e n b a l l o L taken s p e c i f i c a l l y on Logs 1004, 1005 and 1006 resH l t ed from a II to 8 voice vote at the TCD meeting of the Committee with about lO to 12 Committee members being absent. This voice vote hardly represents consensus although the vote complies with the "Regulations Governing Committee Projects" provided that this specific action is not balloted separately and also provided that the Committee voted af f i rmat ively by a 2/3 margin on i ts written bal lot on the entire Committee Report. Motions for separate balloting on portions of the Committee Report were also defeated by voice vote at the TCD meeting of the Committee. While I believe a separate ballot on this subject would have rejected the Committee voice vote, in the Final analysis i t probably would not matter how such a vote would go in the Committee. The opposing views on this part of the Report are so strongly and honestly held that I am convinced the losing side in Committee would propose amendments f o r A s s o c i a t i o n c o n s l d e r a t i o n at the Fa l l Meet ing in P o r t l a n d , where c a r e f u l e v a l u a t i o n o f a l l s u b s t a n t i a t i o n , both t e c h n i c a l and Judgemental w i l l be in o rde r .

I do not wish to vote n e g a t l v e l y on the e n t i r e r e p o r t as too many "no" votes would de lay the adop t l on o f the 1988 L i f e Sa fe t y Code For a t l e a s t 6 to 12 months and there are several hundreds of very important changes proposed that need to be adopted. Since I cannot, in good conscience, support the Commlttee's action on this subject unti l a Floor discussion can give a broader consensus of the membership, I am abstaining."

Mr. Lingenfelter submitted the following COmment with his aff i rmative bal lot:

"While voting af f i rmat ively, we wish to comment on Committee Action on two public comments on NFPA lOl.

268

Regarding Comment 101-279 (Log #14) concerning paragraph 12-3.4.5.4, we believe the Committee should have rejected this comment. The presence of a one-hour separation between hazardous areas (such as laboratories using hazardous materials, kitchens, and storage rooms 50-100 sq f t in area) and other rooms does not obviate the need For f i r e detection in such areas. While the one-hour separation may prevent flames from penetrating the enclosure, there may be considerable distr ibut ion of smoke and toxic gases. Also, lack of Fire detection combined with possible remote locations presents the opportunity For s igni f icant f i r e growth before Fire f ighting personnel (public or private) can begin extinguishment ef for ts , thereby making extinguishment more d i f f i c u l t and more dangerous. In an occupancy where defend-in-place is practiced, early detection is a necessity.

The Committee Action to accept Comment I01-294 (Log #311) (paragraph 12-3.6.1) is also improper. Log #311 reintroduces an exception or ig ina l ly deleted by Proposal I01-462 (pg. 348 of TCR). The exception (Exception No. 2 of the 1985 Edition) basically permits f i r e rated corridor part i t ions to terminate at unrated ceil ings rather than at the underside of a Floor; such ceil ings may have the equivalent of only a 10 or 15 minute rating at best. Therefore, Fire, as well as smoke and toxic gases, may readily pass over the top of the par t i t ion and into the adjacent space. We believe this is suf f ic ient technical Just i f icat ion to delete the previous design option.

Mr. Hudnut submitted the Following comment on his af f i rmat ive bal lot:

"While voting favorably re lat lve to the Technical Committee Documentation, I believe there are procedural problems needing to be addressed. The Following comments do not in any way, however, affect my affirmative vote.

On several occasions the Committee voted to "accept" or "accept in principle" but Failed to disassociate i t s e l f from some remarkably Flawed substantiations advanced by the submitters.

The public, in reading the Technical Committee Report or Documentation and noting Committee acceptance, can only conclude that the Committee agreed with the submitter's substantiations and would not necessarily realize that other reasons may have caused the Committee's action.

For example, I disagree completely with the statement implying that the use of detectors in patient rooms w i l l cause false alarms and therefore be dangerous. The Committee accepted the proposal not to require them for other reasons.

The users of the Life Safety Code should be made aware that Committee acceptance or acceptance in principle is not an endorsement of a submitter's substantiation, especially when a product, system or type of construction required in other sections of the Code has been severel~ critized by the submitter.

Part I I of this Supplementary Report was prepared by the Technical Committee on Safety to Life, and proposes For adoption a Supplementary Report which documents i ts action on the public comments received on i ts Report on NFPA IOIM, Manual on Alternative Approaches to Life Safety, published in the Technical Committee Reports for the 1987 Fall Meeting.

Part I I of this Supplementary Report has been submitted to le t te r bal lot of the Technical Committee on Safety to Life which consists of 29 voting members; of whom 27 voted af f i rmat ively, and 2 ballots were not returned (Messrs. Heilstedt and Penney).

Note that the title of this proposed new document was changed by Comment I01M-I. Revlsions to this document were also done by comments to Appendices C, D, E, F, G and H of NFPA 101. See Comments 101-572 through I01-587.

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PART I

(Log #493) tO] l - ( I - 6 . 4 ) : Accept in Pr inc ip le SUBMITTER: Tom Jaeger, Gage-Babcock & Assoc. COMMENT ON PROPOSAL NO.: 101-4 RECOMMENDATION: Reject Proposal 101-4. SUBSTANTIATION: The proposal is a major change with po ten t ia l l y fa r reaching impact. The term "occupancy subc lass i f i ca t ion" is not defined in Chapters 3 or 4. A user of the Code may in te rp re t the conversion of a doctor 's o f f i ce to a dent is t o f f i ce , or the conversion of a stage theater to a motion p ic ture theater as an occupancy subclassiFicat ion change resu l t ing in the F a c i l i t y having to meet new construct ion requirements. As a user of the Code fo r many years, the only occupancy c l a s s i f i c a t i o n that may be considered to have an "occupancy subc lass i f i ca t ion" is a res ident ia l occupancy. The Submitter has not submitted documentation that th is monumental change is necessary and the proposal should be rejected. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise occupancy chapters' treatment of subc lass i f i ca t ion as fo l lows:

"8-1.4. ] (9-1.4.1) Subclass i f icat ion of Assembly Occupancies. Each assembly occupancy shall be subclassi f ied according to i t s occupant load as fo l lows: . . ."

"14- I .4 .1" (15- I .4 .1 " ) Subclass i f icat lon of Detention and Correctional Occupancies. Users and occupants of detention and correct ional Fac i l i t i e s • . . resident user category is subclass~Fied into Five groups: . . , "

In 24-I.4.2.1 and 25-1.4.2.1 change "c lass i f i ed " to "subclassiFied".

28-1.4 no change. "28-1.4.1 SubclassiFication of Indu£tr ia l

Occupancies. Each indus t r ia l occupancy shall be subclass] l ied acccording to i t s use as Follows:"

(a) use current 28-1.4.1 (b) use current 28 1.4.2 (c) * use current 28 ] .4 .3 .

COMMITTEE COMMENT: The Committee agrees that c l a r i f i c a t i o n is needed as to what are "subclassiFicat ions" and the revis ions should accomplish th is . Use of the term "subclassiFicat ion" wi th in the applicable occupancy chapters w i l l cue the Code user as to when a change i n occupancy s u b c l a s s i f i c a t i o n has o c c u r r e d , A l so see r e v i s i o n s done by Comment 101-560 on A - I - G . 4 (Log #231) . The above a c t i o n s shou ld meet t he Commenter 's i n t e n t w i t h r e s p e c t to b e t t e r d e f i n i t i o n .

A hospital is in the process of planning a major modernization/renovation project to include a l l outpat ient areas• They are able to s h i f t inpat ient areas around wi th in the f a c i l i t y so that work can be phased and accomplished without major impact, but the ambulatory outpatient c l i n i cs must be temporari ly relocated to another f a c i l i t y while that part of the bui ld ing is being upgraded. The only area avai lab le is a general o f f i ce bui ld ing located near the main F a c i l i t y . I t appears that the bui ld ing can be u t i l i z e d func t iona l l y without physical a l t e ra t i on For the in ter im period. This proposed change to the Code would, however, require that the ex is t ing o f f i c e bui ld ing be upgraded/renovated to comply with new business occupancy requirements even though i t meets the requirements For ex is t ing business occupancies and the ambulatory outpatient c l i n i c Fal ls w l th in the business occupancy c l ass i f i ca t i on . We have not increased the hazard to the bui ld ing or to the occupants. Why should th is be necessary? What we have done, however, is s i g n i f i c a n t l y increase the time and expense associated with modernization/renovation of the hospi ta l . In fact , th is could be the straw that breaks the camel's back. I t could cu r ta i l or even proh ib i t the proposed modernization/renovation project . This concept is too r e s t r i c t i v e and is in to ta l c o n f l i c t with the intent of the L i fe Safety Code. With that, I strongly urge you to reject the submitted proposal lOI-4 thereby el iminat ing th is r e s t r i c t i v e and unnecessary change in Code philosophy. COMMITTEE ACTION: Accept in Pr inc ip le .

See Committee Action on Comment I0]-1 on l-G.4 (Log #493) . COMMITTEE COMMENT: The Commit tee A c t i o n on Comment 101 - I (Log #493) shou ld s a t i s f y t he Commenter 's i n t e n t ,

(Log #451) lOl - 4 - (3-2): Accept SUBMITTER: William E. KoFFel, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO.: 101-30 RECOMMENDATION: Insert a new d e f i n i t i o n into Chapter 3 def in ing "Common Path of Travel"• The d e f i n i t i o n shall read as proposed For paragraph 5 - I .2 .6 . SUBSTANTIATION: Whereas the phrase common path of t ravel is used throughout the Code, the d e f i n i t i o n should appear in Chapter 3. As with other terms such as e x i t access, the de f i n i t i on may appear in both Chapter 3 and Chapter 5. COMMITTEE ACTION: Accept.

(Log #494) 10] 2 - ( I -6 .4 ) : Accept in Pr inc ip le SUBMITTER: Mike Thompson, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-4 RECOMMENDATION: Reject Proposal ]01-4. SUBSTANTIATION: The term "occupancy subclassiFicat ion" is not defined in NFPA ]01. Both nursery schools and kindergartens are l i s t ed as a type of Educatlonal Occupancy. Are they considered an occupancy subclassiFication? Does the proposal intend that an ex is t ing bui ld ing meet new construct ion requirements i f a bui ld ing is converted From a nursery school to a kindergarten? Unt i l the term "occupancy subc lass i f ica t ion" is adequately defined, i t is recommended the proposal be rejected. COMMITTEE ACTION: Accept in Pr inc ip le .

See action taken on Comment lOt- ] on I -6.4 (Log #493). COMMITTEE COMMENT: The action taken on Comment lOl - I (Log #493) should sa t i s f y the in tent of the Submitter.

(Log #509) lOt - 3 - ( ] - 6 .4 ) : Accept in Pr inc ip le SUBMITTER: Major Hike Daniel, US Army COMMENT ON PROPOSAL NO.: I01-4 RECOMMENDATION: Reject Proposal 101-4, p. 269, TCR. SUBSTANTIATION: In the acceptance of th is proposal, I 'm not sure that the Committee Ful ly considered a l l of the rami f icat ions. This is indeed a s i gn i f i can t change in philosophy from previous edi t lons of the L i fe Safety Code• As an example, consider the fo l lowing scenario:

(Log #232) 101 - 5 (3 2): Accept SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO,: lOt-tO

I RECOMMENDATION: Add the d e f i n i t i o n of "Occuplable Story" as indicated in the TCR. SUBSTANTIATION: The prepr int For Chapter 3 dld not include the de f i n i t i on of occupiable story as c lear ly proposed and accepted by Proposal lOt-tO. COMMITTEE ACTION: Accept.

(Log #449) 101 - 6 - (3-2): Reject SUBMITTER: William E. Kof fe l , Koffel Assoc., Inc. COMMENT ON PROPOSAL NO,: ]01-9 RECOMMENDATION: Insert a new d e f i n i t i o n into Chapter 3 def in ing "Direct Exi t " as Follows:

Direct Ex i t . A d i rect e x i t is an e x i t which serves only one area or level and the d i rec t e x i t has no openings to other areas or levels. SUBSTANTIATION: We di!sagree with the Committee's Comment that the d e f i n i t i o n is inappropriate For Chapter 3. The Subcommittee on Detention and Correctional Occupancies has accepted the d e f i n i t i o n fo r inclusion in Chapters 14 and 15 (Proposal No. 101-536). However, the term d i rec t e x i t is used elsewhere in the Code. Without an indepth research, we have i den t i f i ed the use of the term in Chapters 26, 27 and 28. Since the term is used in other chapters, the d e f i n i t i o n should appear in Chapter 3.

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COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The proposed term "direct ex i t " , which defines a direct and exclusive ex i t , is not unique enough to d i f fe rent ia te between simi lar, but d i f fe rent , terms used within the Code.

The proposed def in i t ion would thus tend to confuse rather than resolve. For example, some occupancy chapters require that the means of egress discharge d i rec t ly outside without passing through other spaces but these requirements do not intend that the res t r i c t i ve meaning, as proposed by the Commenter, be mandated.

(Log #450) I01 - 7 - ( 3 - 2 ) : R e j e c t SUBMITTER: W i l l i a m E. K o f f e l , K o F f e l A s s o c . , I n c . COMMENT ON PROPOSAL NO,: lOl I0 RECOMMENDATION: Rev ise the d e f i n i t i o n For " H i g h Rise B u i l d i n g " t o read as f o l l o w s :

High Rise Building.* A building more than 75 f t I (25 m) in height. Building height shall be measured

L from the primary level of ex i t discharge. Retain the proposed Appendix note, but delete the

Final sentence. Retain the proposed def in i t ion For occupiable story.

SUBSTANTIATION: Whereas the Code determines building height as measured from the primary level of ex i t discharge, the proposed def in i t ion in the TCR does not provide For consistency throughout the Code. Although the Appendix note attempts to address buildings on sloping terrain, the enforceable language is in the de f in i t ion in Chapter 3. Therefore, such buildings would be adversely affected by the def in i t ion .

Chapter 12 currently and as proposed w i l l contain l im i t s on building height as measured in Feet. The height of the building as defined in Chapter 12 and al l other chapters which res t r i c t height in terms of stories is measured From the primary level of exi t discharge. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter's proposed definition is not consistent with other, generally accepted, definitions of high rise buildings. The Committee believes that For l i f e safety purposes i t is not the I overall building height which is important but rather the measurement to the highest occuplable f loor . The proposed def in i t ion would lose the important concept of measuring from the lowest level of Fire department access.

(Log #233) 10l - 8 - (3-2): Reject SUBMITTER: John Behrens, Huntington Besch, CA COMMENT ON PROPOSAL NO.: lO ] - l l RECOMMENDATION: Revise the de f in i t ion of "Mezzanine" to read as follows:

Mezzanine. An intermediate Floor level placed within a room, the aggregate area of which shall not exceed I/3 the open area of the room in which the mezzanine(s) is located. Enclosed space shall not be included in the determination of the size of the room in which the mezzanine(s) is located. SVBSTANTIATION: The Board for Coordination of Model Codes (BQMC) held public hearings on mezzanines subsequent to the Committee on Safety to Li fe meeting. Although much of that report would be considered new business the proposed def in i t ion is e l i g ib le For comment. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The def in l t ion of mezzanine, as shown in the TCR, is adequate. The entire subject, as addressed in detail by the BCMC report, can be handled as new business for a Future Code edit ion.

(Log #71) I01 - 9 - (4-1.2): Accept in Principle SUBMITTER: John M. Watts, J r . , Fire Safety Inst l tu te COMMENT ON PROPOSAL NO.: lOl-17 RECOMMENDATION: List example assembly occupancies in alphabetical order.

SUBSTANTIATION: Th~s is an ed i tor ia l comment. Alphabetizing the l i s t of example assembly occupancies w i l l f a c i l i t a t e i ts use. Alphabetizing the l i s t s of example occupancies may also be appropriate for other sections of Chapter 4. COMMITTEE ACTION: Accept in Principle.

Do as the Commenter has suggested in 4-I .2, but addi t ional ly perform simi lar alphabetical reorderings in the l i s t s of other occupancy examples in 4-1.3, 4-1.5 and 4-1.7 through 4-1.10. COMMITTEE COMMENT: The expansion of the alphabetical reordering throughout applicable portions of Chapter 4 should meet the Commenter's intent.

(Log #234) lOl - lO (4 1.3): Accept SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: I01-18 RECOMMENDATION: Revise 4-I.3 as Follows:

". . . used For educational purposes through the 12th grade by slx or more persons for Four or more hours per day or more than twelve hours per week." SUBSTANTIATION: The proposal did not include the entire text out of Chapter I0 and would have l imited educational occupancies to exactly four hours per day. COMMITTEE ACTION: Accept.

(Log #235) I01 - I I - ( 4 - I . I I ) : Accept in Principle SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO=: I01-24 RECOMMENDATION: In the l i s t of special structures rewse "vehicles f ixed to a foundation" to read "vehicles occupied as a bui lding." SUBSTANTIATION: Proposal I01-907 on 30-1.3.2 and 30-6.1 has revised Chapter 30 regarding vehicles so that they are covered even i f they may not be on a permanently fi~ed Foundation. Chapter 4 needs to be revised to re f lec t this change. COMMITTEE ACTION: Accept in Principle.

Change "vehicles Fixed to a foundation" to "vehicles". COMMITTEE COMMENT: The use of the word "vehlcles", without additional modifiers, is conslstent with the use of the word "vessels" without modifiers. The Code user then refers to Chapter 30 for the necessary detai ls. The Committee Action should sat isfy the Commenter's intent.

(Log #96) lOl - 12 - (S-I .6): Accept ~n Principle SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: lOI-40 RECOMMENDATION: By way of possible ed i tor ia l improvement connect the last three of the four sentences so that they read as follows:

"Where the elevation difference is not more than 21 in. (53.3 cm) the change of level shall be either by a ramp or a s ta i r that complies with 5-2.2; that has minimum tread depths of 13 in. (33.0) cm); and that has the presence and location of each step readily apparent." SUBSTANTIATION: The original proposal, including the Appendix note, is a good one which w i l l control the problem of small elevation differences ~n a Fair and f l ex i b l e manner. The suggested ed i tor la l change mainly prevents any misunderstanding about the stairs to which the 13 in. minimum tread depth applies. The matter of readlly apparent steps is a good general requirement and, while i t has only been proposed here for certain s t a i r s , i t perhaps s h o u l d be t r a n s f e r r e d to g e n e r a l s ta i r requirements in 5-2.2 (either in this edit ion or the next one). COMMITTEE ACTION: Accept in Principle.

See action on Comment I01-13 on 5 1.6, 5 - I .6 . I and 5-1.6.2 (Log #390). COMMITTEE COMMENT: The action taken on Comment I01-13 should sat lsfy the intent of the Submitter.

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(Log #390) lOl - 13 - (5-1.6, 5-1.6.1 and 5 - l . 6 .2 (New), and A-5-1.6): Accept in Pr inc ip le SUBMITTER: Kenneth Bush, Easton, HD COMMENT ON PROPOSAL NO.: lOl-40 RECOMMENDATION: Revise 5 1.6 to read as Follows:

5 - l .6 Changes in Level in Means of Egress. 5 - l . 6 . l Changes of level in means of egress shal l be

by a ramp or a s t a i r where the elevat ion d i f ference is more than 21 in. (53.3 cm).

5 - I .6 .2" Changes in level in means of egress not more than 21 in. (53.3 cm) shall be e i ther by a ramp or by a s t a i r complying with the requirements of 5-2.2, however, the minimum tread depth of the s t a i r shal l be 13 in. (33.0 cm) and the locat ion of each step shal l be readi ly apparent.

Revise the Appendi~ note so that ~t applies to 5-I .6:2. SUBSTANTIATION: As presently wr i t ten i t appears that the minimum tread depth of 13 in. applies to both those s t a i r s more than 21 in . in e l e v a t i o n change and less than 21 in . in e l e v a t i o n change. I do not b e l i e v e t h i s was the i n t e n t o f the Committee due to the s u b s t a n t i a t i o n p rov ided by the Committee. COMMITTEE ACTION: Accept in P r i n c i p l e .

Revise to read as f o l l o w s : 5-1.6 Changes in Level in Means of Egress. 5-1.6.1 Changes in level in means of egress shal l be

by a ramp or a s t a i r where the elevat ion d i f ference is more than 21 in. (53.3 cm).

5-1.6.2" Changes in level in means of egress not more than 2l in. (53.3 cm) shall be e i ther by a ramp or by a s t a i r comply ing w i t h the requ i remen ts o f 5 - 2 . 2 . The minimum t read depth o f such s t a i r s h a l l be 13 in . (33 .0 cm) and the l o c a t i o n o f each step s h a l l be r e a d i l y apparen t .

Revise the Appendix note so t h a t i t a p p l i e s to 5-1 ,6.2. COMMITTEE COMMENT: The Committee agrees with the in tent of the Submitter but has made some e d i t o r i a l improvements.

(Log #400) ]Of - 14 - ( 5 -2 . l . 14 ) : Reject SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: lOI-7l RECOMMENDATION: Revise 5-2.1.14 to read as Follows:

5-2.1.14 Horizontal Sl id ing Doors. 5-2.1.14.1 Horizontal s l id ing doors complying with

5-2. l .14.2 shall be permitted to be used only under the fo l lowing condit ions:

(a) To serve an elevator lobby. (b) When permitted by Chapters 8 through 30 where

serving an occupant load of not more than 30. (C) When permitted by Chapters 8 through 30 in

horizontal ex i ts or in smoke barr iers . 5-2.1,14.2 to read as contained in 5 - Z . l . l q . l o f the

prepr in t . SUBSTANTIATION: Rather than l i s t a series of Exceptions i t would be cleaner and more eas i ly understood to include the permitted locations d i r e c t l y in the new 5-2.1. ]4 . This would el iminate having to add Exceptions as addit ional areas are found fo r the use of these doors and, also, el iminates a long l i s t of Exceptions. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that the present arrangement u t i l i z i n g Exceptions is preferred at the present time.

(Log #401) lOl - 15 - (5 -2 . l .14 .1 (a ) , and (e) and (F) (New)): Reject SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO,: lOl-71 RECOMMENDATION: Revise 5-2.1.14.1 by adding the fo l lowing:

(e) The door assembly shall be approved and l i s t ed . (F) The primary method of opening the door shall be

i n i t i a t e d by a Force applied in the d i rec t ion of egress. Revise part (a) to read: (a) The door shall be operable by an inexperienced

person without special knowledge or e f f o r t .

SUBSTANTIATION: The fact that these doors are r e l a t i v e l y new to the enforcers of the Code, adding a speci f ic requirement For approval and l i s t i n g as o r i g i n a l l y recommended by the proponent would be of a s i gn i f i can t benef i t . In attempting to make th is paragraph generic, the Committee has elimlnated one of the important features of these doors, that being that they are operable by pushing in the d i rec t ion of egress. By delet ing the o r ig ina l proposed "power operated" requirement, th is feature has been el iminated and the Committee is only re ly ing on the backup feature rather than the prlmary Feature. The proposed text puts in a performance statement without requir ing that they be power operated.

Lastly the revisions to part (a) are consistant with the Submitters o r ig ina l material and i t makes i t very clear that these must be operable by inexperienced people. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that the deta i l included in the Commenter's item (F) introduces propr ietary material which the Committee Feels is not needed as a minimum requirement. Part (e) is not needed as a l l equipment needs to be approved and l i s t i n g can be part of such approval. Part (a) 1s adequately covered in the o r ig ina l action of the Committee.

(Log #530) 101 - 16 - (5 -2 .1 ,3 .1 ) : Accept in Pr inc ip le SUBMITTER: Roll Jensen, P.E., James Ante] l , A.I .A, Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-43 RECOMMENDATION: Revise 5-2.1.3.1 to read as Follows:

5 -2 .1 .3 . l No door openlng in the means of egress shall be less than 32 in. in clear width. Where double doors are provided, at least one of the doors shall be a minimum of 28 in. wide . . . . SUBSTANTIATION: The purpose of minimum door sizes is to ensure that occupants can pass through the opening. I t is sometimes necessary to provide two separately sized doors in a doorway. Only one of those doors should have a minlmum width requirement. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise 5-2.1.3. ] to read: 5-2.1.3.1 No door opening ~n the means of egress

shall be less than 32 in. (81 cm) ~n clear width. Where a pair of doors Is provided, at least one of the doors shal l provide a mlnlmum 32 in. (81 cm) clear width opening.

AIso, revise Exception No. 2 to read: Exception NO. Z: In ex is t ing bui ldings the minimum

door width shall be not less than 28 in. (71 cm). COMMITTEE COMHENT: The Committee agrees in general with the Submitter and does agree that a smaller second leaf should be permitted but that one lea f must provide the 32 in. as required by A l l7 .1 .

Exception No. 2 needed to be revised in order to maintain the minimums cur ren t l y contained in the Code.

(Log #398) ]01 - 17 - ( 5 - 2 . ] . 4 . ] Exception No. 4, 5, 6 and 7): Re3ect SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: 10]-49, 50 RECOMMENDATION: Delete Exceptions NO. q, 5, 6 and 7 as shown in the prepr in t and subst i tute the Following:

Exception NO. 4: Horizontal s l id ing doors complying with 5-2.1.14. SUBSTANTIATION: Rather than have a series of Exceptions a l l regarding hor izontal s l id ing doors, i t is recommended that one Exception be provided and that the l im i t a t i ons be provided s p e c i f i c a l l y in 5-2.1. ]4 to include th is materlal w i th in that subsection. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that the present wording is more d e f i n l t i v e and the Exception arrangement is preferred at th is time.

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(Log #2) I01 - 18 - (5-2.1.4.1 Exceptions No. 5 and 6): Accept SUBMITTER: Hal Cohen, Lebanon, PA COMMENT ON PROPOSAL NO.: lOI-Sl RECOMMENDATION: Change Exception No. 5 and No. 6 to Exception NO. 6 and 7. SUBSTANTIATION: Proposal No. 50 provided new Exception 5 and 6. COMMITTEE ACTION: Accept.

(Log #423) I01 - 19 - (5 -2 .1 .4 .2 ) : Accept in Part SUBMITTER: Peter Lamb, East Lyme Fire Marshal's OFFice COMMENT ON PROPOSAL NO.: I01-52 RECOMMENDATION: Revise 5-2.1.4•2 to read as fo l lows:

5-2.1.4.2 During i t s swing, any door in a means of egress shall leave unobstructed at least ha l f of the required width of an a is le , corr idor , passageway or landing. When f u l l y opened, the door shal l not project more than 3 I/2 in. (8.9 cm) into the required width of a landing nor more than 7 in. (17.8 cm) into the required width of an a is le , corr idor or passageway.

Exception: In ex is t ing bui ld ings, a door giv ing access to a s t a i r shal l nei ther reduce the unobstructed width of a s t a i r nor landing to less than 22 in . , nor, when open, project more than 3 I/2 in. (8.9 cm) into the required width of a s t a i r or landing. SUBSTANTIATION: No substant iat ion was provided fo r the increase in allowed s t a i r obstruction from 3 I/2 to 7 in. Stairs are already allowed to have handrai ls obstruct by 3 I /2 i n . , the increase for doors from 3 I/2 to 7 in. would then have a to ta l obstruct ion of approximately I0 I /2 in. This is unacceptable without addi t ional documentation. This comment essent ia l l y reverts to the present Code text with some ed i t o r i a l clean-up. In addi t ion, the Exception has been revised to delete the terms unl t of ex i t width due to other changes in Chapter 5 and has c l a r i f i e d that i t was not the intent to be more str ingent in ex is t ing bui ldings regarding the door in the Ful ly opened posi t ion. COMMITTEE ACTION: Accept in Part.

Do not revise 5-2.1.4.2 as recommended by the Submitter but revise the Exception to read as fo l lows:

Exception: In ex is t ing bui ld ings, a door giv ing access to a s t a i r shal l neither reduce the unobstructed width of a s t a i r nor landing to less than 22 in. (55.9 cm), nor, when open, project more than 7 in. (17.8 cm) into the required width of a s ta i r or landing. ~MMITTEE COMMENT: The Committee agrees that the Exception needs to be revised and has done that. However, the Committee feels that the 7 in. (17.8 cm) provision is not a problem due to the way people move on s ta i r landings.

COMMITTEE ACTIO__N: Reject. COMMITTEE COMMENT: This comment introduces new business which has not had publ ic review•

(Log #399) lOl - 22 - (5-2 .1 .5 .3) : Accept SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: I01-58 RECOMMENDATION: Revise the t h i r d sentence to read as Follows:

"Egress doors from indiv idual l i v i n g uni ts and guest rooms of res ident ia l occupancies may be provided with devices which require not more than one addi t ional releasing operation such as a n igh t la tch , deadbolt or security chain provided such device is operable From the inside without the use of a key or tool and is mounted at a height not to exceed 48 in. above the Finish Floor.

Exception: Exist ing Security devices shall not exceed 60 in. (153 cm) in height above the Finished f l oo r and shall be permitted to have two addi t ional releasing operations." SUBSTANTIATION: There is presently hardware read i l y avai lable which allows the use of a deadbolt secur i ty device which ~s retracted automatical ly when the latch is retracted. Therefore, only one addi t ional releasing device is necessary, that For the secur i ty chain or s im i la r item. Since many ex is t ing bui ldings have a l a t ch re lease , a deadbol t r e l ease and a s e c u r i t y cha in , the Except ion would a l l ow t h i s to cont inue as the o r i g i n a l 5 -2 .1 .5 .3 would have a l l owed . COMMITTEE ACTION: Accept.

(Log #292) I01 - 23 - (5-2 .1 .5 .3" ) : Accept in Pr inc ip le SVBMITTER: T. Daly/H. Moore, H i l ton Hotels Corp. COMMENT ON PROPOSAL NO.: lOl 58

I RECOMMENDAT_ION: AFter the second use of the word "operation", add "Exceptlon I: and renumber "Exception" to read "Exception 2." SUBSTANTIATION-: The language being added is an obvious Exception to the general requirement For doors w i th in means of egress. COMMITTEE ACTION: Accept in Pr inc ip le .

I Insert "Exception" a f te r "operat ion" as recommended but make the present exceptions a cont inuat ion of the "new" exception. COMMITTEE COMMENT: The ~ntent of the present exception is to apply only to those s i tuat ions covered in the new exception, to make i t an Exception No. 2 would s i g n i f i c a n t l y expand ~t without j u s t i f i c a t i o n .

*See draft.

(Log #l) lOl - 20 - (5-2.1.4.2 Exception): Reject ~UBMITTER: Hal Cohen, Lebanon, PA C_OMMENT ON PROPOSAL NO~: I01-52 RECOMMENDATION: Change Exception to read:

• . . reduce the unobstructed width Of a s t a i r or landing fo r more than 50 people . . . . " SUBSTANTIATION: "Units of ex i t " are being deleted. "50 people" appears to be a popular number with the Code wr i te rs . COMMITTEE ACTION: Reject. C~OMMITTEE COMMENT: See Committee Action on Comment lOl-19 on 5-2.1.4.2 (Log #423).

(Log #97) I01 - 24 - (5-2 .1 .9 .1) : Accept SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: 101-65 RECOMMENDATION: Ed i to r ia l Comment: Should the parenthetical cross reference be to 5-2.1.4.2 rather than 5-2.1.4.1? SUBSTANTIATION: I f the cross reference is supposed to deal w~th width of opening, the correct reference is 5-2.1.4.2. (The 1985 ed i t ion has the same reference to 5-2.1.4.1. ) COMMITTEE ACTION: Accept.

(Log #330) lOl - 21 - (5-2.1.4.2 Exception No. 2 (New)): Reject $UBMITTER: John G. Degenkolb, National Assn. of Theatre Owners COMMENT ON PROPOSAL NO.: I01-52 RECOMMENDATION: Add an Exception No. 2 to read:

Exception No. 2: Doors accessing normally unoccupied areas. SUBSTANTIATION: A theater chain operating in the Prince George area of Maryland found that the L i fe Safety Code had been amended to make the suggested change.

(Log #99) lOl - 25 - (5-2.2.2) : Reject SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-83 RECOMMENDATION: The reorganizat ion is useful but incomplete. The ex is t lng 5-2.2.4.3 also deals with dimensional c r i t e r i a that could go into 5-2.2.2 and th is move would be most e f f ec t i ve i f i t includes the moving of minimum width of s ta i rs and landings out of the table and into a 5-2.2.2 section headed "S ta i r Width and Landing Dimensions."

273

A related reorganization is to renumber what l i t t l e is l e f t of the miscellaneous s ta i r detai ls in 5-2.2.4 as 5-2.2.3. Also number 5-2.2.6, 5-2.2.7 (Guards and Handrails) to Follow 5-2.2.3 to keep detai ls of similar scale together. This leaves the related but separated requirements of the existing 5-2.2.3 and 5 2.2.5 together and able to go immediately before 5 2.3. SUBSTANTIATION: Section 5-2.2 needs further reorganization to put related requirements closer together. Because i t is a l l ed i to r ia l , i t should be possible for the 1988 edition as a logical adjunct to organizational changes already proposed in the TCR. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that the entire section should be thoroughly reviewed and reorganized as needed rather than a patchwork approach.

(Log #424) 101 - 26 - (5-2.2.2.3 Exception (New)): Accept $UBMITTER: Peter Lamb, East Lyme Fire Marshal's Office, CT COMMENT ON PROPOSAL NO.: I01-75 RECOMMENDATION: Add the following Exception:

Exception: Existing curved stairs may be continued in use provided the minimum depth of tread is I0 in. and the smallest radius is not less than twice the s ta i r width. SUBSTANTIATION: There may be exist ing curved stairs that do not comply with this revised text and the Exception is taken From the present Code. COMMITTEE ACTION: Accept.

(Log #98) 10l 27 - ( 5 - 2 . 2 . 2 . 3 and A 5 - 2 . 2 . 2 . 3 ) : Accep t SUBMITTER: Jake Pau l s , Nheaton , HD CO HMENT ON PROPOSAL NO~: 101-76 RECOMHENDATION: E d i t o r i a l c o r r e c t i o n s :

In t he second s e n t e n c e , the word " p l a n s " s h o u l d be "planes".

In the Appendix note, the figures are out of order and mislabeled.

Figures (b) and (d), as designated in the TCR, should be labeled (a) and (b) under the heading "RISER MEASUREMENTS," Figures (a) and (c) should be labeled (c) and (d) under the heading "TREAD DIMENSIONS." SUBSTANTIATION: Corrections to typo and edi tor ia l errors. COMMITTEE ACTION: Accept.

(Log #229) I01 28 (5 2.2.3.1 and 5 2.2.3.5): Reject SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-79 RECOMMENDATION: Add to proposed language after the First use of the word "landing" the Following:

". . . below the level of exi t discharge". SUBSTANTIATION: Satisfy the concerns regarding stairways below the level of discharge without requiring a pro l i fe ra t ion of signs throughout a l l stairways. No evidence has been provided to indicate a d i f f i c u l t y in understanding the need for" downward movement when occupying upper levels of buildings. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that the information provided on these signs is very useful at a low cost. The present Code requires the signs and this has not been proposed to be changed. The direct lon to the exi t discharge is the new inFormat}on belng requested and is an important enhancement to the use of the stairs at time of an emergency. This comment would eliminate all signs above the level of exit discharge.

(Log #391) 101 - 29 - (5 2.2.3.2): Accept SUBMITTER: Kenneth Bush, Easton, MD COMMENT ON PROPOSAL NO.: 101-80 I RECOMMENDATION: Revise the three diagrams to c l a r i f y where the protection is and is not required. SUBSTANTIATION: The present diagrams are not clear as to where the protection is and is not required and should be c la r i f i ed i f they are to serve as a useful Appendix note. COMMITTEE ACTION: Accept.

Secretary's Note: The three revised diagrams Follow:

No protecuon required

F i g u r e A - 5 - 2 . 2 . 3 . 2 ( a )

T l O f t P

Prolectton requtred

No prolect~on required

Figure A-5-2.2.3.2(b)

J / / j J ' , ,, / j , / / / .....

( /" ~ , ' I , i (' i / " /

l//,! Z ~ Protection required

F i g u r e A - 5 - 2 . 2 . 3 . 2 ( c )

274

(Log #228) I01 - 30 - (5-2.2.6.1 and 5-2.2.6.2): Reject ~UBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO~: I01-86 ~ECOMMENDATION: Return to Committee for Further study. SUBSTANTIATION: Thir ty in. (30") height is not substantiated. Di f fers from OSHA requirement, see OSHA regulations 29 CFR 1910.23a. (Supporting material is available for review at NFPA Headquarters.) COMMITTEE ACTION: Reject. ~OMMITTEE COMMENT: Proposal 101-86 was an edi tor ia l reformatting. The 30 in. vert ical distance between surfaces before a guard being required is not a change from the pr ior edit ion of the Code. This paragraph does not address guard height (see 5-2.2.6.6 in draf t ) . The 30 ~n. in 5-2.2.6.2 came from proposal 101-88 and is the distance to reach a handrail which is well j us t i f i ed by NRC research.

(Log #103) 101 - 34 - (5-2.2.6.5): Accept $UBMITTER: Jake Pauls, Wheaton, MO COMMENT ON PROPOSAL NO,: I01-94 RECOMMENDATION: Leave the existing text the way i t is, permitting the lower guard height only within dwelling units. SUBSTANTIATION: There is poor technical j us t i f i ca t i on For a reduced-height guard in residential situations and the substantiation ( " i t is Felt that this should be allowed") is not meaningful. With increased height requirements coming in for handrails, i t is also worthwhile reconsidering guard heights. Refusal to adopt the broadened use of the lower guards may help encourage BCMC to have a harder look at guardrail geometry. The research evldence supports guard heights of 42 in. COMMITTEE ACTION: Accept.

(Log #102) lOl - 31 - (5-2.2.6.4): Accept in Principle SUBMITTER: Jake Pauls, Wheaton, HD COMMENT ON PROPOSAL NO.: I01-92 RECOMMENDATION: Editorial correction:

Proposal I01-92 recommends adding proposed text (to existing text ) , however the preprlnt of Chapter 5, provided in the TCR, does not include the existing text which is "New handrails shall be designed to be continuously graspable along the entire length." This existing sentence should not be dropped; i t includes the valuable requirement about graspability along the f u l l length of the handrail. SUBSTANTIATION: Editorial correction to preprint. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment 101-33 on 5-2.2.6.4(d) (Log #236). COMMITTEE CQHHENT: The action taken on Comment 101-33 (Log #236) should sat is fy the intent of the Submitter.

(Log #lO0) 101 - 32 - (5-2.2.6.4 Exception NO. 3 to (a)): Reject SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-90 RECOMMENDATION: The BCHC recommendation included an additional Exception, also supported by the research noted in the TCR. This Exception is recommended for inclusion here:

Exception No. 3 to (a): Handrails that Form part of a guardrail may be 42 in. (107 cm) high. SUBSTANTIATION: I believe that this was inadvertently missed during the incorporation of the BCMC recommendation by the Subcommittee and Technical Committee. In any event, because adding i t causes no hardship, i t can be added at the TCD stage. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This comment presents new material which has not had public review.

(Log #236) lOl - 33 - (5-2.2.6.4(d)): Accept SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: 101-92 RECOMMENDATION: The original proposal c lear ly indicates that the terms, "handrails shall have a c i rcular cross section with an outside diameter of at least 1.25 in. (3.2 cm) and are not greater than 2.0 in. (5.1 cm)" was to be added to the existing 5-2.2.6.4. However, i f one looks at the preprint of Chapter 5 on page 475 of the TCR the material was substituted for the existing text. The following terms are to be included in 5-2.2.6.5(c):

"New handrails shall be continuously graspable along the entire length." SUBSTANTIATION: AS indicated in the comment, the preprint has not appeared to do what the original proposal requested be done and this comment is intended to c l a r i f y this. COMMITTEE ACTION: Accept.

(Log #227) lOl - 35 - (5-2.3.9.2): Accept SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: I01-I01 RECOMMENDATION: Reword subparagraph l to read:

I. Exterior to the building and be d i rect ly connected to the stairway by ductwork enclosed in noncombustible construction o r . . . . SUBSTANTIATION: I f ductwork is exter ior to the building there is no jus t i f i ca t ion for requiring Fire resist ive construction. COMMITTEE ACTION: Accept.

(Log #531) lal - 36 - (5-2.3.9.2): Reject SUBMITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: IO]-lO} RECOMMENDATION: Reject Proposal lOl ]Ol. SUBSTANTIATION: This proposal requires isolation of pressurized stai r mechanical equipment From the remainder of a building. No record of previous f i res has been included in the proposal. In some buildings, this isolation may use up c r i t i ca l Space. For a requirement l ike this to be added to the Code, some jus t i f i ca t ion should be included. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that the integr i ty of the sta i r needs to be assured. (See 5-I.3.1.) A new exception to 5-I.3.1 w i l l allow these penetrations but the Committee Feels these precautions are needed to go with this new permission. Also see Comment I01-35 on 5-2.3.9.2 (Log #227).

(Log #374) 101 - 37 - (5-2.3.9.2 Exception (New)): Accept in Principle SUBHITTER: T. Oaly, American Hotel and Hotel Assn. COMMENT ON PROPOSAL NO:: I01-I01 RECOMMENDATION: Add new wording af ter paragraph No. 3 to read:

Exception: Where the building, including the stairway enclosure is protected by an automatic and supervised sprinkler system in accordance with Section 7-7, Fire rated construction may be reduced to noncombustible construction. SUBSTANTIATION: Stairways are often not requlred to be sprinklered (NFPA 13, Section 4-4.8.2), thus the need for more extensive Fire resist ive construction. This Exception would allow the design option to either" provide the 2 hour construction for enclosure of this equipment and ductwork or provide sprinkler protection For the entire stairway. COMMITTEE ACTION: Accept in Princlple.

Add an exception to read: Exception to (3): Where the bullding, including the

stairway enclosure, is protected throughout by an approved supervised automatic sprinkler system in accordance with Section 7-7, f i r e rated construction may be reduced to l -hr construction.

275

COMMITTEE COMMENT: The Committee agrees that some reduction should be permitted for sprinkler protection but does not feel that total elimination should be allowed as th~s room is d i rect ly connected to the sta i r enclosure by duct work. Other revisions are edi tor ia l to c l a r i f y the exception.

(Log #383) lot - 38 - (5-2.3.12.1 (New)): Reject $UBMITTER: Vic Humm~ Vic Humm & ASSOC. COMMENT ON PROPOSAL NO.: IOI-N/A RECOMMENDATION: Add new paragraph 5-2.3.12.1 as Follows:

5-2.3.12.1 The fuel tank shall be sized to permit required testing of the standby power For a period of six months with the minimum of two hours of Fuel in reserve at the end of this period. SUBSTANTIATION: This w i l l permit the building owner to conduct normal maintenance and minimize the extra handling of fuel. The typical requirement for Fuel as outlined in NFPA 20 For Fire Pumps and NFPA llO For generators is one gallon per hour per horsepower.

The typical test is 30 minutes per week or 13 hours in a 26 week perlod. I f the engine generator was 30 horsepower this would be 390 or 250 is standard size home type Fuel tank.

Otherwise for a two hour period only a 60 gallon tank would be required. Then each week For testing the owner would have to add IS gallons of Fuel to the tank. Typically this would not be done. ~OMMITTEE ACTION: Reject. ~OMMITTEE COMMENT: This comment Introduces new material which has not had public review. In addltion, the Committee Feels that this is outside the scope of the document.

(Log #532) I01 - 39 - (5-2.4.3.1): Reject ~UBMITTER: Roll Jensen, P.E., James Antell,. A.I.A, Roll Jensen & Associates, Inc. C~QMMENT ON PROPOSAL NO.: lOt-106 RECOMMENDATION: Revise 5-2.4.3.1(c) to read:

(c) All required exits other than horizontal exits, shall discharge in accordance with Section 5-7. ~UBSTANTIATI~: Section S-7 permits some exits to terminate on the First Floor ~f some basic safeguards are provided. I f a horizontal exi t is provided on an upper Floor, separated From the f~rst Floor by 2 hour construction, there is no need to adjust the sta i r discharge provisions of Section 5-7. ~_QMMITTEE ACTION: Reject. ~O_MMITTEE COMMENT: See Committee Comment on 101-40 on 5-2.4.3.1(c) (Log #226).

(Log #226) 101 - 40 - (5-2.4.3.1(c)): Reject SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: lOt-t06 RECOMMENDATION: Revise Committee Action for paragraph "(c)" to read:

(c) All required exits, other than horizontal exits, shall discharge in accordance with Section 5-7. ~UBSTANTIATION: In existing buildings where additional protection is being afforded via the insta l la t ion of horizontal exits, the building should not be further penalized by requiring Further modifications For vert ical exits, since existing S-7 would not require a l l exits to discharge d i rec t ly to the outside. COMMITTEE ACTION: Reject. ~OMMITTEE COMMENT: The present Exceptions do require exits to discharge to the outside, see 5-2.4.3.1 Exception No. 2(b) and Exception No. 3(b). The Committee feels this is needed and deletion would violate the concept of the safety of horizontal exits.

(Log #225) 101 - 41 - (5-2.4.3.5): Reject .SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-I09 RECOMMENDATION: Amend last sentence to read:

"Horizontal exi t doors located across a corridor shall be automatic or self-closing in accordance with 5-2.1.8." SUBSTANTIATION: To be "automatic closing" only as proposed would require the doors to be normally open. This condition is too res t r i c t i ve since the normal position of doors across corridors may vary based on the occupancy. This is an occupancy dependent condition which should be addressed individual ly in Chapters 8-30. COMMITTEE ACTION : Reject. COMMITTEE COMMENT: Nothing in the proposal prevents automatic closing doors from being kept closed. The intent of this is to prevent the door from being improperly held open. For existing buildings see Comment I01-43 on 5-2.4.3.5 Exception (Log #425).

(Log #533) I01 - 42 - (5 2.4.3.5): Reject SUBMITTER: RolF Jensen, P.E., James Antell, A.I.A, Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: lOt-t09 RECOMMENDATION: Delete the third sentence. SUBSTANTIATION: A requirement for automatic closing doors in l ieu of self-closing doors is not reasonable. I t presupposes that the building owner w i l l ignore code r e q u i r e m e n t s by b l o c k i n g doors open. There a re many instances of horizontal exits where the cross-corridor doo rs rema in n o r m a l l y open. To r e q u i r e a u t o m a t i c c l o s e r s on h o r i z o n t a l e x i t d o o r s , and no t on o t h e r e x i t d o o r s , i s no t c o n s i s t e n t . COMMITTEE ACTION: R e j e c t . COMMITTEE COMMENT: See Commi t tee Comment on 101-41 on 5 - 2 . 4 . 3 . 5 (Log #225) . A l s o see Commi t tee A c t i o n on Comment I 0 1 - 4 3 on 5 - 2 . 4 . 3 . 5 E x c e p t i o n (Log #425) f o r e x i s t i n g i n s t a l l a t i o n s .

(Log #425) I01 - 43 - (5-2.4.3.5 Exception (New)): Accept in Principle SUBMITTER: Peter Lamb, East Lyme Fire Marshal's Office, CT COMMENT ON PROPOSAL NO=: lOl 109 RECOMMENDATION: Add an Exception to read as follows

Exception: Where speci f ica l ly approved by the authority having jurisdiction existing doors on horizontal exits may be self-closing rather than automatic closing. SUBSTANTIATION: There are many existing horizontal exits that have been installed as, and maintained as self-closing without problems of being wedged open. I f the authority having jur isdict ion feels that the history of the door has been such that wedges have not been a problem, they should be allowed to be continued in use as self-closing doors. COMMITTEE ACTION: Accept in Principle.

Revise the Exception to read as Follows: Exception: When approved by the authority having

Jurisdiction exlsting doors in horizontal exits may be self-closing. COMMITTEE COMMENT: The Committee concurs with the intent of the Submitter and has made additional editorial improvements.

(Log #104) 101 - 44 - (5-3.3.1.I): Accept ~UBHITTER: Jake Pauls, Wheaton, MO COMMENT ON pROPOSAL NO.: I01-122 RECOMMENDATION: Revise "Ramps" to be "Class A Ramps" in the heading for second column of the new table and add a new sentence, 5-3.3.1.I:

5-3.3.1.1 For Class B ramps used for ascent, the width per person shall be increased by I0 percent, beyond what is required for Class A ramps. Widths for Class B ramps used for descent, shall be calculated the same as For Class A ramps.

276

SUBSTANTIATION: When BCMC introduced the l inear formula, a l l ramps were treated the same despite the t rad i t i ona l use of f a i r l y d i f f e r e n t capacity rules F o r Class B ramps in NFPA 101 and 102. Steeper ramps do not work as e f f e c t i v e l y but t he i r performance is better than formerly assumed in NFPA lOl and 102. For ascent uses, NFPA 102-1986 gives Class B ramps only 90 percent of the capacity given to Class A ramps and the suggestion given here is f a i r l y s im i la r . However, because the capacity rules are Far from ref ined, there may be a good case For simply t reat ing a l l ramps (of slope not exceeding l in 8) the same. On the other hand, reta in ing at least some of the t r ad i t i ona l d i f ference might encourage a more complete technical assessment of the matter (beyond what is noted in John Fruin 's book, "Pedestrian Planning and Design," giv ing some support f o r a 10 percent d i f fe rence) . COMMITTEE ACTION: Accept.

(Log #528) I01 - 45 - (5-4): Reject SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: I01-124 RECOMMENDATION: Retain concept of minimum number of ex i ts as well as minimum number of means of egress. SUBSTANTIATION: The tex t as proposed by the Subcommittee w i l l no longer establ ish minimum number of ex i t s . This could po ten t i a l l y l e t a two or three story bui ld ing ex is t with no ex i ts on the upper f l oo rs , only e x i t access which, in the past has not been allowed. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that 5 4 . ] .2 adequately covers th is . The Commenter has not provided any speci f ic wording to c l a r i f y his in tent .

(Log #534) lOl - 46 - (5-4.1.2) : Accept SUBMITTER: RolF Jensen, P.E., James An te l l , AIA, Roll 3ensen & Associates, Inc. COMMENT ON PROPOSAL NO~: I01-124 RECOMMENDATION: Revise 5-4 . ) .2 to read as Follows:

5-4.1.2 The minimum number of separate and remote means of egress From a l l f loors or port ions thereof shal l be as fol lows:

(Remainder as pr inted) SUBSTANTIATION: The number of ex i ts should be based on f l o o r occupant load, not bui ld ing occupant load. This would be consistent with the other codes. COMMITTEE ACTION: Accept.

(Log #53) I 0 1 - 47 - (5-4.1.2 Exception): Reject SUBMITTER: John M. Watts, J r . , Fire Safety I ns t i t u t e COMMENT ON PROPOSAL NO~: I01-124 RECOMMENDATION: In the Exception, delete the words "Exis t ing bui ld ings". SUBSTANTIATION: While in pract ice most such E<ceptions w i l l be in ex is t ing bui ld ings, i t is presumptuous and overly r e s t r i c t i v e to preclude occupancy oriented exceptions For new bui ld ings. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that there is a s i gn i f i can t hardship fo r ex is t ing bui ldings and that the exception is warranted, but that in n e w construction the requirement is not d i f f i c u l t to comply with. The Submitter provided no examples of occupancies where an exception is needed.

(Log #224) IOl - 48 - (5 -¢ . I .2 Exception): Reject SUBMITTER: T. Daly/H. Moore, Hi l ton Hotels Corp. COMMENT ON PROPOSAL NO.: I01-124 RECOMMENDATION: Delete the word "ex i s t i ng " as proposed. SUBSTANTIATION: Will al low occupancy chapters more f l e x i b i l i t y in determining number and locat ions of ex i t s . Disagree with ra t iona le of Committee that "most bui ld ing codes require t h i s . " While th is statement may be true fo r places of assembly, i t is not true For high

r i se hotels which may have an occupant load of more than 500 but may s t i l l have two means of egress. The change has not been substantiated with any evidence to indicate that occupant load greater than 500 in a spr inklered high r ise bui ld ing (as w i l l be required under th is Code) with two ex i ts has proven to be a problem For proper ex i t i ng . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See action on Comment I01-47 on 5-4.1.2 Exception (Log #53).

(Log #535) lOl - 49 - ( 5 - 4 . l . 3 ) : Accept SUBMITTER: Roll Jensen, P.E., James An te l l , A. I .A, Rol l Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-12G RECOMMENDATION: Revise 5-4.1.3 to read as fo l lows:

5-4.1.3 Where ex i ts serve more than one story, only the occupant load of each story considered i n d i v i d u a l l y need be used in computing the number of ex i ts at that story, provided that the required number of ex i ts shal l not be decreased in the d i rec t ion of e x i t t r ave l . SUBSTANTIATION: I t is the in tent of the Committee that the number of required ex i ts From a story not be decreased in the d i rec t ion of ex i t t rave l . I t is possible to decrease the number of ex i ts from a story while s t i l l maintaining the required number of ex i ts and the required ex i t width. The comment should be raised to include the wording "the required number of ex i ts shall not be decreased in the d i rec t ion of ex i t t r ave l " . COMMITTEE ACTION: Accept.

(Log #536) I01 - 50 - (5-5.1.4) Reject SUBMITTER: Roll Jensen, P.E., James An te l l , A. I .A, Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: lOl-130 RECOMMENDATION: Reject Proposal I01-130. SUBSTANTIATION: The proposal would move the " I /2 diagonal dimension" ru le to the body of the Code. While th ls is a reasonable guidel ine, there are many instances where s t r i c t enforcement of the ru le is not necessary. Of f ice bui ld ing cores often have s ta i r s at each s~de of the core and provide a reasonable separatlon between them. Use of the I /2 diagonal dimension rule often makes the core Far less e f f i c i e n t whi le adding no safety to the occupants of the bu i ld ing. COMMITTEE ACTION: Reject. COMMITTEE COMMENT; The Committee feels that th~s provis ion has been successfully used by both ICBO and BOCA and agrees with the BCMC recommendation. The ru le establishes a speci f ic quant i f i ca t ion For "reasonably remote" which w i l l assist designers as well as enforcers. Also see action on Comment lOl-51 on 5-5.1.4 Exception (Log #8).

(Log #8) I01 - 51 - (5-5.1.4 Exception (New)): Accept in Pr inc ip le SUBMITTER: Bertram M. Vogel, Schirmer Engineering Corp. COMMENT ON PROPOSAL NO.: lOl-130 RECOMMENDATION: At end of F i rs t paragraph add new Exception as Follows:

Excep t ion : In buildings equipped throughout with a n approved automatic spr ink ler System, the minimum separation distance between two ex i ts or e x i t access doors shall be not less than I /4 the length of the maximum overal l diagonal dimension of the bu i ld ing or area to be served, measured in a s t ra igh t l i ne between ex i t s . SUBSTANTIATION: The reason For establ ishing a minimum distance of remoteness between ex i ts was to enhance the chances that in case of a Fire on a f l o o r at least one e x i t would be avai lable For use. In a bu i ld ing equipped throughout with an approved automatic spr ink le r system, the chances of a Fire negating the use of an e x i t is substant ia l ly reduced and accordingly the distance between ex i ts does not have to be as great as fo r a bu i ld ing not equipped with an automatic ext inguishing system.

277

qOMMITTEE ACTION: Accept in Pr inc ip le . At the end of the f i r s t paragraph add a new exception

to read as fo l lows: Exception: In bui ldings protected throughout by an

approved automatic spr ink ler system in accorda@ce with Section 7-7, the minimum separation distance between two ex i ts or e x i t access doors shal l be not less than I/3 the length of the maximum overal l diagonal dimension of the bui ld ing or area to be served measured in a s t ra igh t l ine between ex i ts . qOMMITTEE COMMENT: The Committee concurs that some reduction is j u s t i f i e d for spr inklered bui ldings but that a 50 percent reduction is excessive. Several examples were provided to the Committee, a l l could comply with a I/3 and, therefore, a reduction to I/3 ~s being recommended.

(Log #222) I01 - 52 - (5-5.1.4 Exception (New)): Reject $UBMITTER: T. Daly/H. Moore, Hi l ton Hotels Corp. COMMENT ON PROPOSAL NO,: lOt 130 RECOMMENDATION: Add Exception:

Exception: In bui ldings protected by automatic spr ink le r systems in accordance with Section 7-7, separation between s ta l rs may be reduced to a one hour f i r e resistance ra t ing. SUBSTANTIATION: Where the shaft surrounding both in ter lock ing stairways is two hour constructlon and the bui ld ing is sprinklered (as proposed above), there is no justification For the intervening separation between stairs tO be two hour construction. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This comment addresses material that was not addressed by the Technical Committee Report and is not eligible for comment.

(Log #426) 101 - 53 - (5-5.1.5 (New)): Accept in Part SUBMITTER: Peter Lamb, East Lyme Fire Marshal's OFFice, CT qOMMENT ON PROPOSAL NO.: I01-130 j RECOMMENDATION: Add a new S-5.1.S to read the same as the present 5-5.1.4 r~ther than adding i t to the end of the proposed 5 5 . I .4 .

AIso, add an Exception to the new 5-5.1.5 to read as Follows:

Exception: Exist ing pipe penetrations which are sealed in an approved manner. SUBSTANTIATION: Many e x i s t i n g s c i s s o r s t a i r s have standpipes which run up and interconnect the s ta i r s . I f these are sealed properly, they should be allowed to continue in use. COMMITTEE ACTION: Accept in Part.

j Do the r e o r g a n i z a t i o n as proposed by the Submi t ter but do not add the Except ion. COMMITTEE COMMENT: The Committee agrees w i t h the reorganization but the proposed Exception presents new material which has not had public review.

(Log #537) I01 - 54 - (5 5.1.6) Reject SUBMITTER: Rolf Jensen, P.E., James An te l l , A . I .A . , Roll Jensen & Associates, Inc. qOMMENT ON PROPOSAL NO.: I01-133 RECOMMENDATION: Revise F i rs t sentence to read:

5-5.1.6 Egress From rooms or spaces may open into adjoining or intervening rooms or areas, provided such adjoining rooms contain low hazard or ordinary hazard contents (see 4-2.2) and the rooms provide a d i rec t means of egress to an ex i t .

(Remainder as pr inted) SUBSTANTIATION: To require the intervening room to be accessory to the room served w i l l severely l i m i t the use of the concept. Is a large open plan o f f i c e area accessory to a small corner o f f i c e or conference room? Most bui ld ing o f f i c i a l s would say i t is not accessory and would proh ib i t access through the space. This was not the or ig ina l inbent of the intervening room concept.

COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The provisions fo r low or ordinary hazard are already covered in 5-5.1.6. The Submitter is an t ic ipa t ing a problem with regard to "accessory" which the Committee does not feel w i l l be a problem.

(Log #54) I01 55 - (5-7.2) : Accept in Part in Pr inc ip le SUBMITTER: John M. Watts, J r . , Fire Safety I ns t i t u t e COMMENT ON PROPOSAL NO.: I01 140 RECOMMENDATION: Revise to read:

"A maximum of 50 percent of the required ex i t capacity may discharge through a single area . . . . " SUBSTANTIATION: Wordlng of Proposal I01 140 is l o g i c a l l y incorrect• I t ~mplies that when the specif ied condit ions are not met a l l ex i t s may discharge through areas.

Wording of Proposal I01-140 obscures rather than c l a r i f y s in tent . Precluding discharge through separate, protected areas does not seem defensible (e.g. , in the L i fe Safety Code Handbook, (1985) p. 154, Figure 5 45a, i f the s ta i rwe l l at the bottom of the Figure were not present would th is be an unacceptable conf igurat ion?) COMMITTEE ACTION: Accept in Part in Pr inc ip le .

Revise to read: "A maximum of 50 percent of the required number of

ex i ts and 50 percent of the required e x i t capacity shall be permitted to discharge through areas on the

COMMITTEE COMMENT: The wording as o r i g i n a l l y proposed was intended to c l a r i f y the 50 percent c r l t e r i a . The Submitter did point to a potent ia l confusion of in tent ; however, the Committee st111 wishes to c l a r i f y the 50 percent r e s t r i c t i o n . With regard to the single area the Committee feels that th~s is new bus~ness. The Committee does believe that 50 percent of the ex i ts do need to terminate at the outside.

(Log #538) 101 - 56 - (5-7.2) : Accept in Pr inc ip le SUBMITTER: RolF Jensen, P.E., Jame Ante l l , A . I .A . , Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: lOl-14O RECOMMENDATION: Revise f i r s t sentence as Follows:

5-7.2 A maximum of 50 percent o f the number and 50 percent of the capacity of ex i t s .

I t appears that the th i rd change should be to item l of the E~ceptlon to (c) rather than item 2. SUBSTANTIATION: Ed i t o r l a l . COMMITTEE ACTION: Accept in Pr inc ip le .

See action on I01 55 on 5 7.2 (Log #54) and the Committee agrees that the th i rd change should have been to Item I of the Exception to (c) rather than Item 2. COMMITTEE COMMENT: The action taken by the Committee on Comment I01-55 (Log #54) should sa t is fy the in tent of the Submitter.

(Log #518) I01 - 57 - ( 5 - I 0 ) : Accept in P r l n c i p l e SUBMITTER: Technical Committee on F i resage ty Symbols COMMENT ON PROPOSAL NO.: 101-150 RECOMMENDATION: Reconsider NFPA 171 i n c o r p o r a t i o n in the L i f e Sa fe ty Code as a p p r o p r i a t e . SUBSTANTIATION: NFPA 171, Standard For Publ ic F i r e s a f e t y Symbols, was issued by the NFPA Standards Counci l on June I I , 1986, w i th an e f f e c t i v e date o f Ju l y I , 1986. The Scope o f NFPA 171 is t ha t o f s p e c i f y i n g symbol graph ics For v i sua l a l e r t i n g o f bu i l d i ng occupants dur ing F i re and r e l a t e d l i f e s a f e t y emergencies. NFPA 171 does not address the a p p l l c a t i o n of symbol graphics. COMMITTEE A~TION: Accept in P r i n c l p l e .

Add the f o l l o w i n g appendix notes. A -5 - I 0 .2 When graph ics are used, the symbols o f NFPA

171, Publ ic F i r e s a f e t y Symbols should be u t i l i z e d . Such sign needs to provide equal v i s i b i l i t y and i l l um ina t ion and comply with the other requirements of Section 5-10.

A -5 - I0 . I . 4 see A-5-I0.2. A-5-I0.4.1 see A-5 I0.2. A-5-I0.4.2 see A-5-10.2.

278

COMMITTEE COMMENT: The Committee feels that NFPA 171, Public Firesafety Symbols, does need to be recognized by the Code but feels that an appendix note is the best F i rs t step. Further information on sign size and on color with respect to internal i l l umina t ion needs to be provided p r io r to a spec i f ic code reference being made.

(Log #223) IOl - 58 - ( 5 - I0 .1 . I Exception): Accept SUBMITTER: T. Daly/H. Moore, Hi l ton Hotels Corp. ~HMENT ON PROPOSAL NO.: lOl-I51 RECOMMENDATION: Add a period a f te r the word "ex i t s " and delete the remainder of the sentence. sUBSTANTIATION: Language is redundant since AHJ's already have th is l a t i t ude . COMMITTEE ACTION: Accept.

(Log #198) I01 - 61 - (5-10.3.1" and 5-10.3.4): Reject SUBMITTER: R.H. Minter, Chloride Systems COMMENT ON PROPOSAL NO.: I01-153 (s ic ) lEd: 101-149] RECOMMENDATION: Revise to read:

5-10.3.1" Every sign required by 5 - I 0 . I . 2 . 5- I0 .1 .3 or 5 - I 0 . I . 4 . . . emergency l i g h t i n g mode.

Delete 5- I0 .3 .4 and renumber paragraphs. SVBSTANTIATION: 5-10.3.4 The brightness of low level signs required to assist the means of egress in smoke-Filled environments should be at least as bring as those required by 5- I0.3.3 which is the current requirement For those Exi t signs mounted at normal heights and intended to be v i s i b l e under clear egress conditions. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment lOl-60 on 5-10.3.1 and 5-10.3.4 (Log #208).

(Log #197) lOl - 59 - (5-10.1.4) : Reject SUBMITTER: R.H, Hinter , Chloride Systems COMMENT ON PROPOSAL NO.: lOl-141 RECOMHENDATION: Revise as Follows:

5 - 1 0 . 1 . 4 When low level ex i t signs are s p e c i f i c a l l y required by Chapter 8 through 30, an approved luminescent, self- luminous or se l f - i l l um ina ted sign shall be placed near the f l oo r level below signs required For doors or in corr idors by 5 - 1 0 . l . l and 5 - I 0 . I . 2 . This sign shall . . . ( I . 9 cm) wide. An a l te rna t i ve sign shal l consist of i l luminated l i g h t s t r i ps , whlch may be continuous or broken into sections, and shall be located no more than 18 in. or less than 6 in. from the Floor. They shall be adjacent to the door, the closest edge being wi th in 4 in. of the door Frame and having a to ta l i l luminated length of not less than 3 Ft. SUBSTANTIATION: The proposal was rejected mainly on Format. I t did not conform to the comment Form.

Although there is l imi ted research to support th ls system in bui ld ings, i t has been widely researched by the FAA and is a requirement in commercial a i r l i n e s . I know of no research to support 4- I /2 in. le t te red EXITs located near the Floor. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The conditions and arrangement in bui ldings and structures are s i g n i f i c a n t l y d i f f e r e n t than in an airplane. The distances to ex i ts , ce i l i ng heights, a is le arrangements, etc. provide d i f f e r e n t egress problems. Limited research is indicated by the Submitter and the Committee would l i ke to see more research in bul ldings before including th is in the Code. The Code does not r e s t r i c t i n s t a l l a t i o n of these types of l i gh t s as a supplement to ex is t ing Code required signs and the Committee welcomes both i ns ta l l a t i ons and addit ional research.

(Log #208) I01 - 60 - (5-10.3.1" and 5 10.3.41: Reject SUBMITTER: Ken Honeycutt, I l luminat ing Engineering Society of North America COMMENT ON PROPOSAL NO,: I01 409 (s ic) [Ed: I01-149] RECOMMENDATION: Revise to read:

5- I0.3.1" Every sign required by 5-10.1.2, 5 - I 0 . I . 3 or 5 - I 0 . I . 4 . . . .

Delete 5-10.3.4. SUBSTANTIATION: 5-10.3.4 The brightness of low level signs required to assist the means of egress in smoke-f i l led environments should be at least as br ight as those required by 5- I0.3.3. COMMITTEE AOTION: Reject. ~OHHITTEE COMMENT: Proposal I01-149 was an ed i t o r i a l rewr i te of the section with the exception of the delet ion of 5- I0 .4 .1 .2 and 5-10.4.2.2 as indicated in the substant iat ion. Since 5-10.3.4 received only minor ed i t o r i a l changes from the 1985 Code, th is comment presents new material not addressed in the Technical Committee Report. The Submitter w i l l need to submit th is as a proposal f o r the next ed i t ion of the Code.

(Log #203) I01 - 62 - (5-10.3.1" and 5-10.3.4): Reject SUBMITTER: Wi l l i Decker, Lightalarms Electronics Corp. COMMENT ON PROPOSAL NO.: lOl-149 RECOMMENDATION: Revise to read:

5-10.3.1" Every sign required by 5-10.1.2, 5-10.1.3 or 5 - I 0 . I . 4 . . . .

Delete 5-10.3.4. SUBSTANTIATION: 5-10.3.4 The brightness of low level signs required to assist the means of egress in smoke-Filled environments should be at least as br ight as those required by 5-10.3.3. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment lOl 60 on 5-10.3.1 and 5-10.3.4 (Log #208).

(Log #39) lOl - 63 - (5-10.3.1 ~ and 5-10.3.4): Reject SUBMITTER: Pau l Schnackenberg, Exide Electronics COMMENT ON PROPOSAL NO.: lOl-153 (s ic ) led: lOl-149] RECOMMENDATION: Revise to read:

S-lO.3.1* Every sign required by 5 - I 0 . I . 2 , 5 - I 0 . I . 3 or 5 - I0 . I . 4 . . . .

Delete 5- I0.3.4. SUBSTANTIATION: 5 10.3.4 The brightness of low level signs required to assist the means of egress in smoke-Filled environments should be at least as br ight as those required by 5- I0 .3 .3 . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment lOI-60 on 5-I0.3.1 and 5-I0.3.4 (Log #208}.

(Log #88) 101 - 64 - ( 5 - 1 0 . 3 . 1 " and 5 - 1 0 . 3 . 4 1 : R e j e c t SUBMITTER: Donald W. P ray , U n d e r w r i t e r s L a b o r a t o r i e s I n c . COMMENT ON PROPOSAL NO,: 101-153 ( s i c ) [Ed: 101-149) RECOMMENDATION: Rev ise to r ead :

5-10.3.1" Every sign required by 5-10.1.2, 5-10.1.3 or 5 - I 0 . I . 4 . . . .

Delete 5- I0.3.4. SUBSTANTIATION: 5 10.3.4 The brightness of low level signs required to assist the means of egress in smoke-Filled environments should be at least as br ight as those required by 5-10.3.3. COMMITTEE ACTION: Reject. COHMITTEE COMMENT: See Comment lOl 60 on 5-I0.3.1 and 5-I0.3.4 (Log #208).

(Log #80) 101 - 65 - ( 5 - 1 0 . 3 . 1 " and 5 - 1 0 . 3 , 4 ) : R e j e c t SUBMITTER: Lawrence K e a t i n g , ISMA COMMENT ON PROPOSAL NO.: 101-153 ( s i c ) [Ed: 101 149] RECOMMENDATION: Rev ise to r ead :

5 - 1 0 . 3 . 1 " Eve ry s i g n r e q u i r e d by 5 - 1 0 . 1 . 2 , 5 - 1 0 . 1 , 3 or 5 - 1 0 . 1 . 4 . . . .

D e l e t e 5 - 1 0 . 3 . 4 .

279

SUBSTANTIATION: 5-I0.3.4 The brightness of low level signs required to assist the means of egress in smoke-filled environments should be at least as bright as those required by 5-I0.3.3. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment I01-60 on 5-I0.3.1 and 5-10.3.4 (Log #208).

(Log #298) 101 ~ 66 - (5-10.3.4): Reject yUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: I01-149 RECOMMENDATION: Reject and renumber subsequent paragraphs. SUBSTANTIATION: No substantiation offered by Committee for new requirement. Conflicts with permissible use of se l f luminous exi t signs. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Proposal 101-149 is an ed i tor ia l rewrite to c l a r i f y the Code. The ~ntent of the Submitter is unclear. IF the intent ~s to delete 5-I0.3.4, this paragraph has not been technically changed from the 1985 edit ion of the Code by the Technical Committee Report, therefore this deletion would constitute new material and is not allowed during the comment period.

(Log #204, 199, 87, 38, 40) lOl - 67 - (5-10.4.1.2 and A-5-I0.4.1.2): Accept in Part YUBMITTER: Will Decker, Lightalarms Electronics Corp., R.H. Minter, Chloride Systems, Donald W. Pray, Underwriters Laboratories Inc., Lawrence Keating, International Self-Luminous Manufacturers Assoc., Paul Schnackenberg, Exide Electronics COMMENT ON PROPOSAL NO.: 101-153 RECOMMENDATION: Revise proposed S I0.4.1.2 (New) to read as Follows:

5-I0.4.1.2 The arrow shall be located outside of the EXIT legend, not less than 3/8 in. from any le t te r , and may be integral to or separate From the sign body. The arrow shall be of such size, character and location that is p la in ly v is ib le and ident i f iab le as a directional arrow.

Delete proposed A-5-I0.4.1.2 (New). SUBSTANTIATION: a. I t is desirable to specify arrow location outside of the EXIT legend to eliminate the visual conf l ic t between mi<ed let ters and symbols. The arrow dimensions proposed in Log #458 are not s u b s t a n t i a t e d by any s u p p o r t i n g research and undu ly p r o h i b i t the use o f arrows which may p rov ide s u p e r i o r v i s i b i l l t y / l e g i b i l i t y . The above comment a l l ows the t e s t i n g l a b o r a t o r i e s to develop o b j e c t i v e per formance t e s t i n g c r i t e r i a to measure the l e g i b i l l t y / v i s i b i l i t y o f d i r e c t i o n a l ar rows.

b. The conc lus ions o f n e a r l y a l l research e f f o r t s i n t o e x i t s ign v i s i b i l i t y , which have been conducted the l a s t decade have r e s u l t e d in the adop t i on o f the 6 i n . e x i t legend desc r ibed in 5 10.2 as a s tandard , Reduct ion o f l e t t e r h e i g h t to 4 ~n. w i l l s l g n i f i c a n t l y reduce the visual angle of the word EXIT as perceived by the observer. Reduced v i s i b i l i t y w i l l be the result. The inadequacy of 4 I/2 in. le t ters was previously recognized and G in. let ters were required commencing with NFPA I01-1967.

Since the visual task to be performed is the same For both Exit and directional ex i t signs (namely v i s i b i l i t y / l e g i b i l i t y @ I00), there is no supportable basis for discriminating between the size and proportion of the ex i t legend For these appl~cations. COMMITTEE ACTION: Accept in Part.

Revise 5-10.4.1.2 to read as follows: 5-I0.4.1.2 The arrow shall be located outside of the

EXIT legend, not less than 3/8 in. From any le t te r . The arrow shall be at least 6 in. in length and of such character and location that is plainly v is ib le and ident i f iab le as a directional arrow.

Delete proposed A-5-I0.4.1.2 (New). COMMITTEE COMMENT: The Committee concurs with the Submitter's comments on potential problems involving the le t te r size. However, the Committee does feel that a minimum arrow size needs to be specified but has deleted other requirements in favor of performance specifications.

(Log #293) I01 - 68 - (5-10.4.1.2 and A-5-I0.4.1,2): Reject SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: I01-153 RECOMMENDATION: Reject. SUBSTANTIATION: I. No research.

2. No evidence exist ing directional signs have proven inadequate.

3. Will conf l ic t wlth many building code requirements for sign size.

4. Should be coordinated f i r s t with BCMC. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee believes that something does need to be done about the arrows on ex i t signs. There is v i r t ua l l y no dissension within the Subcommittee on Means of Egress as well as the Task Force on Marking and I l lumination of Means of Egress regarding the need to address this. With regard to sign size see Comment 101--67 on S 10.4.1.2 and A-S-10.1.4 (Log #204).

(Log #9) I01 69 - (5 10.4.2.2): Reject SUBMITTER: Hal Cohen, Lebanon, PA COMMENT ON PROPOSAL NO.: I01-149 RECOMMENDATION: Do not delete 5-I0.4.2.2. SUBSTANTIATION: From a cost ef fect ive standpoint, this requirement provides additional awareness of the integral building safety Features. The average person d o e s n ' t know the reason For a "nu isance" door c l o s e r or a door t h a t "b locks v e n t i l a t i o n . " I agree w i t h the Subcommittee tha t the requ i rement may not be too e f f e c t i v e , but the b e n e f i t c e r t a i n l y outweighs the minimum cos t . COMMITTEE ACTION: Re jec t . COMMITTEE COMMENT: The Committee b e l i e v e s the s ign to be i n e f f e c t i v e ,

(Log #221) I01 70 - (5-11.3 Exceptlon): Reject SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: I01-155 RECOMMENDATION: Revise to "space not greater than 1500 sq f t . " SUBSTANTIATION: No evidence presented to indicate need For such a great reduct ion/ l imi tat ion. Existing 25 f t travel distance l im i ta t ion would allow For a maximum of 1963.5 sq Ft. Assuming a c i rcular space with exi t at the center. Travel distance l lmitat10n would continue in Force. COMMITTEE ACTION: Reject. ~MMITTEE COMMENT: The Committee feels that the comment results in an area which ~s too large for a high hazard area to have one way out.

Subcommittee Editor ial Corrections

Revise 5-2.1.4.1 Exception No. 6 by changing "not more than 50" to "less than 50" to eliminate an ed i tor ia l conf l i c t with the base paragraph.

Move 5-2.2.3.7 to 5-2.2.5.

Hove 5-2.2.4.5 Exception to 5-2.2.2.4 Exception.

Proposal 101-38 to delete A-5-5.1.5 was supposed to delete A-5-I.5; A-5-5.1.5 is not deleted.

(Log #237) I01 - 71 - (G-2.2.3.4(b)): Accept SUBMITTER: John Behrens, Huntington Beach, CA ~MENT ON PROPOSAL NO.: I01-165 RECOMMENDATION: Revise (b) to read:

(b) The lowest or next to lowest story within the conlnunicating space is a street Floor. SUBSTANTIATION: This has always been interpreted ~n the past to mean that the communicating space connects either the f i r s t , second and th i rd f loors or the basement, f i r s t and second f loor . Some architects have recently f e l t that this means i t could connect the second, th ird and Fourth Floor. Changing the word "of" to "within" w i l l c l a r i f y the t rad i t iona l interpretat ion. C~OMMITTEE ACTION: Accept.

280

(Log #539) I01 - 72 - (6-2.2.3.4(e)): Accept $VBMITTER: Rolf Oensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. ~OMMENT ON PROPOSAL NO.: I01-165 RECOMMENDATION: Revise 6-2.2.3.4(e) by adding to the end of the sentence:

"(see 4-2.2)". SUBSTANTIATION: The def ini t ions of low hazard and ordinary hazard Found in 4-2.2 d i f f e r From the definit ions of l ight hazard and ordinary hazard found in NFPA 13. By adding this cross-reference, the user of the Code w i l l be able to readily Find the correct def ini t ion. q O M M I T T _ T ~ : Accept.

(Log #239) I01 - 73 - (6-2.2.3.4(f)) : Reject ~UBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO=: lOl-165 REqOMMENDATION: Revise part (F) to read:

( f ) Exit capacity is suf f ic ient to provide for simultaneous egress for a l l occupants of a l l stories interconnected by the unenclosed f loor opening, by considering a l l stories so interconnected to be a single Floor area in determining the required exi t capacity. SUBSTANTIATION: The old 6-2.2.3.4(d) has not proven to be a problem in the past. The proposal by the Subcommittee would appear to only require the actual interconnected space to be e~ited simultaneously where the Code has t rad i t iona l l y required, the Floor so interconnected to provide f o r simultaneous exiting. This signif icant reduction has not been documented nor jus t i f ied. COMMITTEE ACTION: Reject. ~MMITTEE COMMENT: The Committee does not agree with the Commenter that the current 1985 edition requires entire stories to provide For simultaneous egress. Rather, the Committee bel~eves that there may be areas on a floor that could be separated From the communicating area by l -hr Fire barriers (see wording of proposed subpart (d)) which do not need the extra exi t capacity associated with simultaneous egress. The Commenter has not substantiated why areas on the other side of such Fire barriers need the simultaneous egress capabil ity.

Edi tor ia l ly , c l a r i f y the intent by revising (F) to read:

(F) Exit capacity is suf f ic ient to provide simultaneously For a l l the occupants of a l l levels within the communicating space to egress the communicating space by considering i t to be a single Floor area in determining the required exi t capacity.

(Log #240) lot - 74 - (G-2.2.3.4(g), Exception NO. I to (g) and Exception No. 2 to (g) (New)): Accept in Part in Principle ~UBMITTE_R: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: I01-165 RECOMMENDATION: Revise 6-2.2.3.4(g) to read as follows:

(g) Each story considered separately has at least one half of i ts individual required exit capacity provided by an exi t or exits leading d i rect ly out of that story without occupants having to traverse the communicating space.

Exception No. l to (g): When the entire story is designated as part of the communicating space, at least one half of the exi t capacity of that story must be independent of, and in a direction away From, the unenclosed Floor opening.

Exception No. 2 to (g): Mezzanines with an aggregate area not in excess of I/3 of the f loor area below. ~LT_ANTIATI~: This area has been a signif icant problem in the past. The suggested revision keeps the major intent as contained in present G-2.2.3.4(e) but does c la r i f y how to handle i t when the entire f loor is designated as part of the communicating space. Part (g) as submitted by the Subcommittee would allow a l l the exit access to be within the communicating space as long as i t did not traverse down through the

communicating space. This option is limited to atriums and is the major difference between atriums in 6-2.2.3.5 and the three story on enclosed vert ical openings of 6-2.2.3.4. The changes proposed by the Subcommittee to part (g) eliminate one of the major Features contained in thls section. COMMITTEE ACTION: Accept in Part in Principle.

I. In subpart (g), change " f loor level" to story in two places; change " level" to "Story" in one place; and insert the words "within the communicating space" so as to read:

(g) Each story, within the communicating space, considered separately has at least one half of i ts individual required exit capacity provided by an ex l t o r exits leading d i rect ly out of that story without occupants having to traverse another story within the communicating space.

2. Delete the proposed exception to (g) dealing with mezzanines.

3. Add an appendix note A-6-2.2,3(g) (draft numbering: A 6-2.4.4(g)) to read: Given that a mezzanine, meeting the maximum I/3 area deflnition of mezzanines per Chapter 3, is not a "story", it can therefore have I00 percent of its e~It access within the communicating area back through the StOry below. COMMITTEE COMMENT: The Committee agrees that the words "Floor level" and "level" should be changed to "story" to help clarify intent. It is the Committee's intent to allow For the communicating space to serve as part of the means of egress. Exiting allowances and restr ic t ions For areas not within the communicating space should be addressed by Chapter 5. For example, Chapter 5 is Free to specify whether a corridor can t e r m i n a t e a t an o p e n s p a c e o r i f i t m u s t t e r m i n a t e o n l y at an exi t .

(Log #241) lot - 75 - (6-2.2.3.5(b)): Accept SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: 701-167

I RECOMMENDATION: Revise 6-2.2.3.5(b) third sentence to read:

(b) Exit discharge in accordance with 5 7.2 may be within the atrium. ~UBSTANTIATION: Paragraph 5-7.2 no longer requires permission of the occupancy chapters to u t i l i ze t~e F i f t y percent rule. Therefore, the quote "Where allowed by Chapters 8 through 30" is no longer needed. COMMITTEE ACTION: Accept.

(Log #220) lot - 76 - (6-2.2.3.S(F)): Accept ~BMITTER: T. Daly/H. Moore, Hi l tonHotels Corp. O~ENT QN PROPOSAL NO.: lOl 169

I R_ECOMMENDATION: Delete Subitem 3. v

~BSTANTIATION: There is no need to activate smoke removal system in an atrium i f the Fire alarm system has been activated due to a Fire condition outside of the atrium. The atrium is required to be surrounded by rated construction and is Further required to be sprinklered. This requirement is in conf l ic t wlth Basic/National Building Code Sec. 620.2.1.4 which prohibits manual Fire alarm systems From activating smoke control systems within atriums. COMMITTEE ACTION: Accept.

(Log #213) 101 - 77 - (6-2.2.3.5(g)I.) : Accept in Part in Principle SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. ~OMMENT ON PROPOSAL NO.: I01-170 RECOMMENDATION: Revise wording to read:

I. An approved smoke detection system providing protection to the top of the atrium. SUBSTANTIATION: Should sat isfy Submltter and Committee concerns. Existing language is subject to limited interpretations and applications since beam type detectors need not be placed "at the top of the atrium" to provide ef fect ive protection to the top of the atrium, (see NFPA 72E, Section 4-3.3). Smoke detectors are not needed at each return a i r intake since duct smoke detectors are required in HVAC returns by NFPA 90A, Section 4-3, referenced in Section 7-2.

281

COMMITTEE ACTION: Accept in Part in Principle. Revise the wording of 6-2.2.3.5(g)I tO read: I. Approved smoke detectors located to detect smoke

above the highest Floor level of the atrium and at return a i r intakes From the atrium. COMMITTEE COMMENT: The Committee agrees that the detectors themselves need not necessarily be positioned on the ceil ing at i ts peak. Use of approved beam type detectors should be acceptable. However, with respect to smoke detector placement at return a i r intakes the Committee believes that such positioning is necessary for early detection.

(Log #337) lOl - 78 - (6-2.2.3.7 Exception No. 3): Accept in Principle SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL N~_=.: I01-172 RECOMMENDATION: Accept the proposed submission as in the TCR. SUBSTANTIATION: The Committee gave as a reason to reject "additional guidance is not needed within the Code. In the rare case where one might be interested in employing the ro l l ing shutter method of protection, ear l ie r editions of the Code can be consulted". Subsequent discussions with members of the Committee indicated that the Committee was of the opinion that ro l l ing shutters are obsolete and no longer in use and applicable only to existing buildings. This is far From the truth as they are being constantly installed in new buildings. They are not an archaic method of protection. The Committee was provided with a l i s t of new buildings where they are being used. I f there is a concern for the movement of smoke within a building, this is probably the most practical method of assuring that smoke w i l l not travel from one Floor to another by escalator openings. BCMC has included i t in i ts recommendations to the Model Codes. COMMITTEE ACTION: Accept in Principle.

Add an Exception No. 3 to 6-2.2.3.7 (6-2.4.7 per TCR draft) to read as Follows:

Exception No. 3: In l ieu of such protection, in buildings protected througout by an approved automatic sprinkler system in accordance with Section 7-7, escalators or moving walk openings may be protected by ro l l ing steel shutters appropriate For the f i r e resistance rating of the vert ical opening protected. The shutters shall close automatically by smoke detection and sprinkler operation, independent of each other. There shall be a manual means of operating and testing the operation of the shutter. The shutters shall be operated at least once a week to assure that they remain in proper operating condition. The shutters shall operate at a speed of not more than 30 Ft per minute and shall be equipped with a sensitive leading edge. The leading edge shall arrest the progress of a moving shutter and cause i t to retract a distance of approximately 6 in. upon the application of a Force not in excess of 20 Ib (90 N) applied to the surface of the leading edge. The shutter, following this retraction, shall continue to close. The operating mechanism for the ro l l ing shutter shall be provided with standby power complying with the provisions of NFPA 70, National Electrical Code. COMMITTEE COMMENT: The Committee agrees that the ro l l ing shutter" method of protecting escalator openings should be detailed in the Code. The Committee Action should sat isfy the Commenter's intent.

(Log #452) lOl - 79 - (6 4.4 Exception (New)): Accept $UBMITTER: William E. KofFel, KofFel Assoc., Inc. COMMENT ON PROPO~L NO.: I01-182 RECOMMENDATION: Add an Exception to read as Follows:

Exception: Laboratories in health care occupancies and medical and dental off ices shall comply with NFPA

99, Standard for Health Care Fac i l i t ies . SUBSTANTIATION: Consistency with Chapters 12 and 13; the scope of NFPA 45 and the scope of NFPA 99. COMMITTEE ACTION: Accept.

(Log #341) I01 - 80 - (6-5.2.3): Accept _~_VBMITTER: Donald W. Belles, Belles and Associates, Inc. COMMENT ON PROPOSAL NO.: 101-186 RECOMMENDATION: Delete paragraph 6-5.2.3 (new paragraph 6-5.1.4). SUBSTANTIATION: New paragraph 6-5.I.4 remains vague and unenforceable. Designers, code o f f i c i a l s and manufacturers would have no means of demonstrating compliance. The absence of reference standards or performance c r i t e r i a creates potential l i a b i l i t y . ~_QMMITTEE ACTION: Accept. ~_OMMITTEE COMMENT: The Committee agrees with the Commenter's substantiation and, Further, believes that the authority having jur isdict ion has the authority to prohibit such materials. The Committee Action of "Accept" reaffirms the original Proposal lOl-18G as drafted by the Subcommittee on Fire Protection Features and printed in the TCR.

(Log #214) 101 - 81 - (6-5.2.3): Reject $UBMITTER: T. Daly/H. Moore, Hilton Hotels CoFp. COMMENT ON PROPOSAL NO.: 101-183 R_E~OMMENDATION: Delete second sentence in i ts ent i rety. SUBSTANTIATION: There is no evidence that material of a Class A in te r io r Finish c lassi f icat ion installed in accordance with this section without sprinkler protection (as would be permitted) is any safer than material with a Class B in ter ior Finish c lass i f icat ion with sprinklers. ~MMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter is reminded that the subject requirements apply only to carpet- l ike or t ex t i l e wall covering materials, not to a l l Class A in ter ior wall and ceil ing Finishes. There is evidence, see Proposal 101-190 in the TCR, from the University of Cal i fornia test program that some Class A tex t i l e wall coverings perform poorly and thus need both Class A c lassi f icat ion and sprinkler protection. See the Committee Action on Proposal I01-190 in the TCR which w i l l require, unless successfully tested by a room/corner type Fire test, that these materials be both Class A in ter ior Finish materials and sprinklered.

(Log #215) 101 - 82 - (6-5.2.3 Exception (New)): Reject ~_UBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. ~MMENT ON PROPOSAL NO.: I01-183 RECOMMENDATION: Add:

Exception: The sprinkler option in Section 6-5.7.1 may be used when quick response sprinklers are instal led. ~U_BSTANTIATION: Quick response sprinklers activate 5-6 times faster than standard sprinklers under the same f i f e conditions and thus offset concerns re lat ive to a higher flame spread Fating. COMMITTEE ACTION: Reject. COMMITTEE COMMEN!: The Commenter has provided no evidence that, even with quick response sprinkler protection, a relaxation on in ter ior f in ish c lassi f icat ion to something less than Class A can be tolerated for these carpet-l ike and tex t i l e wall covering materials. Additionally, the Commenter is asked to see the Committee Comment on Comment I01-8i on 6-5.2.3 (Log #214).

(Log #216) 101 - 83 - (6-5.5.1 and 6-5.5.2): Accept in Principle SVBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-188 RECOMMENDATION: Revise "A complete standard system of automatic sprinklers is installed . . . . " in both sections to read:

". . . an approved automatic sprinkler system is installed in accordance with Section 7-7 . . . . " SUBSTANTIATION: Editor ial . Use of standardized wording For reference to automatic sprinkler systems.

282

COMMITTEE ACTION: Accept in Principle. See Committee Action on Proposal 101-183 in the TCR.

COMMITTEE COMMENT: The Committee Action on Proposal 101-183 in the TCR does what the Commenter suggests.

(Log #351) IOl - 84 - (7-4 and A-7-¢): Reject SUBMITTER: Samuel S. Levinrad, Veterans Administration COMMENT ON PROPOSAL NO.: lot-193 RECOMMENDATION: I t is my recommendation that this proposal be accepted rather than rejected. SUBSTANTIATION: The Committee's rejection based on anticipation of a Formal interpretation by ASME should not be a reason For rejecting this proposal. I have been in correspondence with ASME on the same subject. I am enclosing for the Committee's information a copy of my le t te r and a le t te r which I received from the ANSI Committee, which appears to be an o f f i c i a l interpretation. (Note: Copies of the Commenter's supporting materials are available for review at NFPA Headquarters.) The ANSI Committee in their December 30, 1986, reply to me states that their only concern is accidental discharge of sprinklers. They reference that sprinklers should be installed to conform to NFPA 13. I f they are to conform to NFPA 13, then the ANSI Committee is incorrect, i f one reads the part icular ANSI Section Rule I02.2(c) which has been submitted to NFPA Headquarters for review. The ANSI Committee's excuse is that this requirement has been in AIT.I since 195S. Regardless of how many years i t ' s been in the Code, i f i t ' s incorrect i t should be taken out.

In paragraph 5 of their reply to my le t te r , they reference that this is the same requirement that appears in NFPA 75-1981 Section 5-4.2. I remind the Committee that NFPA 75 is talking about a room that has f u l l supervision. Whereby in an elevator equipment room there is no supervision, i t is completely unattended. I refer the Committee to the enclosed ar t i c le which appeared in the March/April 1987 Fire Journal - Subject: Hotel Fire. IF the Mechanical Equipment Room did not have sprinklers and under the same c i rcumstances t h a t the scenar io u n f o l d e d , the re not on l y would have been p r o p e r t y damage, but e x t e n s i v e loss o f l i f e . I t i s the s p r i n k l e r s t h a t p ro tec ted the b u i l d i n g and the personne l .

The Commi t tee 's comments on the sub jec t s t a t e t h a t r a t e o f r i s e o r f i x e d temperature - heat d e t e c t o r s should be connected i n t o the e l e v a t o r c i r c u i t to disconnect the elevator c i rcui ts at the same time that the sprinklers are activated. I believe this is an incorrect application of heat detectors. IF the Elevator Industry is concerned with water causing equipment to run away, they should require that a l l of the control equipment be to ta l l y enclosed in a weatherproof enclosure rather than being l ive front as they are currently installed. In addition a l l rotating equiment should be weatherproof. For Further information, I refer the Committee to Proposal 101-257 which was rejected. The Submitter is a member of the ANSI Committee and his substantiation explains the ANSI reasoning behind requiring the l imi tat ion of sprinklers in elevator equipment rooms.

The problem is not with NFPA 101, the problem is with the ANSI A-17 Committee. I t appears that they have fa i led to coordinate with NFPA 13, NFPA 75 or NFPA 101 in the preparation and writ ing of their standard. The fact that i t has been in their standard since 1955, as I previously said is no reason for i t to remain. C~MITTEE ACTION: Reject. COMMITTEE COMMENT: The Formal Interpretation has been received from ASME. There is now no conf l ic t between NFPA 13/lOt and ANSI/ASME At7.1. AS such, Proposal 101-193 was correctly rejected in the TCR.

(Log #389) I01 - 85 - (7-6.1.3): Accept in Principle SUBMITTER: Vic D. Humm, Vic Humm & Assoc. COMMENT ON PROPOSAL NO.: I01-199 RECOMMENDATION: Add the Following NFPA publications for coordination and reference:

NFPA 72G, Instal lat ion, Maintenance and Use of Not i f icat ion Appliances for Protective Signaling Systems, 1985 Ed.

NFPA 72H, Testing Procedures for Signaling Systems, 1984 Ed.

SUBSTANTIATION: Both publications having been accepted by the Association are good references in regards to the insta l la t ion of audible and visual appliances and the testing of signaling systems. COMMITTEE A ~ : Accept in Principle.

See Proposal 101-972 in the TCR. COMMITTEE COMMENT: NFPA 72G and NFPA 72H w i l l be referenced by new A-7-6.1.3 as proposed in TCR Proposal 101-972. Because NFPA 72G and NFPA 72H are Guides, they cannot be referenced in a mandatory fashion within the body of the Code. Rather, they are more appropriately referenced in a nonmandatory way in an appendix item. This nonmandatory appendix reference should meet the Commenter's intent.

(Log #388) 101 - 86 - (7-6.1.6 Note (New)): Accept in Principle SUBMITTER: Vic D. Humm, Vic Humm & Assoc. COMMENT ON PROPOSAL NO.: lOI-201 RECOMMENDATION: Add Note as follows:

NOTE: Refer to NFPA Publication 72H For assistance in testing procedures for signaling systems.

SUBSTANTIATION: This is to assist the reader to other pertinent NFPA publications. COMMITTEE ACTION: Accept in Principle. See Committee Action and Committee Comment on Comment

101-85 on 7-6.I.3 (Log #389). ~OMMITTEE COMMENT: The nonmandatory appendix reference to NFPA 72H, as explained in the Committee Comment to Comment I01-85 (Log #389), should sat isfy the Commenter's intent.

(Log #242) 101 - B7 - ( 7 - 6 . 2 . 7 ) : Accept in P r i n c i p l e SUBMITTER: John Behrens, Hun t ing ton Beach, CA COMMENT ON PROPOSAL NO.: 101-207 RECOMMENDATION: Add a new sentence between the e x i s t i n g F i r s t and second sentences to read:

" In new i n s t a l l a t i o n s , where two or more smoke de tec to r s are r e q u i r e d w i t h i n an i n d i v i d u a l l i v i n g u n i t they s h a l l be i n t e r c o n n e c t e d so t h a t the a c t i v a t i o n o f one causes a l l i n t e g r a l and separa te a larm systems to o p e r a t e . " SUBSTANTIATION: In a d d i t i o n to the s u b s t a n t i a t i o n prov ided by the o r i g i n a l Subm i t t e r o f t h i s p roposa l , i t should be noted t h a t in a l l cases, the L i f e Sa fe ty Code r e q u i r e s new c o n s t r u c t i o n to have house-powered smoke d e t e c t o r s . When us ing house power, t he re is v i r t u a l l y no d i f f e r e n c e in cost between i n t e r c o n n e c t e d and non in te rconnec ted u n i t s and, t h e r e f o r e , in new c o n s t r u c t i o n , t h i s mandate is not on ly j u s t i f i a b l e , but is economical as w e l l . The t e c h n i c a l r e a l i t i e s are t h a t i f a u n i t i s l a r g e enough to r e q u i r e more than one smoke d e t e c t o r , then the a u d i b i l i t y o f the remote d e t e c t o r in the s l e e p i n g areas is e x t r e m e l y ques t i onab le . COMMITTEE ACTION: Accept in P r i n c i p l e .

Add a new sentence between the e x i s t i n g F i r s t and second sentences to read:

" I n new c o n s t r u c t i o n , where two or more smoke de tec to r s are r e q u i r e d w i t h i n a l i v i n g u n i t , they s h a l l be arranged So t h a t the a c t i v a t i o n o f any d e t e c t o r causes the o p e r a t i o n o f an a larm which s h a l l be c l e a r l y aud ib le th roughou t the l i v i n g u n i t over background noise l e v e l s w i t h a l l i n t e r v e n i n g doors c l o s e d . " ~OMMITTEE COMMENT: The Committee agrees w i t h the concept o f a u d i b i l i t y o f a larm th roughou t a l i v i n g u n i t but made changes to the Commenter's suggested word ing which:

( I ) s t a tes t h a t the p r o v i s i o n a p p l i e s to new c o n s t r u c t i o n and not to new smoke d e t e c t o r i n s t a l l a t i o n s in e x i s t i n g b u i l d i n g s ,

(2) changes "how to " word ing to s p e c i f i c a t i o n o f desired performance because interconnection of detectors represents only one way of meeting the intent, and

(3) draws From some of the wording from NFPA 74, Section 2-2 w~th respect to aud ib i l i t y over background noise with closed doors.

The Committee Action should sat isfy the Commenter's intent.

283

(Log #285) lOl - 88 - (7--6.2.7): Accept in Pr inc ip le $OBMITTER: Charles E. Zimmerman, Norfolk, VA COMMENT ON PROPOSAL NO.: I01-207 RECOMMENDATION: Revise the sentence that was proposed in Proposal I01-207 (7-6.2.7) to read:

"Where two or more smoke detectors are required, by the Code, w i th in an ind iv idual l i v i n g un i t , they shal l be SO arranged that the actuation on one shal l cause a l l i n teg ra l , separate or both audible alarm appllances to operate." SUBSTANTIATION: This rewording of my o r ig ina l proposal is to c l a r i f y that I did not intend to l i m i t the method of interconnection of smoke detectors and sounding appliances ~ i t h in the fami ly l i v i n g un i t .

Responding to the Committee Comment, I bel ieve my proposal is w i th in the document's scope since i t rs ca l l i ng For operational performance of a l l audible alarm appliances whenever a detector senses smoke. This proposal is no d i f f e r e n t than Section 7 6.3.5 of I01 which also requires operation of a l l alarm signals. Further, Chapter 7 has many spec i f i c requirements, which were placed there properly by the Committee because the meaning of the Code should be clear and spec i f i c .

My proposal was addressed to Section 7-6.2.7 rather than to Section 22 because 7-6.2.7 is the basis fo r i n s t a l l a t i o n of s ingle and mul t ip le s ta t ion smoke detectors.

The cost o f comply ing w i t h t h i s arrangement i s not economically unFeaslble during the new construct ion phase. This is evident by the many state and model bu i ld ing codes which now require th is performance.

F ina l ly , my Supporting data c lear ly shows that a detector, that the Code requires, in the l i v i n g un i t , cannot be heard through two Floors, closed doors, or- both. Why must we wait For someone to die in a Fire before the L i fe Safety Code is changed so that a sleeping person w i l l know that the i r basement or the other end of the l l v i n g uni t is on F~re. COMMITTEE ACTION: Accept in Pr inc ip le .

See Committee Action on Comment I01-87 on 7-6.2.7 (Log #242). COMMITTEE COMMENT: The Committee Action on Comment I01-87 (Log #242) should sa t i s fy the Commenter's in tent .

(Log #74) lot - 89 - (7-6.2.7 and 7-6.2.8) : Accept in Pr inc ip le SUBMITTER: H. Brooke Stauf fer , National E lec t r i ca l HanuFacturers Assn. COMMENT ON PROPOSAL NO.: 101-210 RECOMMENDATION: The recommendation o f Proposal 101-210 should be recons ide red and accepted as w r i t t e n . SUBSTANTIATION: To a m p l i f y upon the S u b s t a n t i a t i o n included as part of Proposal 101 210, paragraph 7-6.2.1 i d e n t l f i e s (a) Manual - (b) Automatic and (c) Extinguishing system; paragraph 7 6 . 2 . 2 , 7 - 6 . 2 . 3 , 7-6.2.4 and 7 6.2.5 give spec i f ic guidance fo r Manual F i re Alarm S t a t i o n s . Paragraph 7 6 . 2 . 6 speaks to s p r i n k l e r system i n i t i a t i o n , Proposal 101-210 p rov ides optional guidance For smoke detection - proposed 7-6.2.6 oFFers complete smoke detection and 7-6.2.7 o f fers a par t ia l system in common areas to al low select ion by occupancy chapters by reference. COMMITTEE ACTION: Accept in Pr inc ip le .

I. Insert a new 7-6.2.7 and 7-6.2.8 before ex is t ing 7-6.2.7 to read:

7 - 6 . 2 . 7 When a "complete smoke d e t e c t i o n System" i s r e q u i r e d by another s e c t i o n o f t h i s Code, au tomat i c d e t e c t i o n o f smoke in accordance w i t h NFPA 72E, Standard on Automat ic F i re De tec to rs , s h a l l be p rov ided in a l l oecupiable areas, common areas and work spaces in those environments sui table For proper smoke detector o p e r a t i o n .

7 - 6 . 2 . 8 When a " p a r t i a l smoke d e t e c t i o n system" i s r e q u i r e d by ano ther s e c t i o n o f t h i s Code, au tomat i c d e t e c t i o n o f smoke in accordance w i t h NFPA 72E, Standard on Automat ic F i re De tec to rs , s h a l l be p rov ided in a l l common areas and workspaces, such as cor r idors , lobbies, equipment rooms and other nontenant spaces in those environments sui table For proper smoke detector operation. Select ive smoke detection unique to other sections of th is Code shal l be provided as required by those sections.

2. Renumber ex is t ing 7-6.2.7 as 7-6.2.9. 3. Add the fo l lowing to Chapter 3 de f i n i t i ons : Complete Smoke Detection System. (See 7-6.2.7. ) Par t ia l Smoke Detection System. (See 7-6.2.8.)

COMMITTEE COMMENT: The Committee agrees that Chapter 7 should o f f e r "menu items" For use by other sections of the Code, especial ly by the occupancy chapters, which define "complete" and " p a r t i a l " smoke detection systems. Another section of the Code can then, fo r example, require a "complete smoke detection system" in accordance with 7-6.2.7. The second sentence of proposed 7-6.2.8 c l a r i f i e s that when another section of the Code wants smoke detection that doesn't meet the de f i n i t i ons of e i ther "complete" or " p a r t i a l " (per 7-6.2.7 and 7-6.2.8) , that "se lect ive" amounts of detection shal l be provided as specif ied by that section of the Code.

The above Committee Action should sat is fy the Commenter's in tent .

(Log #28) lOl - go - (7-6.2.8 and 7-6.2.9): Accept in Pr inc ip le SUBMITTER: Joseph A. Drouln, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO=: 101 210 RECOMMENDATION: The proposal to add new sections 7-6.2.6 and 7-6.2.7 should be accepted. SUBSTANTIATION: Guidance on smoke detection is needed in th is section. The occupancy chapters specify that a smoke detector system shall be ins ta l led in accordance with 7-6, but Section 7-6 provides no information For the i n s t a l l a t i o n of smoke detectors. Paragraph 7-6.2.2 through 7-6.2.5 provides guidance for manual stat ions, 7-6.2.6 - spr ink lers , 7-6.3 Occupant No t i f i ca t i on ; 7-6.4 Emergency Forces No t i f i ca t i on , 7-6.5 Emergency Control, 7-6.6 Location of Controls, but there is no information on system smoke detectors. COMMITTEE ACTION: Accept in Pr inc ip le .

See Committee Action on Comment I01-89 on 7-6.2.7 and 7-6.2.8 (Log #74). COMMITTEE COMMENT: The Committee Action on Comment I01-89 (Log #74) should sa t i s fy the Commenter's in tent .

(Log #4) 101 - gl - (7-6.3.2 Exceptions No. 2, 3 and 4): Reject SUBMITTER: Martin H. Reiss, The Gamewell Corp. COMMENT ON PROPOSAL NO.: 101-216 RECOMMENDATION: Add to Exceptions 2, 3 and 4 the fo l lowlng:

"The detector alarm signal shall sound in a continuously manned locat ion in th is s i t ua t i on . " SUBSTANTIATION: I t is important that notice of detector actuation be given so that action can be taken. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Alarm at manned locat ion not necessary. However, Commenter is referred to Commlttee Action on Comment 1oi-93 (Log #343) which w i l l require supervisory alarm signal as a condit ion of proposed Exception No. 2.

(Log #349) 101 - 92 - ( 7 - 6 . 3 . 2 Except ions NO. 2, 3, and 4 and A - 7 - 6 . 3 . 2 Except ions No. 2, 3, and 4 . ) : Reject SUBMITTER: Samuel S. Lev in rad , Veterans A d m i n i s t r a t i o n COMMENT ON PROPOSAL NO.: 101-216 RECOMMENDATION: I t i s my recommendation t h a t t h i s proposal be changed From "Accept" to " R e j e c t " . SUBSTANTIATION: The purpose o f a smoke d e t e c t i o n dev ice i5 p r i m a r i l y to de tec t smoke which a l e r t s the occupants t h a t t he re may be a F i r e . I t s secondary Function or t e r t i a r y Function is to operate other devices such as door closers, dampers, etc. The use of a smoke detector as the Committee is well aware is not to ext inguish Fires, but to a le r t the occupants that there may be a Fire. I t is unpardonable to have f i r e protect ion devices in a bui ld ing and not have them connected to the Fire alarm system so they can a le r t occupants to potent ia l hazards. The problem of nuisance alarms should not be the Committee's concern, these should be addressed by UL and the Fire Alarm Industry.

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COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 101-93 on 7-6.3.3 Exception Nos. 2, 3 and 4 (Log #343). The Committee Action and Committee Comment on Comment I01 93 (Log #343) explain the Committee's thinking on the subject.

(Log #343) lOl - 93 - (7-6.3.2 Exceptions No. 2, 3 and 4): Accept in Part in Principle SUBMITTER: Irving Mande, Norwalk, CT COMMENT ON PROPOSAL NO.: I01-216 RECOMMENDATION: Add the following text to Exceptions No. 2, 3 and 4:

". . . i f the power supply and insta l lat ion wiring to these detectors are monitored by the building Fire alarm system and actuation of these detectors results in a supervisory signal at the building Fire alarm system." SUBSTANTIATION: The Committee does not provide any detailed substantiation for claiming that these detectors need not sound an alarm other than the occurrence of numerous nuisance alarms. Adding the proposed text w i l l be equally effect ive in eliminating nuisance alarms without compromising the r e l i a b i l i t y of these c r i t i ca l systems. As written, the Exceptions are vague on what requirements these detectors and their control equipment would have to meet. The proposed text makes i t clear that the monitoring requirements of the NFPA 72 series would s t i l l apply and the specif ier would have a choice of providing either an occupant not i f icat ion signal or a Supervisory signal to inform the building management about the status of their l l f e safety systems. (Note: A supervisory signal only need sound at the control uni t . ) COMMITTEE ACTION: Accept in Part in Principle.

Add three Exceptions and associated appendix items to 7-6.3.2 to read:

Exception No. 2: ~ Elevator lobby and assoclated machine room detectors used For elevator recall are not required to sound the building evacuation alarm i f the power supply and insta l la t ion wiring to these detectors are monitored by the building Fire alarm system and actuation of these detectors results in a supervisory alarm signal.

Exception No. 3:* Duct detectors used For closlng dampers or heat ing/vent i lat ing/air conditioning system shutdown are not required to sound the building alarm .

Exception No. 4:" Detectors at doors For the operation of automatic door release are not required to sound the building alarm.

A-7-6.3.2 Exception NO. 2. The concept addressed by the Exception is that detectors used For "releasing s e r v i c e " For e l e v a t o r r e c a l l need not sound the b u i l d i n g evacua t ion a larm p rov ided t h a t an a larm c o n d i t i o n is i n d i c a t e d by an aud ib l e s u p e r v i s o r y s i g n a l ,

A 7 -6 .3 .2 Except ions No. 3 and 4. The concept addressed by the Excep t ion is t h a t de tec to r s used f o r "releasing service", such as door or damper closing and fan shutdown, need not sound the building alarm. C~OMMITTEE COMMENT: The Committee believes that given:

( I ) the poor performance of elevator shaft opening protectives (doors) with respect to smoke Spread through buildings, and

(2) the importance of keeping the elevator recall detectors in proper operation because they do not f a i l safely, i . e . , they need power to accomplish elevator recal l , the above changes to proposed Exception No. 2 are jus t i f ied.

With respect to proposed Exceptions NO. 3 and 4, the detectors can be arranged to perform their simple "releasing service" in a f a i l safe manner, i . e . , upon loss of power the electromagnet w i l l deactivate and the door w i l l become sel f closing, so that additional changes are not needed.

The Committee is concerned that "multiple levels" of protection not be specified. For example, consider two nearly identical buildings with neither required by the Code to have a smoke detection system. I f only one building has a smoke barrier and uses detectors to achieve automatic'door closing, why must that building incur the extra expenses, maintenance, and possible nuisance alarms associated with using the "releasing

service" detector for the dual purpose of area smoke detection and the sounding of the building general alarm. The other building had no releasing service detectors and would not be straddled with this requirement. Treatment would be inequitable. I f the occupancy chapters want area smoke detection they should so require i t .

Although the Committee Comment addresses more issues, with respect to "releasing service" smoke detectors, than raised by the Commenter, i t was expanded because i t is referenced as part of the Committee Action and Committee Comment on o the r comments.

Commenters are f u r t h e r reminded t h a t the proposed word ing o f Except ions No. 3 and 4 do not p r o h i b i t one From sounding any part of the buiding alarm upon activation of the releasing service detector.

(Log #496) lOl - 94 - (7-6.3.2 Exceptions No. 2, 3 and 4): Accept in Part in Principle $UBMITTER: Mike Thompson, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-216 RECOMMENDATION: Add the following sentence at the end of Exception 2, 3, and 4:

"A supervisory signal shall be sent and annunciated by the building Fire alarm system in accordance with the requirements of 7-6.1.3." SUBSTANTIATION: Clar i f icat ion. I t is believed that the intent is not to delete these detectors from the Fire alarm system. I agree the detectors shouldn't ring the building evacuation alarm in most cases, but a signal should be sent to the Fire alarm panel to not i fy responsible individuals so that corrective action may be taken. IF not i f icat ion is not made, doors wi l l be chocked open, etc. COMMITTEE ACTION: Accept in Part in Principle.

See Comment I01-93 on 7 6.3.2 Exception Nos. 2, 3 and 4 (Log #343). COMMITTEE COMMENT: The Committee Action and Committee Comment on Comment I0|-93 (Log #343) should meet part of the Commenter's concerns and explain why other portions were not acceptable to the Committee.

(Log #402) 101 - 95 - (7-6.3.2 Exceptions No. 2, 3 and 4 and A-7-6.3.2 Exceptions No. 2, 3 and 4): Reject SUBM~TTER: Patrick E. Phi l l ips, Lag Vegas, NV COMMENT ON PROPOSAL NO.: I01 216 RECOMMENDATION: Delete the three Exceptions and Appendix material revlsed by this proposal. SUBSTANTIATION: These are primarily "Fire detectors." You do not waive the primary requirement because they provide an auxi l iary function (release door, etc.) . Properly installed in accordance with NFPA alarm standards, and properly maintained, the false alarm rate should not be excessive. IF you are not going to ins ta l l them and maintain them properly, you w i l l have f i r e alarms unnecessarily.

This was not correlated with the Signaling Systems Correlating Committee. We believe that we, not I01, know more about detection and alarm Systems. The alarm must at least be transmitted to an attended location (Chapter 4, NFPA 72D) and loca l ly i t is recommended (Appendix A of 72A). COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 101-93 on 7-6.3.2 Exception Nos. 2, 3 and 4 (Log #343). The Committee Action and Committee Comment on Comment I01-93 (Log #343) explain the Committee's thinking on the subject.

(Log #6) I01 - 96 - (7-6.3.2 Exception No. 5 (New)): Reject SUBMITTER: Martin Reiss, The Gamewell Corp. COMMENT ON PROPOSAL NO.: 101-215 RECOMMENDATION: Add Exception NO. 5 as Follows:

Exception No. 5: A delay in automatic not i f icat ion from detector actuation is permitted in order to allow trained personnel time to investigate the cause.

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SUBSTANTIATION: This is common p r a c t i c e t ha t needs to be c l e a r l y d i f f e r e n t i a t e d From pre s igna l in t ha t a subsequent action is not required and i t applies only to detector actuation. I t is also another version of the permission approach taken in Exceptions 2, 3 and 4. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Comment introduces material which has not had public review. Commenter is encouraged to submit the topic as a proposal fo r the next (1991) ed i t ion of the Code when proposals are again being accepted.

(Log #387) I01 - 97 - (7-6.3.2 Note (New) and Exceptions No. 2, 3 and 4): Accept in Part in Pr inc ip le SUBMITTER: Vic D. Humm, Vic Bumm & Assoc. COMMENT O N PROPOSAL NO..: I01-216 RECOMMENDATION: Add Note a f t e r the reference to 7-6.3.10 in the F i rs t paragraph.

In Exceptions No. 2, 3 and 4 l i s ted hereafter the i n i t i a t i n g devices shall be monitored by the signal ing systems For actuation and a v a i l a b i l i t y of operational power ( i . e . , smoke detector) . These signals shall be c a l l e d a s u p e r v i s o r y s i gna l such as For the c l osu re o f a s p r i n k l e r c o n t r o l . (Th is s i gna l c i r c u i t is mon i to red For i n t e g r i t y by the c o n t r o l panel and upon a c t u a t i o n o f a dev ice on the r e s p e c t i v e c i r c u i t an aud ib le and v i sua l s igna l opera te at the s igna l system c o n t r o l panel ) . SUBSTANTIATION: This is i d e n t l c a l to the requ i rements o f 7 -7 .2 . COMMITTEE ACTION: Accept in Part in Pr inc ip le .

See Comment lOl 93 on 7-6.3.2 Exception Nos. 2, 3 and 4 (Log #343). COMMITTEE COMMENT: The Committee Action and Committee Comment on Comment I01-93 (Log #343) should meet part of the Commenter's concerns and explain why other portions were not acceptable to the Committee.

(Log #243) I01 - 98 ( 7 - G . 3 . 4 ) : Reject SUBMITTER: John Behrens, Hun t i ng ton Beach, CA COMMENT ON PROPOSAL NO.: 101-218 RECOMMENDATION: Reject Proposal 101-218. SUBSTANTIATION: At the meeting of the Committee on Safety to L i fe in which the report of the Subcommittee on Building Services and Fire Protection Equipment was discussed, the Committee determined that the term, "v isual " was preferrable to " v i s i b l e " as any alarm device is v i s i b l e to the human eye but may not provide a visual warning For example, the existence of a bel l that can be seen is obviously v i s i b l e but i t does not provide a visual alarm. The Committee made th is change on some proposals (see 101-226) but did not catch them a l l . COMMITTEE ACTION: Reject.

However For ed i t o r i a l consistency change Committee Action on TCR Proposal lOl 226 from Accept in Pr inc ip le to Accept. COMMITTEE COMMENT: The term " v i s i b l e " ( rather than "v isua l " ) f l r e alarm indicat ing appliance is proper as used in the signal ing standards (see NFPA 72G). Also see dlct ionary de f i n i t i ons fo r c l a r i h c a t i o n that " v i s l b le " is correct term.

(Log #392) 101 99 - (7-6.3.9 Exception No. I ) : Accept in Pr inc ip le SUBMITTER: Kenneth Bush, Easton, MD COMMENT ON PROPOSAL NO.: I01-227 RECOMMENDATION: Reject Proposal 101 227. SUBSTANTIATION: This would al low f i r e alarm systems to be used For continuous operations such as music and general paging. This w i l l subject a Fire alarm system to excessive vandalism and sabotage. Anybody that has ever worked in an o f f i c e bu i ld ing that has piped in music is readi ly Famil iar with the sabotage done to speakers to make them nonoperable. The select ive paging allowed by the Code is already questionable, th is extension is unreasonable. The substant iat ion

states presently that there is no reason to p roh ib i t the use of th is system fo r other purposes; th is is not documented by actual i ns ta l l a t i ons in the f i e l d which are constantly being overridden and vandalized. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise Exception No. l to 7-6.3.9 to read: Exception No. 1: Voice communication systems may be

used fo r other purposes, subject to the approval of the author i ty having j u r i s d i c t i o n , i f the Fire alarm System takes precedence over a l l other signals. COMMITTEE COMMENT: There are some cases where a combined f i r e alarm voice communication and paging/music system can be safely useo. I t is appropriate to l e t the AHJ judge the merits on a case by case basis and not al low such use where sabotage of speakers is probable. This action should sa t i s f y the Commenter's in tent .

(Log #3) lOl - tO0 - (7 6.3.11 (New)): Reject SUBMITTER: Martin H. Reiss, The Gamewell Corp. COMMENT ON PROPOSAL NO.: 101 215 RECOMMENDATION: Add new paragraph as Follows:

7-6.3.11 No t i f i ca t i on From automatic Fire detectlon actuation can be delayed up to 180 seconds in order to al low trained personnel the time to invest igate the cause of an alarm signal acknowledged at the control un i t . I f both the detector alarm condit ion is not removed and the control un i t is not reset in th is t~me period, a l l system no t i f i ca t i ons w i l l automatical ly be i n i t i a t e d . SUBSTANTIATION: This w i l l allow For a f a i l - s a f e delay. I t is d i f f e ren t from a pre-signal system in that a subsequent action to i n i t i a t e system n o t i f i c a t i o n is not required. For th is reason, i t should be c lear ly defined in the Code. The purpose of th is delay is to avoid nuisance alarms. The delay is only For detector actuated alarms. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Comment introduces material which has not had publlc review. Commenter is encouraged to submit the topic as a proposal fo r the next (1991) ed i t ion of the Code when proposals are again being accepted.

(Log #382) I01 - lOl - (7-6.5.2) : Reject SUBMITTER: Vie O. Humm, Vic Humm & Assoc. COMMENT ON PROPOSAL NO.: I01 244 RECOMMENDATION: AFter the word "actuated" insect the words "or monitored as l i s ted hereaf ter" .

AFter subheading (b) add the Following: I. Monitor Fans For a v a i l a b i l i t y of operating power. 2. Mon i to r c o n t r o l swi tches and remote s e r v i c e

d i sconnec t swi tches to be in the au tomat i c o p e r a t i o n p o s i t i o n . SUBSTANTIATION: Because s t a i r w e l l s are the bas ic essential path of e x i t and s ta i rwe l l pressur izat ion was designed to minimize the ingress of unsafe environmental a i r . The items which could impair the proper funct ioning of th is required System should not be treated any d i f f e ren t than those that would impalr the operation of a bui ld ing extinguish-system. The Commlttee already recognizes th is in paragraph 7-7.2.1. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee believes that the comment applies to Proposal No. I01-247, not I01-244. Regardless of proposal number, the comment introduces material which has not had public review. Commenter is encouraged to submit the topic as a proposal fo r the next (1991) ed i t ion of the Code when proposals are again being accepted.

(Log #394) 101 - 10Z - ( 7 - 6 . 5 . 2 ( a ) ) : Accept in P r i n c i p l e SUBMITTER: Herman B. Hare, C a r r o l l County V o l u n t e e r Firemans Assn. COMMENT ON PROPOSAL NO.: 101-243 RECOMMENDATION: Revise Sec t ion 7 - 6 . 5 . 2 ( a ) to read:

(a) E l e v a t o r capture and c o n t r o l s h a l l be accompl ished by a c t i v a t i o n o f the e l e v a t o r lobby smoke d e t e c t o r , e l e v a t o r machine room smoke d e t e c t o r and /o r o t h e r dev ices as r e q u i r e d by the A u t h o r i t y Having J u r i s d i c t i o n .

286

SUBSTANTIATION: Modern building design tends to prevent smoke migration into public ex i t access corridors and elevator lobbies from other areas of the building• Considering this fact coupled with the use of selective evacuation of f loors upon the actuation of automatic/manual Fire alarm devices, there is a high probabi l i ty that:

• building occupants could become trapped within the elevator lobby by inadvertently using the elevators to reach a Floor on which a Fire emergency may be located,

. building occupants on the f i r e f loor may use the elevator in a f i r e emergency which could delay their evacuation and by overcrowding, blockage of the elevator doors may occur, thus preventing their closure and creating a panic situation,

• building occupants may become trapped within the elevator during a Fire emergency as a result of a power fa i lu re ,

• Fire fighters may not have immediate use of the elevators with the knowledge that no one may be trapped within the elevators,

• the extinguishment of a Fire may be delayed while f i r e f ighters wait for the elevator after operating the phase 2 recall feature, this waiting period could be several minutes depending upon the height of the building.

Our paramount concern regarding th~s matter should be the l i f e safety of building occupants and Fire fighters and not the possible inconvenience to the public by the so called "nuisance" alarm• In the past 10 years this state has not experienced the numerous nuisance alarms as stated in Log 309, nor has i t experienced the disconnection of the recall Feature. COMMITTEE ACTION: Accept in Principle•

See Comment IOl 108 on 7-6.5.2(F) (Log #S) and current wording of 7-4.4. COMMITTEE COMMENT: Above referenced actions should sat is fy Commenter's intent.

(Log #340) I01 - 103 - (7-6.5•2(a)): Accept in Principle. SUBMITTER: John Warner, Carroll County Volunteer Fire Chiefs ASSOC. COMMENT ON PROPOSAL NO.: I01-243 RECOMMENDATION: Revise Section 7-6.5.2(a) to read:

(a) Elevator capture and control shall be accomplished by activation of the elevator lobby smoke detector, elevator machine room smoke detector and/or other devices as required by the Authority Having Jurisdiction. SUBSTANTIATION: Modern building design tends to prevent smoke migration into Public ex i t access corridors and elevator lobbies From other areas of the building. Considering this Fact coupled with the use of selective evacuation of f loors upon the actuation of automatic/manual Fire alarm devices, there is a high probabi l i ty that:

• building occupants could become trapped within the elevator lobby by inadvertently using the elevators to reach a f loor on which a f i r e emergency may be located,

. building occupants on the Fire Floor may use the elevator in a f i r e emergency which could delay their evacuation and by overcrowding, blockage of the elevator doors may occur, thus preventing their closure and creating a panic situation,

• building occupants may become trapped within the elevator during a Fire emergency as a result of a power fa i lu re ,

• f i r e fighters may not have immediate use of the elevators with the knowledge that no one may be trapped within the elevators,

. the extinguishment of a f i r e may be delayed while f i r e fighters wait For the elevator af ter operating the phase 2 recall feature, this waiting period could be several minutes depending upon the height of the building.

Our paramount concern regarding this matter should be the l i f e safety of building occupants and Fire fighters and not the possible inconvenience to the public by the so called "nuisance" alarm. In the past I0 years this state has not experienced the numerous nuisance alarms as stated in Log 309, nor has i t experienced the disconnection of the recall feature.

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¢OMMITTEE ACTION: Accept in Principle. See Comment 101-108 on 7-6.5.2(F) (Log #5) and

current wording of 7-4.4. COMMITTEE COMMENT: Above referenced actions should sat isfy Commenter's intent.

(Log #190) 101 - 104 - (7-6.5.2(a)): Accept in Principle SUBMITTER: John F• Bender, Office of State Fire Marshal, MD COMMENT ON PROPOSAL NO.: I01-243 RECOMMENDATION: Revise Section 7-6.5.2(a) to read:

(a) Elevator capture and control shall be accomplished by activation of the elevator lobby smoke detector, elevator machine room smoke detector and/or other devices as required by the Authority Having Jurisdiction. SUBSTANTIATION: Reference to ANSI/ASME AI7.1 Rule 211.3b prohibits emergency elevator recall by any device other than a smoke detector located in an elevator lobby or in an elevator machine room. This is a signif icant change from prevlous editions of the ANSI/ASME A17.1 Standard or NFPA lOl. Previous editions essentially would allow activation of the building f i r e alarm system to automatically recall elevators to a designated safe egress f loor . As such, a l l elevators and their occupants could be safely accounted for and the elevators would be immediately available for emergency operation and use by the Fire department upon ar r iva l .

The proposed revision is to delete reference to the ANSI/ASME A17.1 code since the above referenced rule creates a potential l i f e safety threat to elevator occupants who may be comp le te l y unaware o f the a c t i v a t i o n o f the b u i l d i n g F i re a la rm system (presumably f o r some f i r e or o the r emergency c o n d i t i o n which may r e q u i r e b u i l d i n g evacua t i on ) and are unab le to immedia te ly c o n t r o l the e l e v a t o r in o rde r to reach a safe egress F loo r ,

Modern b u i l d i n g design and the use o f va r i ous smoke con t r o l systems may prevent smoke m i g r a t i o n i n t o p u b l i c e x i t access c o r r i d o r s and e l e v a t o r l obb ies thus caus ing a de lay or perhaps no a c t i v a t i o n o f the e l e v a t o r lobby smoke detector• Considering this Fact coupled with the practice of selective evacuation of f loors and zones upon the activation of automatlc/manual Fire alarm devices there is a high probabil i ty that:

I. Building occupants may become trapped by smoke and f i r e within the elevator and/or elevator shaft, by inadvertently using the elevator at the time of f i r e alarm system activation.

2. Building occupants on the Fire f loor may attempt to use the elevator in a f l r e emergency which could delay their evacuation; or they may attempt to overcrowd the elevator and block the elevator doors.

3. Building occupants may become trapped within the elevator and/or elevator shaft during a f i r e emergency as a result of a power Failure.

4. Elevator occupants may not be immediately accounted for during a Fire emergency thus requiring the arriving f i r e department to immediately devote limited manpower resources to search and rescue assignments for elevator occupants at the possible expense of other known trapped building occupants and necessary f i r e control e f for ts .

5. Elevators may not be immediately available to the f i r e department upon their ar r iva l , thus delaying f i r e department emergency use and operation to i n i t i a t e possible rescue and f i r e control operations. This waiting period may be several minutes depending upon the height of the building.

Our paramount concern regarding this issue is the l i f e safety of building occupants and f i r e f ighters during a f i r e or other related emergency and not the possible inconvenience to the public by alleged "nuisance alarms." We believe the authority having jur isdict ion (AHJ) must be given suf f ic ient F l e x i b i l i t y and discretion to specify and/or approve which Fire alarm system devices shall activate elevator recall based on a total evaluation of building occupancy, construction and protection Features as well as local Fire department operations. This same degree of f l e x i b i l i t y incidental ly should be afforded to building designers and their f i r e protection consultants who ultimately are responsible For the total building design and Fire protect ion/ l i fe safety features, subject to approval by the AHJ.

COMMITTEE ACTION: Accept in Pr inc ip le . See Comment I01-I08 on 7-6.5.2(F) (Log #5).

COMMITTEE COMMENT: The Committee Action on Comment lOt- t08 (Log #5) should sa t i s fy the Commenter's in tent .

(Log #93) 101 - 105 - (7 -6 .5 .2(a) ) : Accept in Pr inc ip le SUBMITTER: Christopher L. Conroy, Montgomery County Fire Marshal's OFfice, MD COMMENT ON PROPOSAL NO.: 101-243 RECOMMENDATION: Revise Section 7 6.5.2(a) to read:

(a) Elevator capture and control shal l be accomplished by ac t iva t ion of the elevator lobby smoke detector, elevator machine room smoke detector and/or other devices as required by the Author i ty Having Ju r i sd i c t i on . SUBSTANTIATION: Modern bui ld ing design tends to prevent smoke migration into public ex i t access c o r r i d o r s and e l e v a t o r lobb ies From o ther areas o f the b u i l d i n g . Consider ing t h i s f a c t coupled w i t h the use o f s e l e c t i v e evacuat ion o f F loors upon the a c t u a t i o n o f automat ic/manual f i r e alarm dev ices , there is a high p r o b a b i l i t y t h a t :

b u i l d i n g occupants could become trapped w i t h i n the elevator lobby by inadvertent ly using the elevators to reach a Floor on which a Fire emergency may be located,

bui ld ing occupants on the Fire Floor may use the elevator in a Fire emergency which could delay t he i r evacuat ion and by overcrowding, blockage of the e l e v a t o r doors may occur, thus p reven t ing t h e i r c losu re and creating a panic s~tuation,

bui ld ing occupants may become trapped w i th in the elevator during a Fire emergency as a resu l t of a power Fai lure,

Fire Fighters may not have i nlnedlate use of the elevators with the knowledge that no one may be trapped w i th in the elevators,

the extinguishment of a Fire may be delayed while Fire Fighters wait For the elevator a f te r operating the phase 2 recal l feature~ th is wait ing perlod could be several minutes depending upon the height of the bu i ld ing.

Our paramount concern regard lng t h i s mat te r should be the l i f e s a f e t y o f bu i l d i ng occupants and f l r e F igh te rs and not the poss ib le inconvenience to the pub l i c by the so c a l l e d "nuisance" a larm, which may or may not e x i s t . COMMITTEE ACTION: Accept in P r i n c i p l e .

See Comment 101-I08 on 7 -6 .5 .2 (F ) (Log #5). COMMITTEE COMMENT: The Committee Ac t ion on Comment 101-108 (Log #5) should s a t i s f y the Commenter's i n t e n t .

(Log #409) 101 - 106 - (7 -6 .5 .2(a) ) : Reject SUBMITTER: Patrick E. P h i l l i p s , Las Vegas, NV COMMENT ON PROPOSAL NO.: I01-243 RECOMMENDATION: Do not delete 7-6.5.2(a) as requested by proposal 10]-243. SUBSTANTIATION: As wr i t ten , i t conforms to the ANSI standard in that elevator lobby detectors are part of the bu i ld ing alarm system. They can be a separate zone to f u l l y comply with the ANSI standard, or could include other cor r idor detectors i f the local code requires a more r e s t r i c t i v e standard.

The a l legat ion of "nuisance" alarms probably means the detectors are not ins ta l led and maintained in accordance with NFPA 72E. A s e n s i t i v i t y test would e l iminate hypersensit ive detectors, i f done at i n i t i a l acceptance. IF detectors are properly cleaned, most of the remaining problems would be el iminated. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 101-108 on 7-6.5.2(F) (Log #S). The Committee Action on Comment 101-108 (Log #5) explains the Committee's th inking on the subject.

(Log #350) lOl - I07 - (7 -6 .5 .2(a) ) : Reject ~UBMITTER: Samuel S. Levinrad, Veterans Administrat ion COMMENT ON PROPOSAL NO.: I01-243 RECOMMENDATION: This proposal should be changed From "Accept" to "Reject".

SUBSTANTIATION: The ANSI/ASME A-17.1 Committee have no idea of the requirements fo r bui ld ing f i r e protect ion. In the case of a f i r e and smoke generation, regardless of whether the smoke is in the elevator lobby or on the Floor, i t is imperative that a l l elevators drop to a predetermined f l o o r . This w i l l prevent passengers From being trapped in these elevators should the f i r e or smoke get out of hand and be drawn into the elevator hoistway. The fact that there are problems with Smoke detectors causing nuisance alarms is no reason to degrade Fire protect ion requirements. This more appropr iately belongs as an Appendix item rather than a mandatory i tem. COMMITTEE ACTION: Re jec t . COMMITTEE COMMENT: See Comment 101-108 on 7 - 6 . 5 . 2 ( f ) (Log #5) and the Committee Act ion and Committee Comment on TCR Proposal 101-243 These exp la in the Committee's t h i nk i ng on the sub jec t

(Log #5) I01 - I08 - (7 6.5.2(F) New)): Accept in Pr inc ip le S]JBMITTER: Martin H. Reiss, The Gamewell Corp. ~_OMMENT ON PROPOSAL NO.: I01-243 RECOMMENDATION: Add item ( f ) as fo l lows:

( f ) Elevator reca l l when actuated by just the elevator lobby or associated machine room detectors in the system• SUBSTANTIATION: There are protect ive signal ing and con t ro l systems where the above item can be implemented. COMMITTEE ACTION: Accept in Pr inc ip le .

In 7 -6 .5 .3 add a second sentence tO read: " A d d i t i o n a l l y , the p r o t e c t i v e s i g n a l i n g and con t ro l

system may r e c a l l e l e v a t o r s , as requ i red by 7-4 .4 , i f the a c t i v a t i o n o f the System For t h i s purpose comes on ly From e l e v a t o r lobby or assoc ia ted machine room detectors, or i f otherwise permitted by the author i ty having j u r i s d i c t i o n . "

Revise 7-4.2 and 7-4.3 as fol lows: "Except as modified hereln . . . . ". Further revise 7-6.5.5 (as addressed by TCR Proposal

I01-250) to read: ". . . which provides any of the Functions of 7-6.5.2

or elevator capture per 7 6.5.3, e.g., motor con t ro l l e r fo r . . ." . COMMITTEE COMMENT: The 7-6.5.2 menu items represent Functions that may be required by other sections of the Code to be act ivated by the bui ld ing alarm system. Ac t i v ia t ion of elevator recal l by the alarm System should not be mandated by the Code, but rather allowed as a permissive Feature of 7-6.5.3 and then only i f :

( I ) jus t the elevator lobby or associated machine room detectors act ivate the bui ld ing alarm fo r purposes of elevator r eca l l , or

(2) the au thor i ty having j u r i s d i c t i o n s p e c i f i c a l l y permits the bu i ld ing alarm, regardless of ac t i va t ion source, to recal l the elevators.

The rev is ion to 7-6•5.5 w i l l c l a r i f y that the elevator lobby and machine room smoke detectors and associated wi r ing, which are part of the bui ld ing alarm system, also need monitoring.

(Log #453) 101 - 109 - (7-6 .5 .5) : Reject SUBMITTER: Wil l iam E. Kof fe l , KoFfel Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-250 RECOMMENDATION: Revise 7-6.5.5 to read as fo l lows:

7-6.5.5 The i n s t a l l a t i o n wir ing between the protect ive s ignal ing and control system panel and the a u x i l i a r y f i r e alarm relay shall be monitored fo r i n t eg r i t y .

Retain the ex is t ing Appendix note. SUBSTANTIATION: The a u x i l i a r y f i r e alarm relay is often located in the Fire alarm control panel and not near the emergency control device• The proposed wording above appears to meet the supervision requirements intended by the Committee and the proponent.

Deletion of the Appendix note and the wording in the proposal would impact ex is t ing i ns ta l l a t i ons without providing adequate substant iat ion.

288

COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The relay addressed by this requirement needs to be located within 3 f t of the emergency control device, as required by both the current Code wording and the TCR proposed wording change, so as not to have long runs of wiring without monitoring which could adversely affect the control function.

(Log #246) I01 - II0 - (7-6.6.1): Accept in Principle SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: 101-253 RECOMMENDATION: Do not delete the second sentence of 7-6.6.I but revise i t to read as follows:

"Controls used by the f i r e department shall be located as designated by the authority having j u r i sd i c t i on . " SUBSTANTIATION: I t is agreed that i t might not always be practical to locate control centers adjacent to an entrance but i t is important that controls used by the Fire department be located in a position approved by them. This revised wording would emphasize this need to coordinate this task and, at the same time, eliminate the burden of mandate that would be located near an en t rance . COMMITTEE ~ T I O N : Accept in P r i n c i p l e .

Add the words "accep tab le to the a u t h o r i t y hav ing j u r i s d i c t i o n " to the end o f the f i r s t sentence o f 7 -6 .6 .1 as m o d i f i e d by TCR Proposal I01-253 ( s t i l l deleting the second sentence) so as to read:

7-6.6.1 Operator controls, v is ib le alarm annunciators, and manual COmmunications capabi l i ty sh~ll be instal led in a control center at a convenient location acceptable to the authority having ju r isd ic t ion . COMMITTEE COMMENT: The Committee Action should sat is fy the Commenter's intent.

(log #244) I01 - 111 - (7-5.6. I ) : Reject SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: 101-252 RECOMMENDATION: Reject Proposal 101-252. SUBSTANTIATION: At the meeting of the Committee on Safety to Life in which the report of the Subcommittee on Building Services and Fire Protection Equipment was discussed, the Committee determined that the term, "visual" was preFerrable to "v is ib le" as any alarm device is v is ib le to the human eye but may not provide a visual warning For example, the existence of a bell that can be seen is obviously v is ib le but i t does not provide a visual alarm. The Committee made this change on some proposals (see I01-226) but dld not catch them a l l . COMMITTEE ACTION: Re3ect. COMMITTEE COMMENT: See Committee Action and Committee CommenL on Comment 101-98 on 7-6.3.4 (Log #243).

(Log #245) lOl - It2 - (7--6.6.1): Reject SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: I01-253 RECOMMENDATION: Reject the revisions of "visual" to "v is ib le" . SUBSTANTIATION: At the meeting of the Committee on Safety to Life in which the report of the Subcommittee on Building Services and Fire Protection Equipment was discussed, the Committee determined that the term, "visual" was preFerrable to "v is ib le" as any alarm device is v is ib le to the human eye but may not provide a visual warning. For example, the existence of a bel l that can be seen is obviously v is ib le but i t does not provide a visual alarm. The Committee made this change on some proposals (see I01-226) but d~d not catch them a l l . COMMITTEE ACTION: Reject. COMMITTEE COMMEN!: See Committee Action and Committee Comment on Comment 101-98 on 7 6 . 3 . 4 (Log #243).

(Log #386) 101 - 113 - (7-7.2.1): Reject SVBMITTER: Vic D. Humm, Vic Humm & ASSOC. COMMENT ON PROPOSAL NO=: IOI-N/A RECOMMENDATION: Substitute the following text "automatic sprinkler or other approved extinguishing system" for the words "automatic sprinkler".

For the words "sprinkler system" insert the words "sprinkler system or other approved extinguishlng system". SUBSTANTIATION: This is to coordinate with paragraph 7-7.3 to require supervision of any thing that would impair the operation of that other type of extinguishing system such as loss of power to the extinguishing System control panel or a lack of monitoring in tegr i ty of means of actions by devices such as heat detectors. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Comment introduces new material which has not had public review. Commenter is encouraged to submit the topic as a proposal for the next (1991) edit ion of the Code when proposals are again being accepted.

(Log #385) 101 114 - (7-7.2.2): Reject SUBMITTER: Vic D. Humm, Vic Humm & Assoc. COMMENT ON PROPOSAL NO.: IOI-N/A RECOMMENDATION: Substitute the words "automatic sprinkler or other e<tinguishing'" For the words "automatic spr inkler". SUBSTANTIATION: This Is to coordinate with the alternative method outlined in paragraph 7-7.3* and require similar types of supervision of points of impairment of the al ternat ive type of system. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Comment introduces new material which has not had public review. Commenter is encouraged to submit the topic as a proposal For the next (1991) edit ion of the Code when proposals are again being accepted.

(Log #384) I01 - 115 - (7-7.2.3): Reject SUBMITTER: Vic D. Humm, Vic Humm & Assoc. COMMENT ON PROPOSAL NO~: I01-N/A RECOMMENDATION: Substitute the words "automatic sprinkler or other type of extinguishing" for the words "automatic spr inkler" . SUBSTANTIATION: This is to coordinated with the a l t e r n a t i v e e s t a b l i s h e d in paragraph 7-7 .3 ~ and impose equal s u p e r v i s i o n requ i remen ts by o the r methods o f extinguishment. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Comment introduces new material which has not had public review. Commenter is encouraged to submit the topic as a proposal for the next (1991) edit ion of the Code when proposals are again being accepted.

(Log #247) I01 - 116 - (8-1.3): Accept in Principle ~UBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO=: 101-259 RECOMMENDATION: Revise the proposed def in i t ion of "Amusement Building" to read as follows:

Amusement Building. Any building, temporary, permanent, or mobile conformed such that the means of egress is not readily apparent due to visual distractions, audio distractions or in tent ional ly confounded egress path or is not readily available due to mode of conveyance of occupants through the building. SVBSTANTIATION: The Board For the Coordination of Model Codes has established a special amusement building Ad Hoc Committee. The def in i t ion proposed in this comment is the de f in i t ion which is presently being worked on by that Committee. The purpose of this comment is to give the Subcommittee on Assembly and Educational Occupancies an opportunity to review this def in i t ion.

289

CQMMITTEE ACTION: Accept in Pr inc ip le . Revise the proposed d e f i n i t i o n to read as Follows: Special Amusement Bui ld ing. Any bui ld ing, temporary,

permanent or mobile, containing a device or system which conveys passengers or provides a walkway along, around or over a course in any d i rect ion as a Form of amusement so arranged that the egress path is not read i ly apparent due to visual or audio d is t rac t ions or i n ten t i ona l l y confounded egress path, or is not read i ly avai lable due to the mode of conveyance through the bui ld ing or s t ructure. Included are such amusements as a "haunted house", a " r o l l e r coaster" type r ide wi th in a bui ld ing, a "merry-go-round" wi th in a bu i ld ing, a "submarine" r ide and s im i la r amusements where the occupants are not in the open a i r .

Throughout the chapter, change "amusement bu i ld ing" to "special amusement bu i ld ing" . ~MMITTEE COMMENT: The Committee Action should sa t i s fy the Commenter's in tent .

(Log #249) I01 - 117 - (8-1.3) : Accept SVBMITTER: John Behrens, Huntington Beach, CA ~QMMENT ON PROPOSAL NO.: I01-2Gi RECOMMENDATION: Delete the d e f i n i t i o n of "Restaurant" and of "Nightclub" from 8-1.3. SUBSTANTIATION: The de f i n i t i ons of "Restaurant" and "Nightclub" are no longer necessary as Proposal I01-305 is recommending the delet ion of the exemption fo r restaurants. This exemption was the only reason for the need for these de f i n i t i ons . OC~QMMITTEE ACTIOn: Accept.

(Log #4171 I01 - 118 - (8-1.3} : Accept in Pr inc ip le SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-259 RECOMMENDATION: Revise the proposed d e f i n i t i o n of "Amusement Bui lding" so as to delete reference to "10 persons". SVBSTANTIATION: The proposed de f i n i t i on needs rev is ion and the above comment w i l l al low the Committee lo revise i t as necessary. COMMITTEE ACTION: Accept in Pr inc ip le .

See action on Comment 101-116 on 8-1.3 (Log #247). COMMITTEE COMMEN!: The Committee Action on Comment I01-I16 (Log #247) should meet the Commcnter's in ten t .

(Log #3191 I01 - I19 - (8 1.3): Accept in Pr inc ip le SUBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO.: 101-650 RECOMMENDATION: Any bui ld ing, e i ther temporary, permanent or mobile, which is used to or intended to entertain or amuse more than ten (I0) persons, while they are walking or being conveyed, and which possesses any unusual Features that might lessen the occupant's a b i l i t y to recognize the means of egress, such as visual or audible d is t rac t ions , amusement rldes intended to run in reduced l i gh t i ng levels, or mazes. SUBSTANTIATION: The d e f i n i t i o n of an "amusement bui ld ing" as proposed is very vague; i t could eas i ly be interpreted to include many bui ldings and structures that are not intended, such as movie theaters, museums, restaurants, auditoriums, and dance hal ls . COMMITTEE ACTION: Accept in Pr inc ip le .

See action on Comment I01-I16 on 8-1.3 (Log #247). ~OMMITTEE COMMENT: The Committee Action on Log #247 should sa t i s fy the Commenter's in tent .

(Log #320) I01 - 120 - (8-1.3) : Reject SUBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL N O . : 101-650 RECOMMENDATION: None. SUBSTANTIATION: There may be a c o n f l i c t between the proposed d e f i n i t i o n of an Amusement Bui lding (NFPA 101 - 8 - I .3 , Log #650) and the ex is t ing paragraph on Outdoor Assembly (NFPA I01 - 8-4.2.1) .

~OMMITTEE ACTION: Reject. COMMITTEE COMMENT: Commenter did not submit a recommendation. See action on Comment l O l - l l 6 on 8- I .3 (Log #247).

(Log #l lS) I01 - 121 - (8-1.3) : Reject SUBMITTER: John D. Degenkolb, Carson City, NV ~OMMENT ON PROPOSAL NO.: I01-261 RECOMMENDATION: Expand the scope of the proposed revis ion to the d e f i n i t i o n of the word "Restaurant" so that i t applies to 9 - I .3 fo r ex is t ing assembly occupancies. SUBSTANTIATION: The proposed revised d e f i n i t i o n of "Restaurant" is an improvement over the current d e f i n i t i o n in Chapter 9 fo r ex is t ing assembly occupancies. I f another comment that I submitted on Proposal IOl-30 on 8-3.5. I is accepted, the d e f i n i t i o n of restaurant w i l l be deleted from Chapter B because i t w i l l no longer be used in that chapter. With respect to Chapter g, the restaurant e<ception to the spr ink le r requirement w i l l be retained and the improved d e f i n i t i o n w i l l be useful. ~MMITTEE ACTION: Reject. COMMITTEE COMMENT: The d e f i n i t i o n s of "restaurant" and "nightclub" are no longer necessary as Proposal 101-305 is recommending the delet ion of the Exception fo r restaurants. This Exception was the only reason For the need For these de f i n i t i ons . See Action on Comment 101-117 on 8-1.3 (Log #249).

(Log #248) I01 -- 122 - (8-1.3 and 9-1.31: Accept SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: 101-262

I RECOMMENDATION: Move the proposed d e f i n i t i o n of "Cyclorama" from the Appendix into the Code. SUBSTANTIATION: The term, "Cyclorama" is included wi th in the new d e f i n i t i o n of "Stage Scenery" contalned in Proposal 101-264 and, therefore, i t should be moved from the Appendix into the Code. ~OMMITTEE ACTION: Accept.

(Log #I161 101 - 123 - (8-1.3 and g 1.31: Accept SUBMITTER: John G. Oegenkolb, Carson City, NV C~OMMENT ON PROPOSAL NO.: I01-2G4 RECOMMENDATION: Reword the introductory phrases to the d e f i n i t i o n of "Stage" by adding the words " u t i l i z i n g drops or scenery or other Stage e f fec ts and" so as to read:

Stage. An area w i th in a bu i ld ing used fo r the purpose of entertainment and u t i l i z i n g drops or scenery or other stage ef fects and shal l be c lass i f i ed as one of the fo l lowing: (Retain proposed (a) through (c ) . ) ~_VBSTANTIATION: Given that a s tage- l ike area is e i ther a "stage" or a "plat form" and that a platform, by d e f i n i t i o n , has no drops, scenery or stage e f fec ts , the "stage" must have these items. COMMITTEE ACTION: Accept.

(Log #105) I01 - 124 - (B-2.3.1): Accept in Pr inc ip le SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: 101-272 RECOMMENDATION: The same Exception, as proposed in 101-272, should be included in Chapter 9. ~JJBSTANTIATION: Presumably, i f good enough For new bui ld ings, the changes proposed in B-Z.5.5.6 should also be appl icable to ex is t ing bui ld ings. ( I t appears to be a simple oversight that th is was not proposed also fo r Chapter 9.) COMMITTEE ACTION: Accept in Pr inc ip le .

Add an Exception to 9-2.3.1 to read: Exception: Means of egress serving assembly seating

shal l be permitted to be in accordance with 9-2.5.6.6. COMMITTEE COMMENT: The Committee agrees that the Exception fo r Chapter 9 should be included.

290

(Log #331) lOl - 125 - (8-2.3.2): Accept SUBMITTER: John G. Degenkolb, National Assn. of Theatre Owners COMMENT ON PROPOSAL NO.: 101-275 RECOMMENDATION: Change main ex i t to main entrance/exit. SUBSTANTIATION: To be consistent with action taken on Proposal I01-274. COMMITTEE ACTION: Accept.

(Log #117) I01 - 126 - (8-2.3.2, 8-2.3.3, 9-2.3.2 and 9-2.3.3): Accept SUBMITTER: John G. Degenkolb, Carson City, NV ~MENT ON PROPOSAL NO.: I01-274, 275, Z76 _RECOMMENDATION: Change the term "main exi t " to "main entrance/exit" in:

( I ) The second sentence of current 8-2.3.2 and 9-2.3.2.

(2) Exception No. I of current 8-2.3.2 and 9-2.3.2. (3) The proposed new last sentence of 8-2.3.2, and (4) The f i r s t sentence of 8-2•3.2 and 9-2.3.3.

SUBSTANTIATION: Coordination with use of the term "main entrance/exit" as introduced by Proposal 101-274. COMMITTEE ACTION : Accept.

(Log #120) lot - 127 - (8-2.5 and 9 2.5): Accept SUBMITT.ER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO~: 101-280 RECOMMENDATION: In proposed 8-2.5.5.8 and 9-2.5.5.8 change ". . . the aisle is required plus . . . . " to ". • . the minimum aisle width is required plus . . . . " SUBSTANTIATION: C lar i f i ca t ion of intent. Words were dropped by mistake during the Processing of the proposal. COMMITTEE ACTION: Accept.

(Log #I06) lOt - 128 - (8-2.5.3.2 Exception (New) and 9-2.5.3.2 Exception (New)): Reject SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-280 RECOMMENDATI~: Add Exception as follows:

Exception: For smoke-protected assembly seating, for which a Life Safety Evaluation is done, as described by 8-2.5.3.6, the minimum clear width need only be increased with rows longer than 14 seats plus one additional seat for every additional 3,000 seats above 4,000, up to a total of 25,000 seats in the space. SUBSTANTIATION: This provides F lex ib i l i t y of the type t rad i t iona l l y permitted in NFPA I02 type f a c i l i t i e s and is worth considering here because of increased safety provisions in such assembly seating. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This comment introduces new business which has not had public review.

(Log #332) lOt - I29 - (8-2•5.3.2 and 9-2.5.3•2): Accept in Part SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPO_~L NO.: 101-280 RECOMMENDATION: Accept present wording of 8-2.5.3.2 but amend to read:

"For rows of chairs served by aisles or doorways at both ends, there shall be no more than 18 seats per row and the minimum clear width between rows of 12 in. shall be increased by 0.3 in. For every additional seat beyond 14.

Re-insert present 8-2.5.3(F) of the 1985 edition, Continental Seating, to read:

( f ) Continental Seating. I. With continental seating, the spacing of rows

measured horizontally as Follows (automatic or se l f - r is ing seats shall be measured in the seat up position; other seats shall be measured in the seat down position).

Remainder of ( f ) as in the 1985 edition remains.

SUBSTANTIATION: In o rde r to improve s tandard seat~ng the proposal weakens the present provisions for continental seating by removing such ent i re ly even though i t is referenced elsewhere• Continental seating is t ru ly superior, safer, quicker exiting seating than any other devised and should not be lost. C_OMMITTEE ACTION: Accept in Part.

Add an appendix note to 8-2.5.3.2 and 9-2.5.3.2 to read: •

A-8-2.5.3.2 (A-9-2.5.3.2) The system known as "continental seating" has one pair of egress doors provided For every f ive rows and located close to the ends of the rows• In previous editions of the Code, such egress doors were required to provide a minimum clear width of 66 in. discharging into a foyer, lobby, or to the exterior of the building. This continental seating arrangement can result in egress Flow times that are approximately one half as long as those resulting where side aisles lead to more remote doors ( i . e . , with nominal Flow times of approximately tO0 seconds rather than 200 seconds). Such superior egress Flow time performance may be desirable in some situations; however, special attention should be given either to a comparably-good egress capactiy For other parts of the egress systems to suf f ic ient space to accomodate queuing outside the seating space. COMMITTEE COMMENT: The Con~ittee Feels the concerns of the Commenter w i l l be addressed by the addition of the proposed appendix note.

(Log #107) IOl - 130 - (8-2.5.3.3 Exception (New) and 9-2.5.3.3 Exception (New)): Reject SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-280 RECOMMENDATION: Add Exception as follows:

Exception: For smoke-protected assembly seating, for which a Life Safety Evaluation is done, as described in 8-2.5.3.6, the minimum clear width need only be increased w i t h rows longer than 7 seats p lus one a d d i t i o n a l seat f o r every a d d i t i o n a l G,O00 seats above 7,000, up to a t o t a l o f 25,000 seats in the space. ~LB~TANTIATION: This p rov ides f l e x i b i l i t y o f the type t r a d i t i o n a l l y pe rm i t t ed in NFPA I02 type f a c i l i t i e s and is worth considering here because of increased safety provisions in such assembly seating. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This COnrnent introduces new business which has not had public review.

(Log #108) 101 - 131 - (8-2.5.3.4 Exception (New) and 9-2.5.3.4 Exception (New)): Reject SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-280 RECOMMENDATION: Add Exception as follows:

Exception: For smoke-protected assembly seating, for which a Life Safety Evaluation is done, as described by 8-2.5.3.6, the path of travel shall not exceed 50 Ft. SUBSTANTIATION: This provides F l e x i b i l i t y of the type t rad i t iona l l y permitted in NFPA 102 tyPe f a c i l i t i e s and is worth considering here because of increased safety provisions in such assembly seating. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter has not provided suf f ic ient jus t i f i ca t ion to the Committee to warrant the addition of the proposed Exception.

(Log #109) 101 - 132 - ( 8 - 2 . 5 . 3 . 6 and 9 - 2 . 5 . 3 . 8 ) : Accept in Par t ~UBMITTER: Jake Pauls , Wheaton, HD COMMENT ON PROPOSAL NO.: 101-280 RECOMMENDATION: Revise as follows:

8-2.5.3.6 (9-2.5.3.6) Where bleacher or grandstand seating without backs is used indoors, rows of seats shall be spaced not less than 22 in. back to back and the rise per row shall not exceed 12 in. (30.5 cm). Aisles, in accordance with this chapter, shall be provided except as permitted by NFPA 102-1986, Assembly Seating, Tents and Membrane Structures (4--3).

291

SUBSTANTIATION: The requirements For bleacher and grandstand seating without backs, instead of being a repe t i t i on of the 1985 ed i t ion , should bui ld upon the improvements brought into NFPA I02-1986 and the improvements in the remainder of 8-2.5. The text suggested above does th is and i t provides a complete replacement For everything proposed fo r 8-2.5.3.6 in the TCR, including the Exception For fo ld ing or telescoping seating (which is also regulated by NFPA 102-1986 4-3). The length o£ dead end ais les is covered by the proposed 8-2.5.5.4. The text of 4-3.1 of NFPA I02-1986 might be repeated here to make the r e q u i r e m e n t s tand on i t s own.

Note t h a t the maximum 3 0 - i n . spac ing o f rows does no t seem j u s t i f i e d by any safety consideration (where there are ais les) and therefore ~t is deleted. (NFPA 102-1986 l im i t s the spacing to 28 in. only i f no aisles are provided.) COMMIT!EE ACTIONN: Accept in Part.

Revise 8-2.5.3.6 (9-2.5.3.6) to read as Follows: 8-2,5.3.6 (9-2.5.3.6) When bleacher or grandstand

seating without backs is used indoors, rows of seats shal l be spaced not less than 22 in, back to back. COMMITTEE COMMENT: The Committee believes the action taken adequately addresses the concerns of the Commenter.

(Log #118) lOl - 133 - [ 8 - 2 . 5 . 3 . 8 and 9 - 2 . 5 . 3 . 8 ) : Accept SU#]iIT_TER: John G. Degenko lb , Carson C1Ly, NV COMMENT ON PROPOSAL NO.: I01~280 RECOMMENDATION: In proposed 8 2 . 5 . 3 . 8 and 9 2 . 5 . 3 . 8 change "e~ceeds" to "e~ceedlng" so as to read:

" . . . w i t h the pa th o f t r a v e l to an a i s l e exceed ing lO Ft . . . . " SUBSTANTIATION: Better grammar. ~_OHMITTEE ACTION: Accept.

(Log #119) 101 - !34 ( 8 - 2 . 5 . 4 . 1 and 9 2 . 5 . 4 . 1 ) : Accept ~n P r i n c i p l e SVBHITTER: John G. Oegen~olb, Carson C i t y , NV COMMENT ON PROPOSAL NO.: 101-280 RECOMHENDATION: I n proposed 8 - 2 . 5 . 4 , 1 and 9 - 2 . 5 . 4 . 1 :

( t ) Change " s h a l l no t be p e r m i t t e d u n l e s s the r e q u i r e d 12 i n . ( 3 0 . 5 cm) c l e a r a n c e between rows o f c h a i r s i s p rov ided . . . . " t o :

" s h a l l no t be p e r m i t t e d u n l e s s the r e q u i r e d c l e a r a n c e between rows o f c h a i r s is p r o v i d e d . . . . " , and

(2) Change " . . . where c o n t i n e n t a l s e a t i n g i s used . . . . " to:

". . . where the number of seats exceeds 14 fo r cows served by aisles or doorways at both ends or exceeds 7 For rows served by an a is le or doorway at one end only

SUBSTANTIATION: ( I ) The requlred clearance is not always 12 in. The clearance must then increase by 0.3 in. or 0,6 in. per seat fo r longer rows, therefore simply re fe r to the requlred clearance,

(2) The term "continental seating" is to be no longer used i f the proposed TCR changes occur. COMMITTEE ACTION: Accept in Pr inc ip le .

See a c t i o n taken on Comment 101-135 on 8 2 . 5 . 4 . 1 and 9 - 2 . 5 . 4 . 1 (Log # I I 0 ) . COMMITTEE COMMENT: The Commit tee A c t i o n on Comment 101-135 (Log #II0) should sa t i s f y the Commenter's in tent .

(Log #I I0) 101 - 135 - (8-2.5.4.1 and 9-2 .5 .4 .1) : Accept YUBMITT_ER: Jake Pauls, Wheaton, HD COMMENT ON PRO~SAL NO.: I01-280, 281 RECOMMENDATION: Delete the phrase "where continental seating is used."

In the second sentence replace the phrase "required 12 in. (30.5 cm) clearance" with "clearance required by 8 - 2 . 5 . 3 . "

The same changes shou ld a l s o be made i n c o r r e s p o n d i n g r e q u i r e m e n t s i n Chap te r 9.

SUBSTANTIATION: With the delet ion of special rules fo r continental seating (now covered general ly) there is no need to re fe r to i t here. The suggested change on spacing requirements takes into account the larger spacing required, beyond 12 in . , depending on row length. COMMITTEE ACTION: Accept.

(Log # I I I ) 101 - 136 (8-2.5.5.4 Exception No. 2 (New) and 9-2.5.5.4 Exception No. 2 (New)): Reject SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-280 RECOMMENDATION: Add a second Exception as Follows"

Exception No. 2: For smoke-protected assembly seating, For which a L i fe Safety Evaluatlon is done, as described by 8-2.5.3.6, a longer dead end a is le is permitted where Seats served by the dead end a is le are no more than 40 seats From another a is le measured along a row o f sea ts hav ing a minimum c l e a r w i d t h , between rows, o f 12 ~n. p l us 0 .3 i n , For e v e r y a d d i t i o n a l s e a t above 14 i n t he row. SUBSTANTIATION: Th i s p r o v i d e s f l e x i b i l i t y o f the t ype t r a d i t i o n a l l y p e r m i t t e d in NFPA 102 t ype f a c i l i t i e s and is worlh considering here because of increased safety provisions in such assembly seating. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This conm~ent introduces new business whlch has not had public review.

(Log #95) I01 137 - (8 2.5.5.6 and 9-2.5.5.6) : Accept in Pr inc ip le SUBHITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-284 RECOMMENDATION: P rov ide a new 8 - 2 , 5 . 5 . 6 ( 9 - 2 . 5 . 5 . 6 ) and A - 8 - 2 . 5 . 5 . 6 ( A - 9 - 2 . 5 . 5 6) as shown be low:

8-2.5.5.6" Minimum clear widths of a is les and other means o f egress s h a i l be in accordance w i t h Tab le 8 - 2 . 5 . 5 . 6 ( I ) o r , on l> For b u i l d i n g s p r o v i d i n g Smoke P r o t e c t e d Assembly S e a t i n g and For wh ich an Approved L i f e S a f e t y E v a l u a t i o n is conduc ted , Tab le 8 - 2 . 5 . 5 . 6 ( 2 ) . For Table 8 2 . 5 . 5 . 6 ( 2 ) the number o f sea ts s p e c i f i e d must be w i t h i n a s i n g l e assembly Space and i n t e r p o l a t i o n s h a l l be p e r m i t t e d between the s p e c i f i c v a l u e s shown. For both Tab les the minimum c l e a r w i d t h s shown s h a l l be m o d i f i e d in accordance w i t h a l l o f t he F o l l o w i n g :

(a) I f r i s e r s exceed 7 i n . in h e i g h t , m u l t l p l y t he s t a i r w i d t h i n the Tab les by F a c t o r A, where A h 1 + ( r i s e r h e i l h t - 7 . 0 i n . ~

5 (b) S t a i r s no t hav ing a h a n d r a i l w i t h i n a 3 0 - i n .

h o r i z o n t a l d i s t a n c e s h a l l be 25 p e r c e n t w ide r t han o t h e r w i s e c a l c u l a t e d , i . e . , m u l t i p l y by B = 1 .25 .

(c ) Ramps s t e e p e r than 1 in 10 s l o p e , used in a s c e n t , s h a l l have t h e i r w i d t h i n c r e a s e d by I0 p e r c e n t , i . e . , m u l t i p l y by F a c t o r C = I . I 0 .

Tab le 8 - 2 . 5 . 5 . 6 ( I ) Inch of. Clear Width Per-

Seat Served Passageways, Ramps and

No of Seats Flow Time ~ e c . ) Stairs Doorways _

Unlimited 200 0.300 AB 0.220C

Tab le 8 - 2 , 5 . 5 . 6 ( 2 ) (For use o n l y w i t h S m o k e - P r o t e c t e d Assembly S e a t i n g )

I n c h o f C l e a r Wid th Per Seat Served

Passageways, Ramps and

No o f Seats Flow Time L s e ~ S t a i r s _Doorways __ 2 ,000 200 0 .300 AB 0.220C 5 ,000 260 0 .200 AB 0 .150 C

10,000 360 0 .130 AB 0 . I 0 0 C 15,000 46 0.096 AB 0.070 C 20,000 560 0 .076 AB 0 .056 C 25 ,000 o r more 660 0 .060 AB 0 .044 C

292

A-8-2.5.5.6 Tables 8-2.5.6.6(I) and 8-2.5.5.6(2) are based on a l inear relationship between number of seats and nominal flow time, with a minimum of 200 seconds (3.3 minutes) For 2,000 seats plus l second For every additional 50 seats up to 25,000, Beyond 25,000 total seats, the nominal Flow time is l imited to 660 seconds ( I I minutes). Nominal flow time refers to the Flow time for the most-able group of patrons; some less- fami l iar , less-able groups might take longer to pass a point in the egress System. (Although three or more d ig i ts are noted in the Tables, the result ing calculations should be assumed to provide only two s ign i f icant figures of precision.)

The remainder of the Appendix note is as set out in Proposal I01-979 which provides additional guidance on the Li fe Safety Evaluation.

An example calculation may help describe the use of Table 8-2.5.5.6(2).

Within an arena providing Smoke-Protected Assembly Seating and having a total of 12,500 seats; for capacity purposes only, what should be the clear width of an aisle s ta i r , with 8-inch r isers and with a center handrail, providing means of egress for 340 seats? Interpolating between the width (0.13 and 0.096) respectively for I0,000 and 15,000 seat Fac i l i t ies , the required s ta i r width, in inches, per seat served is 0.I13 AB where A is 1.2 and B is 1.0. The aisle s ta i r width, for capacity purposes, is the product of 340 (0.113) (1.2) (l.O) or 46.1 in. In this case a minimum width c r i te r ion of 48 in. (proposed 8 2.5.5.7) w i l l govern i ts width. Previous editions of the Code credited this aisle stair w~th a capacity of only 150 persons. SUBSTANTIATION: Rather than use ill-defined headings (such as "lecture halls" and "gymnasium"), with some size indications, the recommended version, with two tables, covers a greater number of sizes of Facility. Furthermore, interpolation is permltted between the values shown in the second table. Correction Factors For stairs and ramps are specified outside of the tables to simplify their presentation. Nominal flow time for the largest Facilities is limited to 660 seconds or II minutes, the same as noted in NFPA 102 1986, A-3-3.2.2. The terms "Smoke Protected Assembly Seating" and "Life Safety Evaluation" should be listed in a definitions section. (The former- is the same as in NFPA I02-1986 and the latter is simply the first sentence of the Appendix note proposed in 101-979.) "Flow time" may also need to be defined: it is the time during which there is crowd Flow past a point in the means of egress system and it is a component of total evacuation time. COMMITTEE ACTION: Accept in Principle.

Delete 8-2.5.5.6 (9-2.5.5.6) and A-8-2.5.5.6 (A-9-2.5.5.6) as proposed in Proposal I01-284 [Also in Proposal 101-280] and substitute the Following:

8-2.5.5.6 (9 2.5.5.6) The width of aisles shall be sized in accordance with 8-2.3.2 (9-2.3.2).

Revise 8-2.3.1 (9-2.3.1) to read as Follows: 8-2.3.1 (9-2.3.1) The capacity of means of egress

shall be in accordance with Section 5-3 or, in the case of means of egress serving theatre type seating or simi lar seating arranged in rows, in accordance with 8-2.3.2 (9-2.3.2).

Add a new 8 2.3.2 (9-2.3.2) using the Commenter's 8-2.5.5.6 (9-2.5.5.6) as modified below:

On Table 8-2.5.5.6(I) and Table 8-2.5.5.6(2) change the column headings ent i t led "Flow Time" to read "Nominal Flow Time".

On Table 8-2.5.5.6(I) indicate in table heading "For Use Without Smoke Protected Assembly Seating".

On Table 8-2.5.5.6(2) indicate in table heading "For Use With Smoke Protected Assembly Seating".

Also add the following def in i t ions to 8-I.3 (9-1.3): Flow Time. Flow time is the time during which there

is crowd Flow past a point in the means of egress system and i t is a compontent of total evacuation time.

Li fe Safety Evaluation. A l i f e safety evaluation is a writ ten review dealing with the adequacy of l i f e safety Features relat ive to f i r e , storm, collapse, crowd behavior, and other related safety considerations.

Smoke-Protected Assembly Seating. Seating served by means of egress that is not subject to blockage by smoke accumulation within or under a structure.

A-8-I.3 (A-9-I.3) Smoke-Protected Assembly Seating. An assembly area wherein the roof is not less than 15 f t above the highest cross aisle or seat row, and having smoke-actuated venting Fac i l i t ies within that part of the roof su f f i c ien t to maintain the level of smoke at least 6 f t above the highest seating or walking level, is considered to be smoke-protected assembly seating.

Note: All actions apply to Chapters 8 and 9. COMMITTEE COMMENT: The Committee agrees with the Commenter and has included his recommendations with some additional text proposed by the Committee, but moved the material to 8-2.3.1 so as to apply not only to aisles.

(Log #333) 101 - 138 - (8-2.5.5.6 and 9-2.5.5.6): Accept in Principle SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-284 RECOMMENDATION: I t is requested that the Committee rewrite to provlde clearer wording. SUBSTANTIATION: An archltect representlng a major theater chain Found the proposed wording to be confusing.

"Aisles - th~s section needs revision: but the proposed revision submitted by the Subcommittee on Assembly and Educational Occupancies is confusing and difficult to follow. I thlnk simpler alternative criteria should be established. Proposed change I01-283 starts out good but it also becomes confusing." COMMITTEE ACTION: Accept in Principle.

See action on Comment I01 137 8-2.5.5.6 and 9 2.5.5.6 (Log #95). COMMITTEE COMMENT: The Commitee Ac t i on on Log #95 should meet the Commenter's i n t e n t .

(Log #112) 101 - 139 - (8-2.5.5.7 and 9-2.5.5.7): Reject SUBMITTER: Jake PauIs, Wheaton, MD COMMENT ON PROPOSAL NO.: 101-280 RECOMMENDATION: Replace the phrase "In theater and simi lar type seating" with "For seating arranged in rows (not at tables)". SUBSTANTIATION' This wordlng may help to avold interpretat ion d i f f i c u l t i e s . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter has not provided suf f i c ien t j u s t i f i c a t i o n to warrant the proposed change in the Code and Feels the current wording creates no interpretat ion d i f f i c u l t i e s .

(Log #334) 101 - 140 (8-2.5.5.7(g (New) and 9-2.5.5.7(g) (New)): Reject SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-280 RECOMMENDATION: Add a new subsection (g) to read:

(g) No aisle shall be required to have a width of greater than 8 f t . SUBSTANTIATION: The modification of the Code where aisle widths are concerned can result in aisle widths of - in one case at least - of 12 f t where the present Code would have required 8 f t . When you exceed 8 f t in width you run into other problems where ra i l ings are concerned. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See action on Comment I01-137 on 8-2.5.5.6 and 9-2.5.5.6 (Log #95).

The Committee feels that previous action taken w i l l result in reasonable aisle widths without being excessive.

(Log #250) I01 141 - (8-2.7.2 and 9-2.7.2): Accept SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: IOI-N/A

I RECOMMENDATION: Delete 8-2.7.2 and 9-2.7.2. I

293

SUBSTANTIATION: Paragraph 5 7.2 has been revised by Proposal lOt-140 to no longer require the ind iv idual occupancy chapters permit i t s use. Therefore, these paragraphs are no longer necessary and can be deleted under Proposal I01-140. COMMITTEE ACTION: Accept.

COMMITTEE ACTION: Accept in Part. See Committee Action on Comment 101-144 on 8-3.2.1.7

(Log #336). COMMITTEE COMMENT: The Committee agrees with part l of the Commenter's recommendation. The action on Comment I01-144 (Log #336) should sa t i s f y the Commenter's concern.

(Log #335) IOl - 142 - (8-2.7.4 and 9-2.7.4): Reject SUBMITTER: John G. Degenkolb, Carson Clty, NV COMMENT ON PROPOSAL NO.: I01-286 RECOMMENDATIQN: C l a r i f i c a t i o n requested as to in tent . Is i t intended that the terrace is i n t e r i o r or ex te r io r . What i f the entrance terrace is located under the overhang of a bui ld ing above? SUBSTANTIATION: C l a r i f i c a t i o n of in tent needed. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter has not proposed tex t as required by Section l l - 7 ( d ) of the NFPA Regulations Governing Committee Projects. I t is the Committee's in tent that the terrace is ex te r io r and without an overhang.

(Log #155) I01 - 143 - (8-2.11): Accept SUBMITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-270

I ECOMMENDATION: Delete a l l of current 8 2.11 e>cept ~:~T~ ~ ~ilings. SUBSTANTIATION: The Committee Proposal, on which this comment 15 belng made, places a l l the acceptable means of egress components for th ls occupancy and the i r associated "special Features" together in the 2.2 section of th ls occupancy chapter. Some of the proposed wording For this e~panded 2.2 sectlon comes from the 2.11 Special Features port ion of the current (1985 ed i t ion) chapter. Without the proposed delet ions the requirements would appear twlce and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #336) IOl - 144 - (8-3 .2 .1 .7) : Accept in Pr lnc ip le SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO~: I01-293 RECOMMENDATION: Revise current wording as Follows:

"Other mater ials may be used i f they have successful ly passed a t h i r t y minute Fire test in the U.L. Small Scale Furnace." SUBSTANTIATION: To more c lear ly i d e n t i f y the Furnace intended For the Fire test. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise current wording as Follows: "Other materials may be used i f they have passed a

t h i r t y minute Fire test in a small scale furnace, 3 f t by 3 f t , with the sample mounted in the hor izontal plane at the top of the Furnace and subjected to the standard time temperature curve. COMMITTEE COMMENT: The revised Committee wording addresses the furnace gener ical ly so as to avoid propr ie tary requirements. This should meet the Commenter's in tent .

(Log #540) 101 - 146 - (8 -3 .2 .1 .7) : Accept in Pr inc ip le SUBMITTER: Rolf Jensen, P.E., James Ante l l , A . I .A . , Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-293 RECOMMENDATION: Revise 8-3.2.1.7 to read as Follows:

8 3.2.1.7 Proscenium Curtain. The proscenium opening of every leg i t imate stage shall be provided with a proscenium curta in. Asbestos proscenium curtains shall be constructed and mounted to intercept hot gases, flames and smoke. Other materials may be used i f they have successful ly passed a 30 minute Fire test in the small scale (30 in. × 30 in . ) Furnace with the sample mounted in the hor izontal plane at the top of the Furnace and subjected to the standard Lime temperature curve. Proscenium curtains shall l i m i t v i s i b i l i t y of a f i r e on the stage From the auditorium For a f i ve minute period. SUBSTANTIATION: Second paragraph remains as pr inted. TO reduce some of the bulky wording in the proposed change. Also, we question whether asbestos proscenium curtains are commercially avai lab le. I f not, the second sentence could be ei lminated. COMMITTEE ACTION: Accept in Pr lnc ip le .

See Committee Action on Comment I01-144 (Log #336) on 8-3.2.1 .7. COMMITTEE COMMENT: The Committee believes asbestos proscenium curtains are commercially avai lable and that the proposed wording as ammended by the action on Comment lot 144 on 8 3.2.1.7 (Log ~33G) adresses the concerns of the Commenter.

(Log #122) I01 - 147 - ( 8 - 3 . 2 . I . I I ) : Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: lot 295 RECOMMENDATION: In the second sentence change "Foam plast ics . . . . " to "Foamed plast ics (see A-6-5.1.3)

SUBSTANTIATION: Proposed cross reference w111 lead the user to a d e f i n i t i o n of Foamed p last ics. COMMITTEE ACTION: Accept.

(Log #123) lOl - 148 (8-3.2.2.6 and 9-3.2.2.6) : Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-297 RECOMMENDATION: At end of proposed (a) change "to provide sufficient air when other systems are not in operation" to "to provide sufficient air whether or not other systems are in operation". SUBSTANTIATION: The sufflcient air needs to be provided regardless of operation of other systems, not only when other systems are not in operation. COMMITTEE ACTION: Accept.

(Log #121) 101 - 145 - (8-3 .2 .1 .7) : Accept in Part SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-293 RECOMMENDATION: Either:

(1) Replace the wording that references a 30 minute f i r e test in the small scale Furnace with a reference to a recognized test procedure published by NFPA, ASTM, UL or other acceptable group, or

(2) Delete reference to the unnamed small scale test and discuss the a p p l i c a b i l i t y of other options as an Appendix item. SUBSTANTIATION: A reference to an unnamed, unrecognized test procedure should not appear in the body of the Code.

(Log #124) I01 - 149 (8-3.2.2.7 and 9-3.2.2.7) : Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-297 RECOMMENDATION: In 8-3.2.2.7 and 9-3.2.2.7:

(1) Change the proposed last sentence From "The project ion lamp or pro ject ion room exhaust System may be combined . . ." to "The project ion lamp and project ion room exhaust systems may be combined . . . " , and

(2) Change the spe l l ing , in the next to the last sentence, From "ridged" to " r i g i d " . SUBSTANTIATION: C l a r i f i c a t i o n of in tent . COMMITTEE ACTION: Accept.

294

(Log #126) I01 - 150 - (8-3.4.1 Exception and 9-3.4.1 Exception): Accept in Pr inc ip le SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 181-303 RECOMMENDATION: Revise the proposed rewording of the Exception to read:

Exception: Assembly occupancies which are a part of a mixed occupancy (see I -4 ,7 ) , in which the other occupancy predominates, may be served by the same Fire alarm system as the other occupancy. SUBSTANTIATION: Assembly OCCUpancies are not part of another occupancy. Rather, an assembly occupancy can be part of a mixed occupancy that involves one or more other occupancies. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise 8-3,4.1 Exception and 9-3.4.1 Exception to read:

Exception: Assembly occupancies which are a part of a mixed occupancy (see I -4 .7) may be served by a common f i r e alarm system provided the ind iv idual requirements of each occupancy are met. COMMITTEE COMMENT: The Committee Action should sa t is fy the Commenter's in tent ,

(Log #125) lot - 151 - (8-3.4.1 and 9-3.4.1) : Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-302 RECOMMENDATION: Insert commas so as to rephrase the proposed wording as Follows:

General. Al l Class A and a l l Class B assembly occupancies, and a l l theatres with more than one audience viewing room, shall be provided with an approved f i r e alarm system in accordance with th is section. SUBSTANTIATION: C l a r i f i c a t i o n that, regardless of number of rooms, a l l Class A and Class B assembly o c c u p a n c i e s a re r e q u i r e d to have an a larm System. COMMITTEE ACTION: Accept .

(Log #127) lOl - 152 - (8-3.4.2 Exception No. 2 and 9-3.4.2 Exception No. 2): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-304 RECOMMENDATION: Revise the proposed wording of Exception No. 2 to read:

Exception No. 2: I n i t i a t i o n may be by means of an approved automatic spr ink le r system, ]n accordance with 7-6.2.1(c) , providing f i r e detection and protect ion throughout the bu i ld lng. SUBSTANTIATION: Exception No. 1 cor rec t ly states that a f i r e detection system provides f i r e detection. Exception No. 2, which addresses spr ink ler system use fo r i n i t i a t i n g an alarm system, should stress that the spr ink le r system can be arranged to act as a Fire detection device but i t also provides protect ion as an ext inguishing system, and thus the term " f i r e detect ion" does not t e l l the whole story. COMMITTEE ACTION: Accept.

(Log #75) I01 - 153 - (8-3.4.2 Exception NO. 2 and 9-3.4.2 Exception No. 2): Reject SUBMITTER: H. Brooke Stauf fer , National E lec t r ica l Manufacturers Assn. qOMMENT ON PROPOSAL NO~: I01-304 RECOMMENDATIONN: Revise Committee Action in Exceptlon NO. 2 to read as Follows:

". . . 7-6.2.1(c) , providing protect ion throughout the bu i l d ing . " SUBSTANTIATION: The automatic F~re detection system in Exception l provides detect ion. The automatic spr ink le r System in Exception 2 provides protect ion. The spr ink le r system w i l l not detect a smouldering f i r e as demonstrated in the Ft. Lauderdale Fire demonstrations.

COMMITTEE ACTION: Reject. GOMMITTEE COMMENT: The Committee feels that i n i t i a t i o n by means of an approved automatic sp r ink le r system provides f i r e detection and protect ion. See action on Comment 101-152 on 8-3.4.2 Exception No. 2 and 9-3.4.2 Exception No. 2 (Log #127). Exception No. I of 8-3.4.2 and Exception No. l of 9-3.4.2 permits an automatic Fire detection system i n i t i a t e d by heat.

(Log #29) I01 - 154 - (8-3.4.2 Exception No. 2 and 9-3.4.2 Exception No. 2): Reject SUBMITTER: Joseph A. Drouin, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO.: I01-304 RECOMMENDATION: Revise Committee Action in Exception 2 to read as Follows:

" . . . 7-6.2.1(c) , providing protect ion throughout the bu i ld ing . " SUBSTANTIATION: The automatic f i r e detection system in Exception l provides detection. The automatic spr ink ler system in Exception 2 provides protect ion. The spr ink ler system w i l l not detect a smouldering Fire as demonstrated in the Ft. Lauderdale Fire demonstrations. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Comment on Comment 101-153 on 8-3.4.2 Exception No. 2 and 9-3.4.2 Exception No. 2 (Log #75).

(Log #128) I01 - 155 - (8 3.5.1): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-305 RECOMMENDATION: In the 8-1 .3 de f i n i t i ons section, delete the de f in i t i ons of "Restaurant" and "Nightclub". SUBSTANTIATION: The proposed revisions to 8-3.5.1 w i l l no longer exempt Class B assembly occupancies used e x c l u s i v e l y as r e s t a u r a n t s From the s p r i n k l e r requ i rement . Thus, the d i f f e r e n t i a t i o n between " r e s t a u r a n t s " and " n i g h t c l u b s " i s no l onge r needed because n e i t h e r term w i l l be used s p e c i f i c a l l y in the chap te r . Please note t h a t the Committee Ac t i on on t h i s comment w i l l a f f e c t the a c t i o n on Proposal No. 261 on 8 -1 .3 d e f i n i t i o n . ~OMMITTEE ACTION: Accept.

(Log #541) 101 - 156 - (8 3 .6 ) : Accept in P r i n c i p l e SUBMITTER: Ro l f Oensen, P .E . , James A n t e l l , A . I . A . , RolF Jensen & Assoc ia tes , Inc . COMMENT ON PROPOSAL NO,: 101-309 RECOMMENDATION: Add an Excep t ion No, 2 as Fo l lows :

Except ion No. 2: Lobbies which meet the requ i rements For i n t e r v e n i n g rooms (see 5 - 5 . 1 . 6 ) need not have a F i r e r es i s t ance r a t i n g , SUBSTANTIATION: Many assembly occupancies have main l obb ies se rv ing on ly the assembly area. IF the lobby leads d i r e c t l y to an e x i t , and i s not pa r t o f a c o r r i d o r system, there i s no need to r e q u i r e ra ted doors between the assembly area and the lobby. Door hardware and latches cause s i gn i f i can t acoustical problems fo r theaters and other assembly occupancies. COMMITTEE ACTION: Accept in Pr inc ip le .

Add an Exception No. 3 as fo l lows: Exception No. 3: Lobbies, serving only one assembly

area, which meet the requirements for intervening rooms (see S-5.1.6) need not have a fire resistance rating. COMMITTEE COMMENT: The Committee's revised wording, limiting the lobby wall reduction to lobbies serving only one assembly area, will help to maintain adequate separation between assembly areas. The Committee Action should meet the Commenter's intent.

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(Log #129) I01 - 157 - (8-3.6.1 Exception No. 1): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-309 RECOMMENDATION: In Exception NO. 1, add the words "or lobby" and "independent of corr idors and lobbies" so as to read:

"Corridor and lobby protect ion shal l not be required when assembly rooms se rved by t he c o r r i d o r o r l o b b y have a t l e a s t 50 p e r c e n t o f t h e i r e x i t c a p a c i t y d i s c h a r g i n g d i r e c t l y t o t he o u t s i d e i n d e p e n d e n t o f c o r r i d o r s and l o b b i e s . " SUBSTANTIATION: The assemb ly room can be se rved by e l t h e r , o r bo th , a c o r r i d o r o r l o b b y and t he c o r r i d o r o r l o b b y wou ld no t r e q u i r e p r o t e c t i o n i f h a l f t he eg ress c a p a c i t y f r o m the assemb ly room went d l r e c t l y to the o u t s i d e w i t h o u t u s i n g t he c o r r i d o r o r l o b b y . COMMITTEE ACTION: Accep t .

(Log #1307 I01 - 158 - (8-3.6.2 and 9-3.6.27: Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-311 RECOMMENDATION: Move the proposed wording to Sectlon 31-2. SUBSTANTIATION: The subject of stor ing c loth ing and personal e f fects in corr idors and lobbies is bet ter addressed as an "operating Feature" and thus belongs in Chapter 31 and not in Chapters 8 and 9. COMMITTEE ACTION: Accept.

(Log #542) 101 159 (8 4 .1 .3(d) ) : Reject SUBMITTER: Roll Jensen, P.E., James Ante l l , A . I .A . , Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: lOl 312 RECOMMENDATION: Accept o r ig ina l proposal. SUBSTANTIATION: No study has shown the need For f u l l spr ink lers, Full smoke detectlon and compartmentation in any occupancy at any locat ion. The requirements fo r smoke detection in a compartmented, sprinklered bui ld ing w i l l only add operational and maintenance problems. AIso, th is section requires automatic operation of the bui ld ing voice alarm. This con f l i c t s with the provisions of NFPA 72F which p roh ib i t automatic voice messages. See Committee comment on Item 101-225 which agrees that pre-recorded voice messages should only be used upon analysis of the spec i f ic i n s t a l l a t i o n . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See o r ig ina l Committee Comment on TCR Proposal I01-312 on 8-4.1.3(d7

Log #5437 lOl 160 - ( 8 - 4 . 1 . 6 ) : R e j e c t SUBMITTER: RolF Jensen , P . E . , James A n t e l l , A . I . A . , R o l f Jensen & A s s o c i a t e s , I n c . ~OMMENT ON PROPOSAL NO.: 101 314 RECOMMENDATION: Accep t o r l g i n a l p r o p o s a l . SUBSTANTIATION: NFPA 72F p r o h i b i t s p re r e c o r d e d v o i c e messages. The Commi t tee on S a f e t y t o L i f e has dec i ded t o p e r m i t t he o p t i o n o f p r e - r e c o r d e d v o i c e messages, bu t s t a t e s i n t h e i r Commentary on I t e m 101 225 t h a t s p e c i f i c a n a l y s i s s h o u l d be p e r f o r m e d . Pre r e c o r d e d v o i c e messages can be a o p t i o n - bu t s h o u l d no t be r e q u i r e d . COMMITTEE ACTION: R e j e c t . ~OMMITTEE COMMENT: See o r i g i n a l Comml t tee Comment on TCR P roposa l I 0 1 - 3 1 4 on 8 - 4 . 1 . 6 .

SUBSTANTIATION: The boldface type heading w~ll ca l l a t tent ion to the new requirement and set i t o f f as a separate subject from the items which precede and fo l low i t . COMMITTEE ACTION: Accept.

(Log #131) I01 - 162 - (8 4.2): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-315 RECOMMENDATION: Revise the proposed wording to read:

8-4.2 High Rise Buildings. High r ise assembly occupancy bui ld ings, and high r ise mixed occupancy bui ldlngs which house assembly occupancies in the high r ise portions of the bul ld ing, shall comply wlth Section 30 8. SUBSTANTIATION: The boldface type heading should be added to ca l l a t tent ion to the new requirements For high r ise. Few high r ise bui ldings are exclusively used For assembly purposes. Rather, i t is more COmmOn to Find an assembly occupancy located at the top of a bui ld ing used predominately as some other occupancy, i . e . , restaurant at top of hotel guest room tower. The proposed change stresses that the high r ise provls~ons are needed in such a bui lding ~n order to protect the occupants of the assembly area regardless of how the other occupancles would be required to be protected via the other occupancy chapters of the Code. COMMITTEE ACTION: Accept.

(Log #544) 101 - 163 (8 4.2): Reject SUBMITTER: Rolf Jensen, P.E. James An te l l , A . I .A . , RoIF Oensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-315 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The h igh-r ise provisions were added by t h e main Commi t tee w i t h no r e v i e w by t he Sub -Commi t t ees . T h i s comment i s be ing s u b m i t t e d to a l l o w the Sub-Commi t tee t o r e v i e w the p r o p o s a l and make changes to c o i n c i d e w i t h the s p e c i f i c needs o f t he occupancy g roup . COMMITTEE ACTION: R e j e c t . COMMITTEE COMMENT: See a c t l o n on Comment I01 162 on 8 - 4 . 2 (Log #131 ) .

(Log #113) I01 - 164 - (8 4.2.1 Exception (New)): Accept in Pr inc ip le SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: I01-316 RECOMMENDATION: I f Proposal 101-284 or a var ia t lon on i t (dealing with a broader approach to 8-2.5.5.6) is adopted, add an Exception as Follows:

! Exception: Smoke-protected assembly seating complying with 8-2.5.5.6 need not comply with 3 3.2 or

i NFPA 102, Standard fo r Assembly Seating, Tents and Air-Supported Structures.

IF Proposal I01-284 or a s im i la r approach is not adopted to 8-2.5.5.6, no Exception is needed. In e i ther event the proposed Appendix note (which should have referred to 8-2.5.5.6, not A-8-2.5.5.67 is l i k e l y not needed. SUBSTANTIATION: Proposal 316 was submitted to cover the eventual i ty of changes to 8-2.5.5.6 and to give the correct t i t l e of NFPA 102. COMMITTEE ACTION: Accept in Pr inc ip le .

I Add the Exception as proposed by the Commenter. COMMITTEE COMMENT: The Committee Action should sa t i s f y the Commenter's in tent .

(Log #178) IOl - 161 - (8-4.2) : Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories qOMMENT ON PROPOSAL NO.: I01-315 RECOMMENDATION: Insert , before the actual sentence with the requirement, a boldface type heading "High Rise Bui ld ings".

(Log #545) 101 165 - (8-4.3.2) : Accept in Part in Pr inc lp le SUBMITTER: Roll Jensen, P.E., James An te l l , A . I .A . , Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-317 RECOMMENDATION: Delete 8 4.3.2(d) .

Replace 8-4.3.2(e) with appendix note For (e) change "should" to "sha l l " in appendix note.

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~UBSTANTIATION: 8-4.3.2(d) prohibits cotton, paper, and "similar decorative materials" unless they are Flame retardant. Every exhibit w i l l contain some materials that are not Flame retardant. This section is unenforceable and unreasonable.

8-4.3.2(e) requires sprinklers in large exhibit booths. This may not be possible in some exhibit halls. Requiring battery powered smoke detection would provide the necessary early warning without adding unreasonable requirements. COMMITTEE ACTION: Accept in Part in Principle.

Amend only (d) to read: (d) Accoustical and decoratlve material including,

but not limited to, cotton, hay, paper, straw, moss, sp l i t bamboo and wood chips shall be flame retardant treated to the sat is f icat ion of the authority having jur isd ic t ion. Materials that cannot be treated for flame retardency shall not be used. COMMITTEE COMMENT: The rewording of (d) helps to c l a r i f y that the flame retardency requirements apply to acoustical and decorative materials, not to product on display.

With respect to (e), no changes were made because mult i- level display booths and large single level booths with celings create shielded areas outside the protection of building cei l ing sprinklers. The TCR proposed wording is needed for adequate protection.

(Log #133) I01 - 166 - (8-4.3.3 and 9-4.3,3): Accept S_UBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: lOI-317 RECOMMENDATION: Revise the third and Fourth sentences of Subpart (b) of proposed 8-4.3.3 and 9-4.3.3 to read:

"Plastic shall be limited to Class A or Class B in ter ior wall and ceil ing Finish. Foamed plastics (see A-6-5.1.3) are prohibited." SUBSTANTIATION: The proposed TCR wording would have limited the use of plastics to Class B rating only and some users would have incorrectly believed that the better Class A could not be used. The correct terminology is " in ter io r wall and cei l ing Finish". The term should be "foamed p l a s t i c s " r a t h e r than "foam p l a s t i c s " and a re fe rence to A G - 5 . I . 3 de f i nes the term f o r the user . qOMMITTEE ACTION: Accept.

(Log #135) 101 168 - (8 4.3.3(e) and 9-4.3.3(e)): Accept ~_~BMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-317 RECOMMENDATION: In proposed 8-4.3.3(e) and 9-4.3.3(e) add a semicolon so as to read as Follows:

(e) Exhibit booths that are mult i level; consist of multiple rooms with ceil ings; or are over 225 sq ft. with ceil ings, shall be protected . . . . SUBSTANTIATION: Clar i f icat ion that multiple rooms with ceilings or single room more than 225 sq f t with cei l ing each are suf f ic ient conditions to warrant sprinkler protection. COMMITTEE ACTION: Accept.

(Log #76) I01 - 169 - (8-4.3.3(e) and 9-4.3.3(e)): Accept in Part SUBHITTER: H. Brooke Stauffer, National Electrical Manufac tu re rs Assn. COMMENT ON PROPOSAL NO.: 101-317 RECOMMENDATION: Revise the l a s t sentence o f 8 - 4 . 3 . 3 ( e ) and 9 - 4 . 3 . 3 ( e ) to read as Fo l lows:

" . , , c e l l i n g s , s h a l l be p ro tec ted by an au tomat i c smoke d e t e c t i o n system. They s h a l l a l so be p r o t e c t e d by au tomat ic s p r i n k l e r s in b u i l d i n g s so p r o t e c t e d . " SUBSTANTIATION: Appendix i tems A - 8 - 4 . 3 . 3 ( e ) and A - 9 - 4 . 3 . 3 ( e ) p rov ide d e t a i l e d i n f o r m a t i o n f o r a smoke d e t e c t o r . COMMITTEE ACTION: Accept in Part.

Revise the Exception to 8--4.3.3(e) and Exception to 9-4.3.3(e) to read as Follows:

Exception to (e): Vehicles, boats, and similar exhibited products having over I00 sq f t of roofed area shall be provided with smoke detectors acceptable to the authority having jur isdict ion.

Delete the proposed appendix notes to 8-4.3.3(e) and 9-4.3.3(e). COMMITTEE COMMENT: The Subcommittee is of the opinion that the roofed areas of booths do not require both automatic sprinkler protection and early warning devices. Smoke detection should be provided for RV's and boats having roofed areas e×ceedlng 100 sq Ft.

The Commenter has not provided substantiation to snow why smoke detection is required in areas protected by automatic sprinklers.

(Log #132) I01 - 167 - ( 8 - 4 . 3 . 3 ( b ) and 9 - 4 . 3 . 3 ( b ) ) : Accept in P r i n c i p l e SUBMITTER: John G. Degenkolb, Carson C i t y , NV COMMENT ON PROPOSAL NO.: 101-317 RECOMMENDATION: Revise the second sentence o f subpar t (b) o f proposed 8 - 4 . 3 . 3 and 9 - 4 . 3 . 3 to read:

" T e x t i l e wa l l cove r i ngs , such as c a r p e t i n g having a napped, t u f t e d , looped, or s i m i l a r s u r f a c e , s h a l l not be used as wa l l or c e i l l n g F i n i s h . " SUBSTANTIATION: The word ing proposed by the Subcommittee would prohibit carpeting From being used as wall or ceil ing f inish in exhibit booths. Carpeting is generally applied to Floors and " tex t i l e wall coverings" (which may look l ike carpeting, but do not have the same degree of wear resistance) are applied to walls and ceilings. The t ex t i l e wall coverings, because of their napped/tufted/looped surfaces introduce the same flame spread problems commonly associated with carpeting placed on walls and ceil ings. The entire subject is best addressed by prohibiting the use of t ex t i l e wall coverings in exhibit booths. COMMITTEE ACTION: Accept in Principle.

Revise the second sentence of subpart (b) of proposed 8-4.3.3 and 9-4.3.3 to read:

"Texti le wall coverings, such as carpeting having a napped, tufted, looped, or similar surface used as wall or ceil ing f in ish shall comply with G-5.7.2(a)." COMMITTEE COMMENT: The Committee Action should sat isfy the Commenter's intent.

(Log #30) 101 170 (8 - -4 .3 .3 (e ) and 9 - 4 . 3 . 3 ( e ) ) : Accept in Par t ~_UBMITTER: Joseph A. Drou in , Simplex Time Recorder Co. COMHENT ON PROPOSAL NO.: 101-317 RECOMHENDATION: Revise the l a s t sentence o f 8 - 4 . 3 , 3 ( e ) and 9 - 4 . 3 . 3 ( e ) to read as f o l l o w s :

" . . , c e i l i n g s , s h a l l be p ro tec ted by an au tomat i c smoke d e t e c t i o n system, and by au tomat ic s p r i n k l e r s in b u i l d i n g s so p r o t e c t e d . " ~UBSTANTIATION~ Appendix i tems A - 8 - 4 . 3 . 3 ( e ) and A 9 - 4 . 3 . 3 ( e ) p rov ide d e t a i l e d ~n fo rmat ion For a smoke d e t e c t o r system, t h e r e f o r e , the smoke d e t e c t o r system should be re fe renced in the main body. COMMITTEE ACTION: Accept in Par t . COMMITTEE COMMENT: See Committee Ac t i on and Committee Comment on Comment 101-169 on 8 4 . 3 . 3 ( e ) and 9 - 4 . 3 . 3 ( e ) (Log #76).

(Log #136) 101 - 171 - ( 8 - 4 . 3 . 3 ( g ) 5 and 7 and 9 - 4 . 3 . 3 ( g ) 5 and 7) : Accept in P r i n c i p l e SUBMITTER: John G. Oegenkolb, Carson C i t y , NV COHMENT ON PROPOSAL NO.: 101-317 RECOHMENDATION: Revise proposed 8 - 4 . 3 . 3 ( g ) 5 and (g )7 and 9 - 4 . 3 . 3 ( g ) 5 and (g)7 as f o l l o w s :

5. Devices used For cooking s h a l l be separated f rom each o the r by a minimum d i s tance o f 2 f t .

7. F ryers , po ts , pans, and s i m i l a r dev ices s h a l l be p rov ided w i t h l i d s . SUBSTANTIATION: C l a r i f i c a t i o n o f i n t e n t . COHHITTEE ACTION: Accept in P r i n c i p l e .

Accept r e v i s i o n proposed to 8 - 4 . 3 . 3 ( g ) 5 and 9 - 4 . 3 . 3 ( g ) 5 .

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Revise proposed 8-4.3.3(g)7 and 9-4.3.3(g)7 to read as follows:

7. Single well cooking equipment using combustible o i ls or solids shall have l ids available for immediate use. Multi-vat cooking equipment using combustible o i ls or solids shall comply with NFPA 96. COMMITTEE COMMENT: The Committee Action should sat isfy t he Commenter ' s i n t e n t .

(Log #134) 101 - 172 - (8-4.3.5 and 9-4.3.5): Accept in Part SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-317 RECOMMENDATION: Revise proposed 8-4.3.5 and 9-4.3.5 to read:

". . . Class I I or greater lasers, blasting agents, and explosives, excluding sparklers, shall be prohibited within exhibit hal ls ." SUBSTANTIATION: This comment is submitted to allow the Subcommittee to readdress i t prohibit ion on the use of any explosives. The term "explosives" is Far reaching and even includes "sparklers". Regardless of the Subcommittee's decision, the term "and in" needs to be corrected to "and". COMMITTEE ACTION: Accept in Part.

Revise proposed 8-4.3.5 and 9 4.3.5 to read: ". . . Class I I or greater lasers, blasting agents,

and explosives shall be prohibited within exhibit ha l ls . " COMMITTEE COMMENT: The editor ial corrections accepted. All explosives, even sparklers, should be prohibited From eKhibit halls.

(Log #72) I01 173 - (8 4.5): Resect $UBMITTER: Richard Fussner, Kings Island Amusement Park COMMENT ON PROPOSAL NO.: I01-318 RECOMMENDATION: Revise recommendation to include information regarding protection of special structures. SUBSTANTIATION: Special buildings, such as air-supported structures and soft-sided metal frame structures are used throughout the industry as amusement buildings. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter has not proposed text as required by Section 11-7(d) of the NFPA Regulations Governing Committee Projects.

(Log #251) 101 - 174 (8 4.S.2): Accept in Princlple SUBMITTER: John Behrens, Hungtington Beach, CA COMMENT ON PROPOSAL NO.: I01 318 RECOMMENDATION: Revise the proposed 8-4.5.2 to read:

8-4.5.2 Every amusement building shall be protected throughout by an approved automatic sprinkler system instal led and maintained in accordance with Section 7-7. Where the amusement building is movable or portable, sprinkler water supply may be by an approved t e m p o r a r y means. ~UBSTANTIATION: AS i n d i c a t e d by a r e c e n t F i r e J o u r n a l a r t i c l e , t he use o f " q u i c k response s p r i n k l e r s " s h o u l d be used w i t h ex t reme c a u t i o n and d e t e r m i n e d on a case by case b a s i s . NFPA 13 a l l o w s the use o f q u i c k response s p r i n k l e r s bu t does no t mandate them and u n t i l more i s known about the response c h a r a c t e r i s t i c s o f q u i c k response s p r i n k l e r s the Code s h o u l d no t mandate t h e i r use. COMMITTEE ACTION: Accept i n P r i n c i p l e .

Accep t the r e v i s i o n proposed f o r 8 - 4 . 5 . 2 and add an appendix note as follows:

A-8-4.5.2 I t is the intent of the Committee to provide a suppression system that w i l l act quickly to provide for l i f e safety of the occupants. COMMITTEE COMMENT: The Committee recognizes that some amusement buildings are large buildings that require standard automatic sprinkler system protection. However, the Committee also recognizes that there are other types of special amusement buildings which might be able to take advantage of Quick response sprinkler technology.

(Log #7) 101 - 175 - (8-4.5.2): Accept in Principle SUBMITTER: Chester W. Schirmer, Schirmer Engineering Corp. COMMENT ON PROPOSAL NO.: I01-318 RECOMMENDATION: Delete "using quick response sprinklers" from 8-4.5.2. SUBSTANTIATION: Present l i s t ing laboratories tests of quick response sprinklers do not investigate the poss ib i l i ty of multiple sprinkler opening under various types of f i r e conditions in rooms or spaces containing multiple sprinklers. Testing also has not investigated use of quick response sprinklers on dry pipe sprinkler systems. The mandating of quick response sprinklers may therefore be detrimental rather than advantageous unti l specific insta l la t ion c r i t e r i a have been developed by NFPA 13, taking into consideration tests such as those outllned above. COMMITTEE ACTION: Accept in Principle.

See action on Comment I01-174 on 8 4.5.2 (Log #251). COMMITTEE COMMENT: The Committee Action should sat is fy the Commenter's intent.

(Log #321) 101 - 176 - (8-4.5.2 Exception (New)): Reject SUBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO.: I01-318 RECOMMENDATION: Add new Exception to 8-4.5.2 as follows:

Exception: IF approved quick-response sprinklers are not available, then standard heads may be used. SUBSTANTIATIO_N: a. Our investigations thus far suggest that quick response sprinklers are only approved for residential occupancies, not for assemblies.

b. Many amusement bulldings w i l l surely use dry sprinkler systems. Our research shows that only pendant and sidewall heads are available, not uprlght.

Because of a. and b. above, i t w i l l be d i f f i c u l t to comply with the Code as proposed. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action on Comment I01-174 on 8-4.5.2 (Log #251).

(Log #412) 101 - 177 - ( 8 - 4 . 5 . 3 ) : Accep t i n P r i n c i p l e SUBMITTER: John G. Oegenko lb , Carson C i t y , NV COMMENT ON PROPOSAL NQ~: 101-318 RECOMHENDATION: Change p roposed w o r d i n g o f 8 - 4 . 5 . 3 t o read :

" . . . i n acco rdance w i t h S e c t i o n 7 -6 . A c t u a t i o n o f any smoke d e t e c t i o n sys tem d e v i c e s h a l l sound an a l a r m a t a c o n s t a n t l y a t t e n d e d l o c a t i o n on the p r e m i s e s . A c t u a t i o n o f t he a u t o m a t i c s p r i n k l e r sys tem o r a c t u a t i o n o f a second smoke d e t e c t i o n d e v i c e s h a l l cause t he i l l u m i n a t i o n i n the means o f eg ress t o i n c r e a s e t o t h a t r e q u i r e d by S e c t i o n 5 - 8 . " SUBSTANTIATION: A c t u a t i o n o f a second d e t e c t o r s h o u l d r e s u l t i n n o t i f y i n g c o n s t a n t l y a t t e n d e d l o c a t i o n i n order to reduce the number of nuisance alarms that would result from such reporting upon activation of the f i r s t detector. Additionally, the required sprinkler system should be used to increase the il lumination level. COMMITTEE ACTION: Accept in Principle.

Change proposed wording of 8-4.5.3 to read: ". . . in accordance with Section 7-6. Actuation of

any smoke detection system device shall sound an alarm at a constantly attended location on premises. Actuation of the automatic sprinkler system or actuation of a smoke detection system having an approved ver i f i ca t ion or cross zoning operation capabil i ty shall cause the il lumination in the means of egress to increase to that required by Section 5-8." COMMITTEE COMMENT: The Committee Action should sat is fy the Commenter's intent.

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(Log #326) 101 - 178 - (8 -4 .5 .3) : Reject SUBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO.: I01-318 RECOMMENDATION: Is i t the intent of the Subcommittee that there must be a "constantly attended locat ion" fo r any amusement bu i ld ing, regardless of the size of the bui lding? Is the requirement met by having the alarm sound near where the usher or r ide operator is stationed? Does the "constantly attended locat ion" mean the s ta t ion defined in NFPA 71 and 72A through D? SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter has not proposed tex t as required by Section 11-7(d) of the NFPA Regulations Governing Committee Projects.

(Log #137) 101 - 179 - (8 -4 .5 .3(a) , (b) and (c) (New)): Accept $UBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-318 RECOMMENDATION: Add wording to the end of the second sentence of proposed 8-4.5.3 so as to read:

"Actuation of the smoke detection system shal l : (a) Sound an alarm at a constantly attended locat ion

on the premises, and (b) Cause i l l um ina t ion in the means of egress to

increase to that required by Section 5-8, and (c) Stop any con f l i c t i ng or confusing sounds and

v isua ls . " SUBSTANTIATION: Conf l i c t ing or confusing sounds and v isuals, such as music, sound ef fects and strobing l i gh t s , i f not "turned o f f " w i l l contlnue to serve as miscues and ob l i t e ra te the useful evacuation signals and cues. COMMITTEE ACTION: Accept.

(Log #252) lOl - 182 - (8 -4 .5 .4 .4) : Accept in Pr inc ip le SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: I01-318 RECOMMENDATION: Revise 8-4.5.4.4 to read:

8-4.5.4.4 In amusement bui ld ings where mazes, mirrors or other designs are used to confound the egress path, approved d i rec t iona l e x i t marking which w i l l become apparent in an emergency shall be provided along the f l oo r . SUBSTANTIATION: Paragraph 8-4.5.4.1 already requires e x i t marking. The in tent of 8-4.5.4.4 is to make th i s marking be along the Floor in such designs. COMMITTEE ACTION: Accept in Pr inc ip le .

Add an appendix note the TCR tex t Proposal I01-318 on 8-4.5.4.4 to read:

A-8-4.5.4.4 Consideration should be given to the provision of d i rec t iona l e x i t marking on or adjacent to the Floor. COMMITTEE COMMENT: The Committee Feels the addi t ion of an appendix note adequately addresses the concern of the Commenter.

(Log #324) I01 - 183 - (8-4 .5 .4 .4) : Reject SUBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO~: I01-318 RECOMMENDATION: Replace the words "are used to confound" with the words "which may confound". SUBSTANTIATION: Amusement bui ld ings are usual ly designed for amusement or entertainment, rather than to confound the means of egress. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See action on Comment I01-I16 on 8-1.3 (Log #247) which establishes a revised definition for "Special Amusement Building".

(Log #322) I01 - 180 - (8-4.5.3 Exception (New)): Reject $UBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO.: I01-318 RECOMMENDATION: Add new Exception as Follows:

Exception: I f the bui ld ing is unheated or is an open st ructure, in accordance with 30-I .3.7, then approved heat or r a t e - o f - r i s e detectors may be used instead of smoke detectors. SUBSTANTIATION: I f an amusement bui ld ing is unheated or has open sides or is otherwise open to outdoor temperatures, a smoke detector may be i ne f fec t i ve and/or cause f a l s e a larms. COMMITTEE ACTION: Re jec t . COMMITTEE COMMENT: The Committee is o f the op i n i on t h a t the use o f smoke de tec to r s are p r e f e r a b l e and the unusual c i rcumstances s ta ted by the Commenter do not wa r ran t a new Excep t ion For heat ac tua ted d e t e c t o r s in 8 - 4 . 5 , 3 .

The Committee Feels the equ i va lency concepts l oca ted in Sec t ion I - 5 o f the Code p rov ide s u f f i c i e n t guidance in the case o f unusual c i rcumstances .

(Log #323) I01 - 181 - (8-4.5.4.1 and 8-4.5.4.2) : Reject $UBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO.: 101-318 RECOMMENDATION: Delete paragraphs 8-4.5.4.1 and 8-4.5.4.2 en t i r e l y , then renumber the remaining paragraphs. SUBSTANTIATION: These requirements are already stated in 8-2.10 and 5-10.3.3 COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Section 8-4.5 is new in the Code and is a complete package addressing special provisions For amusement bui ld ings. Because i t is a package, a l l per t inent information is located w i th in the occupancy chapter and is hence "user Fr iendly".

(Log #325) 101 - 184 - (8-4 .5 .5) : Accept SUBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO.: I01-318

l RECOMMENDATION: Where i t says ". . . or in amusement structures", change to ". . . or in amusement buildings". SUBSTANTIATION: The definition in 8-1.3 is For amusement buildinqs, not structures. COMMITTEE ACTION: Accept.

(Log #156) 101 - 185 - (9-2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-319 RECOMMENDATION: Delete a l l of current 9-2.11 except 9-2.11.3 on r a i l i n g s . SUBSTANTIATION: The Committee proposal, on which th is comment is being made, places a l l the acceptable means of egress components fo r th is occupancy and t he i r associated "special features" together in the 2.2 section of th is occupancy chapter. Some of the proposed wording For th is expanded 2.2 section comes from the 2.11 Special Features port ion of the current (1985 edi t ion) chapter. Without the proposed delet ions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #138) 101 - 186 - (9 -3 .2 .1 .2) : Accept in Pr inc ip le SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-322 RECOMMENDATION: Either:

(1) Replace the wording that references a 30-minute f i r e test in the small scale Furnace with a reference to a recognized text procedure published by NFPA, ASTM, UL or other acceptable group, or

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(2) Delete reference to the unnamed small scale test and discuss the app l i cab i l i t y of other options as an Appendix item. SUBSTANTIATION: A reference to an unnamed, unrecognized test procedure should not appear in the body of the Code. COMMITTEE ACTION: Accept in Principle.

Revise last sentence of proposed text in TCR Proposal 101-322 on 9-3.2.1.2 such that i t reads as Follows:

"Other materials may be used i f they have passed a t h i r t y minute f i r e test in a small scale Furnace, 3 f t by 3 f t , with the sample mounted in the horizontal plane at the top of the Furnace and subjected to the standard time temperature curve. COMMITTEE COMMENT: The revision to 9-3.2.1.2 reaffirms the desire of the Committee to require a 30 minute Fire test For new construction. Asbestos is continued to be acceptable for exist ing occupancies. Also, see Committee Action on Comment I01-144 on 8-3.2.1.7 (Log #336).

(Log #546) 101 - 187 - (9-3.2.1.2): Accept in Principle SVBMITTER: Roll Jensen, P.E., James Antel l , A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO~: I01-322 RECOMMENDATION: Revise 9-3.2.1.2 to read as Follows:

9-3.2.1.2 Proscenium Curtain. The proscenium opening of every legit imate stage shall be provided with a proscenium curtain. Asbestos proscenium curtains shall be constructed and mounted to intercept hot gases, flames and smoke. Other materials may be used i f they have successfully passed a 30 minute Fire test in the small scale (30 in. < 30 in. ) Furnace with the sample mounted in the horlzontal plane at the top of the Furnace and subjected to the standard time temperature curve. Proscenium curtains shall l im i t v i s i b i l i t y of a Fire on the stage From the auditorium for a Five minute period. SUBSTANTIATION: Second paragraph remains as printed. To reduce some of the bulky wording in the proposed change. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment I01-186 on 9-3.2.1.2 (Log #138). COMMITTEE COMMENT: The Committee believes the actlon taken previously addresses the concerns of the Commenter.

(Log #139) I01 - 188 - (9-3.2.1.7): Accept SVBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-323 RECOMMENDATION: Revise the proposed second sentence to read:

"Foamed plastics (see A-6-5.I.3) may be used only by specific approval of the authority having jurisdiction." SUBSTANTIATION: Proper term is "Foamed plastic" and the cross reference will lead the user to a definition. ~OMMITTEE ACTION: Accept.

(Log #157) 101 - 189 - (I0-2.11): Accept ,S_UBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-331

I RECOMMENDATION: Delete a l l of current lO-2.11 except 10-2.11.5 on windows. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places al l the acceptable means of egress components for this occupancy and the i r associated "special features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording for this expanded 2.2 section comes from the 2.11 Special Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. ~OMMITTEE ACTION: Accept.

(Log #20) 101 - 190 - (10-3.6.1 Exception No. 2): Reject SUBMITTER: Paul S. Quigg, USG Corp. COMMENT ON PROPOSAL NO.: I01-343 RECOMMENDATION: Disallow entire recommendation cal l ing for deletion of present Exception No. 2 of 10-3.6.1 and substitution of a new Exception No. 2 which states:

Exception No. 2: In buildings protected throughout by an approved supervised automatic sprinkler system instal led in accordance with Section 7-7 corridor walls may be nonrated provided such walls in conjunction with doors instal led therein and ceil ings at which they terminate resist the passage of smoke. SUBSTANTIATION: I. The l iFesafety Fire record of sprinklered Fac i l i t ies is excellent. Door closers and the need to extend corridor walls to the f loor or roof above are both an operational problem (closers) and an extreme cost (wall extensions) which is unjustified in fully sprinklered schools when the sprinklers are supervised, offered by the submitter of I01-343, is without technical merit. Perhaps "the lifesafety fire record of Fire rated walls is excellent"; however, the life safety Fire record of fire rated walls to contain the Fire to the area of origin is also e×cellent. It has not been demonstrated that the life safety characteristics of sprinklers obviate the necesslty for having the life safety characteristics which are provided by Fire rated corridor walls.

2. Recommendation I01-343 requires walls, doors, ceilings, and the intersection of these elements, to "resist the passage of smoke"; however, no test standard or criteria is offered to permit evaluation of this characteristic. The recommendatlon, if approved, could not be uniformly applied because the standard for evaluation does not exist . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The l i f e safety Fire record of sprinklered Facil~tles is e>cellent. Door closers and the need to extend corridor walls to the Floor or roof above are an operational problem (closers) which is unjust i f ied in Fully sprlnklered schools when the sprinklers are supervised. The combination of automatic sprlnklers and smoke resisting part i t ions make i t an acceptable al ternat ive.

(Log #84) 101 - 191 - ( 1 0 - 3 . 6 . 1 E x c e p t i o n NO. 2 ) : R e j e c t SUBMITTER: Rober t A. Wessel , Gypsum Assn. COMMENT ON PROPOSAL NO.: 101-343 RECOMMENDATION: D e l e t e proposed new E x c e p t i o n 2 and r e t a i n c u r r e n t w o r d i n g . SUBSTANTIATION: A l t h o u g h i t i s r e c o g n i z e d t h a t s p r i n k l e r s have a good r e c o r d , t h i s does no t j u s t i f y a reduction in other f i r e protection systems. I t is the goal of a l l parties concerned with l i f e safety to improve the current si tuat ion. I f i t is determined that sprinklers are a method of achieving that goal, then so be i t . The practice of removing other l i f e safety systems in order to finance the sprinkler system is counterproductive. The proposed new Exception cal ls for the assemblies to "resist the passage of smoke". This is ambiguous at best. What c r i t e r i a is to be used to demonstrate compliance with this provision? The lack of any specific measurement method w i l l result in confusion and an i nab i l i t y to enforce such an ambiguous requirement. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action and Comment on Comment lot-190 on I0-3.6.1 Exception No. 2 (Log #20).

(Log #253) 101 - 192 - ( 1 0 - 3 . 6 . 2 and 1 1 - 3 . 6 . 2 ) : Accept SUBMITTER: John Behrens , H u n t i n g t o n Beach, CA COMMENT ON PROPOSAL NO.: 101-345

I RECOMMENDATION: In addition to the two new paragraphs recommended by the proposal, add an identical paragraph to 31-3. SUBSTANTIATION: Although this paragraph does relate to the design of a building, i t also relates to the daily operations and should appear in Chapter 31 as well as in Chapters I0 and 11. COMMITTEE ACTION: Accept.

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(Log #548) lOl - 193 - ( lO-4 . l .3 (d ) ) : Reject $UBMITTER: Rolf Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-348 RECOMMENDATION: Accept or ig inal proposal. SUBSTANTIATION: No study has shown the need for Full sprinklers, f u l l smoke detection and compartmentat~on in any occupancy at any location. The requirements for smoke detection in a compartmented, sprinklered building w i l l only add operational and maintenance problems. Also, this section requires automatic operation of the building voice alarm. This conf l ic ts with the provisions of NFPA 72F which prohibits automatic voice messages. See Committee comment on I01-225 which agrees that pre-recorded voice messages should only be used upon analysis of the specif ic insta l la t ion. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that the smoke detectors required by this section provlde faster response for smoke detection which is needed for this part icular use which is located more than 35 Ft below the level of ex i t discharge.

(Log #179) lOl - 194 - (I0-4.2): Accept $UBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: lOl 349 RECOMMENDATION: Insert, before the actual sentence with the requirement, a boldface type heading "High Rise Buildings." SUBSTANTIATION: The boldface type heading w i l l cal l attention to the new requirement and set i t o f f as a separate subject from the ~tems which precede and follow i t . COMMITTEE ACTION: Accept.

(Log #549) I01 - 195 - (10-4.2): Reject $UBHITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-349 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The high-rise provisions were added by the Main Committee with no review by the Sub-Committees. This comment is being submitted to allow the Sub-Committee to review the proposal and make changes to coincide with the specif ic needs of the occupancy group. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee believes in the event a high rise educational occupancy is constructed, i t should meet the requirements of 30-8 for high rise buildings.

(Log #254) lOl - 196 - (I0-7.2.11.4 and I I -7.2.11.4): Accept $UBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: 101-359 RECOMMENDATION: Revise First sentence of I0-7.2.11.4 and II-7.2.11.4 to read:

"Every room or space normally subject to c l ient occupancy, other than bathrooms, shall have at least one outside window for emergency rescue or vent i la t ion. " SUBSTANTIATION: When this paragraph was repeated from the educational sections of Chapters lO and I I , i t was not modified to make i t consistent with the provisions of 10-7 and 11-7. COMMITTEE ACTION: Accept.

(Log #348) I01 - 197 - (10-8.5.1.2, 11-8.5.1.2 and I I -9 .5 .1 .2) : Reject SUBMITTER: Samuel S. Levinrad, Veterans Administration COMMENT ON PROPOSAL NO.: I01-370, 395, 397 RECOMMENDATION: I t is my recommendation that these three proposals change from "Reject" to "Accept".

SUBSTANTIATION: In the type of atmosphere that these paragraphs refer to, i t is quite common For the personnel, be they're housekeeping or administrative to remove the "typical insertion type protection devices" and never replace them. Adding this requirement to the standard w i l l not be overly expensive. By in ferr ing that the insertion type device w i l l be " insta l led by someone", I believe is just a wish on the Committee's part. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that this would be overly res t r ic t i ve and that the typical insertion type protection devices are satisfactory for the intent of this paragraph. No additional data has been provided to the Committee for reconsideration of the Commenter's recommendation.

(Log #158) I01 - 198 - ( I I 2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-380 RECOMMENDATION ~ Delete al l of current 11-2.11 except II 2.11.5 on wlndows. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places a l l the acceptable means of egress components for this occupancy and their associated "special features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording For this expanded 2.2 section comes From the 2.11 Special Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #21) 101 - 199 - ( I I -3 .6 .1) : Reject SUBHITTER: Paul S. Quigg, USG Corp. COMMENT ON PROPOSAL NO.: I01-389 RECOMMENDATION: Disallow entire recommendation which states:

"Revise II-3.6.1 by changing "shall be of construction having not less than one hour f l r e resistance rating" to read: "shall be of smoke resistant construction having not less than a twenty minute Fire resistance rat ing" and continue with the remainder of the paragraph and exceptions as printed." SUBSTANTIATION: The recommendation suggests that l i f e safety w i l l not be adversely affected i f corrldor walls currently required to have a 1 hr Fire rating were relaxed to require only a 20-min Fire rating, provided the wall "be of smoke resistant construction". We request the revision be denied because:

I. A wall of smoke resistant construction is not defined by standard or criteria; therefore, the requirement has no meaning.

2. Even though a criteria for smoke-resistant construction does not exist, it could be expected that a 20-min rated wall would have less "smoke resistance" than a l-hr rated wall. This being the case, life safety would be compromised by virtue of less smoke resistance as well as less Fire resistance. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action and Comment on Comment lOl-190 on I0-3.6.1 Exception No. 2 (Log #20).

(Log #85) I01 - 200 - ( I I -3 .6 .1 ) : Reject SUBHITTER: Robert A. Wessel, Gypsum Assn. COMMENT ON PROPOSAL NO.: 101-389 RECOMMENDATION: Delete proposed new language and retain exist ing wording. SUBSTANTIATION: This proposal assumes that the smoke resistance of a 20 minute wall w i l l be the same as that of a l hour wall. The statement in the substantiation that the rating of an exist ing wall cannot be determined does not j u s t i f y the proposed new wording. The fact that we may be dealing with an unknown in exist ing buildings in no reason to reduce the requirements. This practice w i l l only fuel confusion

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and jeopardize the safety of the building occupants. The requirement For smoke resistance is essentially unenforceable in the absence of c r i t e r i a upon which to base the alleged smoke resistance properties of a given wall. IF the f i r e resistance rating of a wall is unknown i t stands to reason that the smoke resistance w i l l also be unknown. This proposal accomplishes nothing and should be rejected. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action and Comment on Comment I01-190 on I0-3.6.I Exception NO. 2 (Log #20).

(Log #303) 101 - 201 - (12-1.1.4.2): Accept in Principle SUBMTTTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: I01-407 RECOMMENDATION: Add a new 12-I . I .4.2, renumbering the subsequent paragraphs:

12-1.I.4.2 In modernization projects and renovations to exist ing Fac i l i t ies , only that portion of the total f a c i l i t y affected by the project shall comply with the provisions of Chapter 12 in accordance with Section 1-4 .6 . SUBSTANTIATION: Health care occupancies are unique to other occupancies in that we are constantly modernizing exist ing structures. As technology or the public need for health care changes, hospitals have to renovate in order to maintain current with the state of the art thereby providing the highest level of quali ty care. A major obstacle to our constant modernization is the local or state authority havlng ju r i sd ic t ion mandating we bring the entire complex up to current "new" standards. I t ~s important to understand that those areas of a building that are not undergoing renovation are s t i l l in Full compliance with acceptable editions of the Code. Because of the possible Financial implications of this impractical request hospitals may need to reconsider thei r renovation programs, thwarting the i r obligations to meet the medical needs of thei r communities.

The wording change w111 allow health care Fac i l i t ies to elevate thei r buildings to the "new" Code requirements in accordance with a long range/master plan. qOMMITTEE ACTION: Accept in Principle.

Do as the Commenter proposes, but in the third l ine change "project shall comply" to "project need comply". COMMITTEE COMMENT: The Committee agrees with the Commenter but made the minor r e v i s i o n to reduce any i m p l i c a t i o n t h a t the Code in tends to l i m i t compl iance. The change should meet the Commenter's i n t e n t .

(Log #G3) 101 - 202 - (12-1.1.4.6): Accept in Principle SUBMITTER: Thomas D. Mattern, UCLA Neuropsychiatric Hospital COMMENT ON PROPOSAL NO.: I01-407 RECOMMENDATION: I t is my understanding that this proposal has been referred to the Subcommittee on Administratlon of the Li fe Safety Code, and in so doing, the Committee rejected this proposal with the comment that "the current method of defining new construction is adequate".

The Subcommittee's action on this proposal must be questioned ~n their rejection for the Following reasons:

While there are two sections coverlng "Health Care Occupancies"

I. Chapter 12 "New" 2. Chapter 13 "Existing" There is not in either of these chapters any clear

def in i t ion as to when an "existing Health Care occupancy", in the process of modernization, passes a point that requirements for compliance with a l l aspects of the current Life Safety Code should be met.

Although reference under 12-I . I .4, is made to l-4.s and I-4.6, i t is apparent that by referr ing this proposal to the Administrative Subcommittee, that these two sections are not as clearly defined as the Subcommittee on Health Care occupancies would l ike to see. I must conclude that although the Subcommittee "believes the current method of defining new construction is adequate" they by the i r actions believe that a more comprehensive def in i t ion is required.

As the o r i g i n a l Submi t t e r o f t h i s p roposa l , I f e e l t h a t r e c o n s i d e r a t i o n by the Subcommittee on Hea l th Care occupancies is r e q u i r e d and i f any a c t i o n is taken i t should be in the form o f "Accept in P r i n c i p l e " w i t h m o d i f i c a t i o n s to the o r i g i n a l proposal as the Subcommittee f e e l s a p p r o p r i a t e . SUBSTANTIATION: The Hea l th Care I n d u s t r y today is undergo ing major changes due to modern t e c h n o l o g i e s and the need For compe t i t i veness w i t h i n the marke tp lace .

In o rde r f o r h o s p i t a l s to meet the demands o f the p a t i e n t s they serve, c o n t i n u a l upgrad ing and m o d e r n i z a t i o n is r e q u i r e d .

One o f the major obs tac les Faced by Hosp i t a l P lann ing Committees is to de f i ne at what p o i n t they pass beyond the scope o f " m o d e r n i z a t i o n " , and e n t e r the area o f "new c o n s t r u c t i o n " . As noted in the o r i g i n a l p roposa l , t h i s a l so appears to be an u n c l e a r l y de f i ned area f o r a u t h o r i t i e s hav ing J u r i s d i c t i o n . In o rde r not to t o t a l l y s t i f l e the c o m p e t i t i v e na tu re o f the Hea l th Care I n d u s t r y due to the i n a b i l i t y to progress at a r a t e d i c t a t e d by our changing t imes , and the a b i l i t y to p rov i de a e s t h e t i c a l l y p leas ing atmospheres f o r the p a t i e n t s we serve w i t h o u t major cost inc reases to these p a t i e n t s , t h a t would be r e q u i r e d i f "new c o n s t r u c t i o n " s tandards were to be enforced because o f unc l ea r d e f i n i t i o n s . For these reasons I f e e l t h a t r e c o n s i d e r a t i o n o f the Commit tee 's a c t i o n i s a p p r o p r i a t e . COMMITTEE ACTION: Accept in P r i n c i p l e .

NO change necessary. COMMITTEE COMMENT: The Committee feels that the action taken on Comment lOl 201 on 12 I . I .4 .2 (Log #303) should sat isfy the intent of the Submitter.

(Log #8G) I01 - 203 - ( 1 2 - I . G . 2 ) : Reject SUBMITTER: P h i l l i p Z. Tapper, Co l lege Park, MD COMMENT ON PROPOSAL NO.: 101 413 RECOMMENDATION: Delete Types I I I (200) and V (000) f rom t a b l e . SUBSTANTIATION: The t a b l e has been des igna ted as types o f b u i l d i n g c o n s t r u c t i o n t h a t h e a l t h care occupancies s h a l l be l i m i t e d to , s ince Types I I I (200) and V (000) are not p e r m i t t e d in any case, they should not be i nc l uded in the t a b l e . I f i nc luded they would on l y add to i t s c o n f u s i o n . COMMITTEE ACTION: Re jec t . COMMITTEE COMMENT: The Committee Feels t h a t i t is necessary to have these e n t r i e s in the t a b l e , f i r s t to c l a r i f y t h a t they are not p e r m i t t e d , and not j u s t an omiss ion , and secondly to be c o n s i s t e n t w i t h the t a b l e in Chapter 13 which does a l l o w l i m i t e d use o f these c o n s t r u c t i o n types.

(Log #304) 101 - 204 - (Tab le 12 1 . 6 . 2 ) : Accept in Par t SUBMITTER: Douglas S. E r i ckson , American H o s p i t a l Assn. COMMENT ON PROPOSAL NO.: I01-413 RECOMMENDATION: Remove the s p r i n k l e r requ i remen t f rom 2, 3 and 4 s t o r y Type I (443) and (332) and Type I I (222) nu rs ing homes. SUBSTANTIATION: This new requ i remen t is unreasonab le f o r the f o l l o w i n g reasons:

( I ) The ph i l osophy o f Chapters 12 and 13 i s to p r o t e c t the i n s t i t u t i o n a l occupant in p lace . We do t h i s by: p r o v i d i n g s u b s t a n t i a l c o r r i d o r w a l l s and doors; h o r i z o n t a l areas o f re fuge so we d o n ' t have to move nonambula tory p a t i e n t s v e r t i c a l l y ; c o r r i d o r smoke d e t e c t o r s g i v i n g the s t a f f and f i r e s e r v i c e as prompt a response as p o s s i b l e ; s t a f f t r a i n i n g in "how to " respond to a f i r e scenar io , e tc . The record shows a l l the necessary t o o l s are in p lace to p reven t a m u l t i p l e loss o f l i f e f rom a one s t o r y or h igh r i s e b u i l d i n g . The i n s t a l l a t i o n o f a s p r i n k l e r system does l i t t l e or no th ing to c o n t r o l the spread o f smoke, which is the g r e a t e s t hazard to p a t i e n t s .

We b e l i e v e t h a t the c u r r e n t LSC ph i l osophy is sound. That ph i l osophy p ropo r t s t h a t c u r r e n t f e a t u r e s o f h e a l t h care c o n s t r u c t i o n and o p e r a t i o n s p rov ide adequate l e v e l s o f s a f e t y w i t h o u t s p r i n k l e r s .

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(2) As the need for health care changes, more and more acute care f a c i l i t i e s are getting into long term care. Unoccupied f loors of f u l l y complying mult i-story hospitals with strong histories of f~re safety are being converted into units For long term care occupants. The introduction of this proposal places unreasonable financial burdens on health f a c i l i t i e s during a time when reducing health care costs is a major national p r io r i t y .

(3) The author of the proposed change provides absolutely no documentation or s ta t i s t i ca l support for the need for this requirement. Over the years health care has demonstrated uncompromising levels of f i r e safety. (There is every reason to believe that this proud record shall continue with hospital-based long term care f a c i l i t i e s . )

The NFPA process is designed to respond to demonstrated and substantiated need; neither of which are included in the proposal. COMMITTEE ACTION: Accept in Part.

Remove the sprinkler requirements from two-story Type I (443) (332) and Type I I (222) nursing homes. COMMITTEE COMMENT: The Committee does not agree with the substantiation that sprinklers "do l i t t l e or nothing to control the spread of smoke". The Committee feels that sprinklers wi l l control the Fire and thereby l im i t the development of smoke. However, the Committee feels that since this is a "defend in place" occupancy, the s ta f f , in conjunction with equipment and other protection Features required, can provide the protection of the patients. I f evacuation is needed i t is not impractical to evacuate a two-story Fac i l i t y with the s ta f f provided.

(Log #328) lOt - 205 - (Table 12-1.6.2): Accept in Part $UBMITTER: Richard D. Strub, Hillhaven Corp. COMMENT ON PROPOSAL NO.: I01-413 RECOMMENDATION: Delete revised Table 12-I.6.2 and retain original table from 1985 Life Safety Code. SUBSTANTIATION: Hillhaven Corporation operates nursing home Fac i l i t ies in 42 states. We feel that the proposed change to Table 12-I.6.2 places unnecessary restr ic t ions on one- and two-story health care f a c i l i t i e s . Our Corporation believes that the defend-in-place policy in Type I and I I (222) Buildings adequately protects our residents. The sprinkler requirement is therefore an unjust i f iable expense. COMMITTEE ACTION: Accept in Part.

See Comment 101-204 on 12-I.6.2 (Log #304). COMMITTEE COMMENT: The action taken on Comment I01-204 (Log #304) should sat isfy part of the Submitter's concern. The Committee Feels that the remaining changes to the table are jus t i f ied For l i f e safety purposes.

(Log #42) lOt - 206 - (Table 12-l.6.2): Accept in Principle $UBHITTER: Autumn H. Blakeley, Milwaukee, WI COMMENT ON PROPOSAL NO~: I01-413 RECOMMENDATION: Delete the entire table as proposed in 413 and support the Subcommittee on Health Care Occupancies recommendation. SUBSTANTIATION: This is a reversal of the Subcommittee on Health Care Occupancies position that there is no j us t i f i ca t i on to continually create a more res t r i c t i ve code in occupancies which have highly ski l led s ta f f and where Fire record cannot j u s t i f y a position. COMMITTEE ACTION: Accept in Principle.

See Comment I01-204 on 12-I.6.2 (Log #304). COMMITTEE COMMENT: The action taken on Comment I01-204 (Log #304) does revert to the original Subcommittee on Health Care Occupancies'action.

(Log #288) lOt - 207 - (Table 12-1.6.2): Accept in Part SUBMITTER: Ray Taylor, ARA Living Centers COMMENT ON PROPOSAL NO.: I01-413 RECOMMENDATION: Delete proposed Table 12-I.6.2 and retain existing table from 1985 edition.

SUBSTANTIATION: AS a representative of a large nursing home chain in the lower midwestern states, I recommend that the existing Table 12-I.6.2 in the 1985 edition be retained. The new requirements place unduly restr ict ions on new 2 and 3 story f a c i l i t i e s of Type I or I I (222) construction types. Many of our f a c i l i t i e s are constructed in remote areas lacking public water which results in prohibit ive sprinkler insta l la t ion cost. Restricting these Fac i l i t ies to one-story by eliminating the construction option has not been adequately jus t i f i ed . COMMITTEE ACTION: Accept in Part.

See action on Comment 101-204 on 12-1.6.2 (Log #304). COMMITTEE COMMENT: The action taken on Comment 101-204 (Log #304) should sat is fy part of the Submitter's concern. The Committee feels that the remaining changes to the table are jus t i f i ed For l i f e safety purposes.

(Log #454) I01 - 208 - (Table 12-I.6.2): Accept in Part SUBMITTER: William E. KoFFel, KoFFel Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-413 RECOMMENDATION: The proposal should be rejected. SUBSTANTIATION: Throughout the BCMC process and submission of the proposal there has been no substantiation presented to j us t i f y the revision. The presence or lack of s ta f f does not effect the f l r e resistance and structural in tegr i ty of the building. The proponent has fai led to document that the Fire severity is greater in nursing homes than in hospitals. Likewise, histor ical f i r e data Fails to provide substantiation for the change. COMMITTEE ACTION: Accept in Part.

See Comment I01-204 on 12-1.6.2 (Log #304). COMMITTEE COMMENT: The action taken on Comment I01-204 (Log #304) should sat isfy part of the Submitter's concern. The Committee feels that the remaining changes to the table are jus t i f i ed for l i f e safety purposes.

(Log #497) lOl - 209 - (Table 12-1.6.2): Accept in Part SUBMITTER: Mike Thompson, American Health Care Assn. COMMENT ON PROPOSAL NO.: I01-413 RECOMMENDATION: Reject Proposal I01-413 and retain existing table in the 1985 edition. SUBSTANTIATION: Where is the documentation substantiating the change to require sprinklers in 2- or 3-story nursing homes and not hospitals of Type I and Type I I (222) construction? In the past I0 years, there has only been one multiple l i f e loss F~re i r a nursing home, which, incidently, occurred in a one-story Fac i l i ty . The Committee's anticipatlon that patients w i l l have to be moved ver t i ca l l y is no more relevant to a nursing home than a hospital. The defend-in place concept followed by horizontal movement is s t i l l a viable concept in nursing homes and has. been documented as an acceptable concept by lack of multiple death nursing homes Fires. The current nonsprinkler option should be continued in the under 75 Ft Faci l i t ies unti l documentation is provided that substantiates the change. Many nursing homes are constructed in areas which lack public water supply. The Current standard allows the two or three-story nursing homes to be bui l t with more stringent requirements. This change has eliminated the nonsprinklered option for a two-story nursing home, yet not For a hospital, simply because the Committee anticipates vert ical evacuation in nurslng homes only COMMITTEE ACTION: Accept in Part.

See Comment 101-204 on 12 1.6.2 (Log #304). COMMITTEE COMMENT: The action taken on Comment 101-204 (Log #304) should sat isfy part of the Submitter's concern. The Committee feels that the remaining changes to the table are jus t i f i ed For l i f e safety purposes.

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(Log #498) 101 - 21O - (12-2.2.2.2 Exception No. 2): Accept in Principle SUBHITTER: Mike Thompson, American Health Care Assn. ~QMMENT ON PROPOSAL NO.: I01-41~ RECOMMENDATION: Revise Exception 2 under Section 12-2.2.2.2 by adding "units, wings or f loors of health care f a c i l i t i e s dedicated to occupants with Alzheimer's disease," between the words "hospitals" and "and". SUBSTANTIATION: A new trend to the nursing home industry is to provide wings, Floors or units in a nursing home dedicated to housing occupants suffer ing From Alzheimer's disease. Due to the nature of this disease, locking arrangements similar to those permitted in psychiatric hospitals is necessary. Adoption of this proposal w i l l provide guidance to those health care f a c i l i t i e s with Alzhe~mer units. COMMITTEE ACTION: Accept in Principle.

Revise 12-2.2.2.2 Exception No. 2 to read as Follows: E x c e p t i o n No. 2: Door l o c k i n g a r r a n g e m e n t s a re

p e r m i t t e d i n h e a l t h c a r e o c c u p a n c i e s , o r p o r t i o n o f health care occupancies, where the c l in ica l needs of the patients require specialized security measures For the i r safety, provided keys are carried by s ta f f at a l l times. COMMITTEE COMMENT: The Committee Feels that this has always been the intent of this paragraph and that the c l a r i f i c a t i o n provided by the Committee should meet the Submitter's intent.

(Log #499) I01 - 211 (12-2.2.2.8 and Exception): Accept in Principle SUBMITTER: Mike Thompson, American Health Care Assn. q0MMENT ON PROPOSAL NO.: 101-414 RECOMMENDATION: Delete 12-2.2.2.8 with Exception and reword as follows:

12-2.2.2.8 High rise health care occupancies shall comply with the provisions of 5-2.1.5.2. SUBSTANTIATION: Simpl i f icat ion of wording the section. COMMITTEE ACTION: Accept in Principle.

Revise the new 12-2.2.2.8 as Follows: 12-2.2.2.8 High rise health care occupancies shall

comp ly w i t h t he p r o v i s i o n s o f 5 - 2 . 1 . 5 . 2 . S e l e c t e d doo rs on s t a i r w a y s may be equ ipped w i t h h a r d w a r e t h a t p r e v e n t s re e n t r y i n acco rdance w i t h 5 - 2 . 1 . 5 . 2 E x c e p t i o n No. I ,

D e l e t e t he E x c e p t i o n . COMMITTEE COMMENT: The Committee agrees with the ed i tor ia l intent of the Submitter. The provisions proposed by the Committee should sat isfy the Submitter's intent.

(Log #305) 101 212 - (12-2.3.3 Exception NO. 2): Accept in Principle SUBMITTER: Douglas S. Erickson, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-417 RECOMMENDATION: Reword p roposed E x c e p t i o n No. 2 t o r e a d :

Exception No. 2: Aisles, corridors and ramps in a reas n o t i n t e n d e d For t r e a t m e n t o f i n - p a t l e n t s may be a min imum o f 5 Ft (152 cm) i n c l e a r and u n o b s t r u c t e d w i d t h , SUBSTANTIATION: Occupants o f ou t p a t i e n t t r e a t m e n t a reas a re assumed to be a m b u l a t o r y and t h e r e f o r e capable of self-preservation. Eight Feet wide corridors are not a necessity because patients are not evacuated via l i t t e r s , beds, or wheelchairs. COMMITTEE ACTION: Accept in Principle.

Revise 12-2.3.3 Exception to read as Follows: Exception: Aisles, corridors and ramps in adjunct

areas not intended For the housing, treatment, or use of in-patients may be a minimum of 44 in. (I12 cm) in clear and unobstructed width. COMMITTEE COMMENT: The Committee Feels that revising the present Exception would be clearer and meet the intent of the Submitter.

(Log #159) I01 - 213 - (12-2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: 101-414 RECOMMENDATION: Delete a l l of current 12-2.11. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places a l l the acceptable means of egress components For this occupancy and thei r associated "special features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording for this expanded 2.2 section comes from the 2.11 Special Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #550) 101 - 214 - (12-2.11.5 and 13-2.11.5): Reject SUBMITTER: Roll Jensen, P.E., James Antel l , A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-435 RECOMMENDATION: Reject Proposal 101 435. SUBSTANTIATION: Proposal I01-63, which has been accepted, deletes the Code requlrement For automatic closing doors to be operated by the sprinkler system based on l ) smoke detection is also required which w i l l close the doors when smoke is present, 2) smoke detectors w i l l be expected to activate before sprinklers, 3) a connection from the sprinkler system to the Fire alarm system to the automatic door releases is too expensive and compleK to prohibit alternatives All of these Factors apply to health care occupancies especially exist ing health care occupancies. q0MMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that closing the doors to control the movement of smoke either by zone or throughout the f a c i l i t y is necessary when a Fire has been detected by sprinklers in th is, a "defend-in-place," occupancy.

(Log #41) 101 - 215 - ( 1 2 - 2 . 1 1 . 8 and 1 3 - 2 . 1 1 . 8 ) : R e j e c t SUBHITTER: Autumn H. B l a k e l e y , M i lwaukee , WI COMMENT ON PROPOSAL NO.: 101 436 RECOMMENDATION: R e i n s t a t e t e x t recommended by the Subcommi t tee on H e a l t h Care Occupanc ies . SUBSTANTIATION: Handrails are a part of the compartmentation provlded For this occupancy as an element in the path of egress. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Chapters 12 and 13 do not require handrails in corridors, and therefore the strength provisions would be to a non-requirement. Handrails in stairs and other locations are regulated by Chapter 5 which has determined not to impose strength requirements in this Code.

(Log #306) 101 - 216 - (12-3.2.1): Accept in Principle SUBMITTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: I01-440 RECOHHENDATION: Revise proposal as Follows:

12-3.2.1 Hazardous Areas. Central/bulk laundries greater than 100 sq Ft.

SUBSTANTIATION: The establishment of a square Footage c r i t e r i a For personal/therapeutic laundry Fac i l i t ies is inappropriate. The number of machines (dryers) is the real concern and no where in the proposed language does i t address the hazard. Individual Floor therapeutic laundries present the same i f not a lesser hazard than a standard semi-private room. These areas are locked when not in use and highly monitored when being occupied. COMMITTEE ACTION: Accept in Principle.

Do the change for laundries in both Chapters 12 and 13. COMMITTEE COMMENT: The Committee agrees with the Submitter but notes that this needs to be done to both Chapters 12 and 13.

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(Log #500) I01 - 217 - (12-3.2.1): Accept SUBMITTER: Mike Thompson, American Health Care Assn. COMMENT.ON PROPOSAL NO.: I01-440

I RECOMMENDATION: Revise f i r s t column entry to read: "Boiler and fue l - f i r ed heater rooms".

SUBSTANTIATION: I t is believed that the intent was not to require e lect r ic unit heaters or heat pumps to be located in a 2-hour enclosure or l-hour enclosure with sprinklers. These types of units may be Found in certain areas of small nursing home f a c i l i t i e s and afforded no more of a Fire hazard than an a i r conditioning unit. COMMITTEE ACTION: Accept.

(Log #65) I01 - 218 - (12-3.2.1): Reject SUBMITTER: Thomas D. Mattern, UCLA Neuropsychiatric Hospital COMMENT ON PROPOSAL NO.: I01-440 RECOMMENDATION: Under def in i t ions, 7th def in i t ion "Laundries greater than I00 sq f t " change to read:

"Commercial laundries greater than 200 sq Ft". SUBSTANTIATION: While I have general agreement with the Committee's actions, I feel that I00 sq f t becomes too res t r ic t i ve without a fur ther def in i t ion of a "laundry".

Psychiatric hospitals are required to provide a "home environment" for the i r patients. In order to meet this requirement, and what is also considered a part of the therapeutic treatment for patients, small "laundry" Fac i l i t ies consisting of a washer and dryer are required. The f e a s i b i l i t y of inserting these two machines in I00 sq f t of space becomes unreal is t ic , and in most cases occupy spaces of 150 to 200 sq f t .

In addition, where washers and dryers are located on patient units, these locations are generally under direct supervision of s ta f f assigned to the patient care area and are not used for the laundering of hospital supplied materials ( i . e . , sheets, pillowcases, etc.) but rather for patient personal clothing.

By regulations governing licensing and accreditation, a l l laundry areas are to be inspected and monitored daily for build up of l i n t or other combustible material.

In my eleven years of experience with this type of setting, only one minor " f i r e " has occurred, and that incident was caused by an overheated motor on a washing machine.

I t is my opinion that the Committee reconsider this specif ic item within the proposed standard. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The action taken on Comment I01-216 on 12-3.2.1 (Log #306) has inserted the term "central/bulk" which the Committee Feels more accurately describes these Fac i l i t ies rather than the term "commercial". The Committee Feels that the 100 sq f t l im i ta t ion is rea l i s t i c especially considering that this would now only apply to the central/bulk laundries and not therapeutic "laundries which may be provided.

(Log #307) I01 - 219 - (12-3.2.4 and 13-3.2.4): Accept SUBMITTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: 101-443 RECOMMENDATION: Revise proposal by changing the reference from "NFPA 56F" to "NFPA 99". $~BSTANTIATION: NFPA 56F has been incorporated in NFPA 99. COMMITTEE ACTION: Accept.

(Log #442) lot - 220 - (12-3.2.4 and ]3-3.2.4): Accept SUBMITTER: James E. Bikes, Ft. Worth, Tx COMMENT ON PROPOSAL NO.: 101-443 RECOMMENDAT~: Log #504 ". . . in accordance with NFPA 56F" this should be amended to read " in accordance with NFPA 99," SUBSTANTIATION: NFPA 56F has been incorporated into NFPA 99. COMMITTEE ACTION: Accept.

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(Log #455) I01 - 221 - (12-3,4.3.1 Exception and 13-3.4.3.1 Exception): Reject SUBMITTER: William E. Koffel , KoFfel Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-446 RECOMMENDATION: Add a new Exception to read as Follows:

Exception: Patient room detectors are not required to i n i t i a t e a general alarm. SUBSTANTIATION: I f Proposal No. 455 Is accepted by the Committee and NFPA membership the smoke detectors would have to i n i t i a t e the building Fire alarm system by the provisions of this section. The Exception is intended to c l a r i f y that the room detectors need only annunciate as required by proposed section 12-3.4.5.3.

Even i f Proposal No. 455 is rejected, the Exceptlon is s t i l l appropriate. Whereas the requirement for room detectors appears in some building codes, Fac i l i t ies (long term care) may elect to eliminate the corrldor detectors as permitted in 12-3.4.5. For this reason the Exception is proposed For Chapter 13 also. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Comment 101-253 on 12-3.4.5.3 q, Log #309) has eliminated the requirement for smoke detectors in patient 's sleeping rooms. I f smoke detectors are used as an al ternat ive to other provisions of the Code i t is the intent o£ the Code that these do i n i t i a t e the alarm. IF the detector:, are required by some other code they are not required under this Code and therefore are not regulated by this (]ode.

(Log #347) 101 - 222 - (12-3.4.3.1, 12-3.4.2, 12-3.4.5, 12-3.4.5.1, 13-3.4.5 Exception No. l , 12-3.4.5.1, 12-3.4.5.2, 12-3.4.5.3 and 12-3.4.5.4): Accept in Part in Principle SUBMITTER: Samuel S. Levinrad, Veterans Administration COMMENT ON PROPOSAL NO.: 101-445, 447, 449, 450, 451, 453, 454, 455, 456 RECOMMENDATION: Change From "Accept" to "Reject". SUBSTANTIATION: There are several areas which I f ind disturbing with respect to the Board of Coordination of Model Codes (BCMC).

I. I understand the BCMC's concern with respect to the nuisance a larm problems o f smoke d e t e c t o r s . I f they are a major problem the Code should e i t h e r prohibit their use or in an Appendix Suggest an application.

2. Apparently the BCMC is not Familiar with the operation of a medical facility. Medical facilities are staffed 24 hours a day. Adding room detectors connected to the nurses call emergency circuit mandates a pre-signal which has been previously discussed and increase the nurses responsibility and workload. If the detectors are there to prohibit smoking in patient rooms this is an administrative problem, not a Code problem,

3. At approximately $I00 per detector installed For a 200 bed hospital the construction cost is unnecessarily increased by at least $2S0,000.

4. By deleting smoke detectors in Fully sprinklered buildings is i t the intent of the Committee on Safety to Li fe to no longer require an early warning system?

5. I agree with the negative comments proposed by Messrs. Benjamin, Bryan, Burgun, Kei l , Nelson and Quiter.

There are several issues where i t appears the BCMC is overstepping i t ' s bounds without basing i ts decisions o n any technical substantiation.

Why in a hospital does the Committee desire a pre-signal system? Can they j u s t i f y the lost t~me in someone to physically ver i fy a f i r e incident before i n i t i a t i n g an alarm? Such an arrangement w i l l cost l ives and could lead to l i t i g a t i o n against the Code making bodies.

The incidence of Fatal Fires in patient rooms is minimal. Rather than requiring detectors in each patient room, the Committee should be addressing the fa i lu re of medical Fac i l i t i es to implement and carry out a rigorous nonsmoking policy.

Smoke detectors are an early warning device. To write an Exception to the use of smoke detectors in a f u l l y sprinklered building is unsubstantiated. I t is not the duty of a Code Making Panel to write standards because they "think" a Fire detection device is 6verly sensitive or is causing "false alarms". This is the responsib i l i ty of UL or FM, not NFPA lot .

NFPA 72E does not contain smoke detector spacing requirements. Appendix A of 72E recommends spacing.

The panel in recommending e i ther a v e r i f i c a t i o n c i r c u i t or v e r i f i c a t i o n panel f o r smoke detectors is once again asking for problems. This recommendation should not apply to hospitals. The use of a v e r i f i c a t i o n alarm or c i r c u i t w i l l also delay the alarm signal from other alarm, i n i t i a t i n g devices on the same c i r c u i t as the smoke detectors, such as the manual box, f low switch or heat detector. I t is doubtful that the local inspection au thor i ty w i l l approve th is arrangement. I therefore recommend that th is requirement also be rejected. COMMITTEE ACTION: Accept in Part in Pr inc ip le .

With regard to Proposal No. 445 Reject. With regard to Proposal No. 447 Reject. With regard to Proposal No. 449, 455, and 450 see

Committee Action on Comment I01-253 on 12-3.4.5.3 (Log #309).

With regard to Proposal NO. 454 and 453 Accept in Pr inc ip le . See Committee Action on Comment I01-251 on 12-3.4.5.1 (Log #308).

With regard to Proposal No. 451 Accept in Pr inc ip le . See Committee Action on Comment 101-251 on 12-3.4.5.1 (Log #308), Comment 101-253 on 12-3.4.5.3 (Log #309), and Comment I01-279 on 12-3.4.5.4 (Log #14).

With regard to Proposal No. 45G Accept in Pr inc ip le . See Comment 101-279 on 12-3.4.5.4 (Log #14). COMMITTEE COMMENT: The Committee has rejected the Submitter's request to re ject Proposal 101-445 since the Committee is not intending to permit pre-signal systems. Proposal 101 445 refers to Proposal 101 446. The intent of the Submltter is unclear wlth regard to th is paragraph. I t appears that his intent to p roh lb i t pre-signal systems which these proposals do.

The Committee has rejected the Submitter's request to re ject Proposal I01-447 since the Committee believes that smoke detector v e r i f i c a t i o n is an acceptable method o f avo id l ng unwanted False alarms t h a t n o t i f y the F i re depar tment .

With regard to the remain ing p roposa ls which the Submi t t e r i s commenting on, the a c t i o n s taken on Comments 101-251. 101-253, and 101-279 should s a t i s f y the i n t e n t o f the Subm i t t e r .

(Log ~456) 101 - 223 - (12-3.4.3.2 Exception No. 2 (New) and 13-3.4.3.2 Exception No. 2 (New)): Reject SUBMITTER: Will iam E. KogFel, KofFel Assoc., Inc. COMMENT ON PROPOSAL NO.: 101-448 RECOMMENDATION: Number the Exception proposed in Proposal No. 101-447 as Exception No. l and add a new Exception to read as fo l lows:

Exception No. 2: Patient room detectors are not required to transmit an alarm to the Fire department. SUBSTANTIATION: As proposed, one could in te rpre t the Code to require pat ient room detectors as proposed in Proposal No. 455 and as required by some bui ld ing codes to automatically transmit an alarm to the f i r e department. The intent of the BCMC recommendation was to sound a l oca l a larm on ly . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee has deleted the requirement For pat ient sleeping room detectors. See Comment 101-253 on 12-3.4.3.2 (Log #309).

The Committee Feels that i f smoke detectors are used as a trade o f f fo r other requirements then they should not be exempted. IF they are ins ta l led to meet other codes they are not required by NFPA 101 and need not meet the provision.

(Log #436) 101 - 224 - (12-3.4.5) : SUBMITTER: Karl A. Krause, Karl Krause Corp. COMMENT ON PROPOSAL NO.: 101-451 RECOMMENDATION: (Commenter provided no comment.) SUBSTANTIATION: None. COMMITTEE ACTION: RETURNED TO SUBMITTER.

(Log #437) 101 - 225 - (12-3.4.5): SUBMITTER: Karl A. Krause, Karl Krause Corp. COMMENT ON PROPOSAL NO.: 101-453 RECOMMENDATION: (Commenter provided no comment.) SUBSTANTIATION: None. COMMITTEE ACTION: RETURNED TO THE SUBMITTER.

(Log #438) 101 - 226 - (12-3.4.5): SUBMITTER: Karl A. Krause, Karl Krause Corp. COMMENT ON PROPOSAL NO.: I01-454 RECOMMENDATION: (Commenter provided no comment.) SUBSTANTIATION: None. COMMITTEE ACTION: RETURNED TO THE SUBMITTER.

(Log #439) 101 - 227 - (12-3.4.5): SUBMITTER: Karl A. Krause, Karl Krause Corp. COMMENT ON PROPOSAL ~ : I01-455 RECOMMENDATION: (Commenter provided no comment.) SUBSTANTIATION: None. COMMITTEE ACTION: RETURNED TO THE SUBMITTER.

(Log #440) I01 - 228 - (12-3.4.5): SUBMITTER: Karl A. Krause, Karl Krause Corp. COMMENT ON PROPOSAL NO~: 101-456 RECOMMENDATION: (Commenter provided no comment.) SUBSTANTIATION: None. COMMITTEE ACTION: RETURNED TO THE SUBMITTER.

(Log #551) 101 - 229 - (12-3.4.5): Accept in Pr inc ip le SUBHITTER: Roll Jansen, P.E,, James An te l l , A . I .A . , Roll Jensen& Associates, Inc. COMMENT ON PROPOSAL NO.: I01-449 RECOMMENDATION: Reject Proposal I01-449. SUBSTANTIATION: See comments on Proposals 101-454 and 101-455. COMMITTEE ACTION: Accept in P r i n c i p l e .

See Comment 101-253 on 1 2 - 3 . 4 . 5 . 3 (Log #309). COMMITTEE COMMENT: The a c t i o n taken on Comment I01-253 (Log #309) should sa t is fy the in tent of the Submitter.

(Log #346) 101 - 230 - (12-3.4.5): Accept in Pr inc ip le SUBMITTER: Peter I . Bentivegria, Bala Cynwyd, PA COMMENT ON PROPOSAL NO.: 101-449 RECOMMENDATION: Delete ent i re change. Leave Code as is. SUBSTANTIATION: Too cost ly, detectors create False alarms, hospitals are adequately s taf fed to protect pat ients. COMMITTEE ACTION: Accept in Pr inc ip le .

See Action on Comment I01-253 on 12-3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101-253 should sa t i s f y the in tent of the submitter.

(Log #48) I01 - 231 - (12-3.4.5): Accept in Pr inc ip le SUBMITTER: Marlene J. Berkoff , San Rafael, CA COMMENT ON PROPOSAL NO.: 101 449 RECOMMENDATION: Delete recommendation to "implement the recommendations From the Board For the Coordination of the Model Codes (BCMC) with respect to pat ient sleeping room detectors that may be t ied into the nurse ca l l system." SUBSTANTIATION: Problem is that there is no substant iat ion in f i r e record of hospi ta ls showing a need For smoke detectors in pat ient rooms i f they are also in corr idors. Smoke detectors in pat ient rooms

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often give false alarms. This creates chaos on nursing units and also leads s ta f f to disregard the warnings -- when one time i t may be real. Hospitals are staffed 24 hours a day. There is continued surveillance of patient rooms. Alarms going o f f w i l l excite patients and w i l l not help s ta f f and w i l l add greatly to hospital costs. Even the requirement For corridor smoke detectors was removed From the 1976 edition of NFPA 101 as belng redundant and unnecessary in a 24-hour staffed Fac i l i ty . COMMITTEE ACTION: Accept in Principle.

See Action on Comment I01-253 on 12-3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101-253 should sat is fy the intent of the submitter.

(Log #47) 101 - 232 - (12-3.4.5): Accept in Principle SUBMITTER: Autumn H. Dlakeley, Milwaukee, WI C~MMENT ON PROPOSAL NO.: I01-449 RECOMMENDATION: Delete the entire paragraph, "Implement the recommendations From the Board for the Coordination of Model Codes (BCMC) with respect to sleeping room detectors that may be tied into the nurse call system." SUBSTANTIATION: This w i l l cause havoc with nursing personnel when smoke detectors emit False alarms repeatedly. There is no f i r e record to substantiate such an expensive requirement. COMMITTEE ACTION: Accept in Principle.

See Action on Comment lOI-2S3 on 12-3.4.5.3 (Log #309). ~OMMITTEE COMMENT: The action taken on Comment I01-253 should sat isfy the intent o f the submitter.

(Log #552) 101 - 233 - (12-3.4.5): Accept in Principle SUBMITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, I n c . COMMENT ON PROPOSAL NO.: 101-451 RECOMMENDATION: Reject Proposal I01-451. SUBSTANTIATION: See comments on Proposals I01-454 and 101-455. COMMITTEE ACTION: Accept in Principle.

See Comment lOI-251 on 12-3.4.5.1 (Log #308), Comment 101-253 on 12-3.4.5.3 (Log #309), and Comment 101-279 on 12-3.4.5.4 (Log #14). ~_QMMITTEE COMMENT: Action taken on Comment I01-251, 101-253, and 101-279 should sat is fy the intent of the Submitter.

(Log #344) I01 - 234 - (12-3.4.5): Accept in Principle SUBMITTER: Peter I. Bentivegria, Bala Cynwyd, PA ~__OMMENT ON PROPOSAL NO.: I01-451 RECOMMENDATION: Delete entire change. Leave Code as is. SUBSTANTIATION: Degree of safety proposed excessive. COMMITTEE ACTIONN: Accept in Principle.

See Comment I01-251 on 12-3.4.5.1 (Log #308), Comment 101-253 on 12-3.4.5.3 (Log #309), and Comment I01-279 on 12-3.4.S.4 (Log #14). COMMITTEE COMMENT: Action taken on Comment I01-251, 101-253, and 101-279 should sat isfy the intent of the Submitter.

(Log #45) 101 - 235 - (12-3.4.5): Accept in Principle SUBMITTER: Autumn H. Blakeley, Milwaukee, WI COMMENT ON PROPOSAL NO.: 101-451 RECOMMENDATION: Delete the entire paragraph:

"12-3.4.5 Detection. 12-3.4.5.1 Corridors. An approved automatic smoke

detection system shall be installed in a l l corridors and shall activate the f i r e alarm system in accordance with 7-6.2.

Exception: Buildings protected throughout by an approved supervised automatic sprinkler system in accordance with Section 7-7.

12-3.4.5.2 Spaces Open to Corridors. See ]2-3.6.1. 12-3.4.5.3 Patient Sleeping Rooms. Patient sleeping

rooms shall be provided with a smoke detector complying with the requirements of UL 217 or UL 268 permanently connected to house current. Such detectors shall provide a visual display on the corridor side of each patient room and shall provide an audible and visual alarm at the nursing station attending that room. Such detector and related devices may be combined with the nursing call system and the total system need not be e lec t r i ca l l y supervised. The room detector may be used to close the door in accordance with 12-3.G.3.3.

Exception: In rooms equipped with automatic door closing devices with integral smoke detectors on the room side, the integral detector may substitute in accordance with i ts l is t ing For the required smoke detector provided i t performs the required alert ing functions.

12-3.4.5.4 Hazardous Areas. Heat detectors shall be installed in hazardous areas which are not sprlnklered and shall sound an alarm at a constantly attended location. (See 12-3.2.1.)" SUBSTANTIATION: The provision overrules the Subcommittee on Health Care Occupancies which decided i t to be expensive and not warranted by f i r e experience. COMMITTEE ACTION: Accept in Principle.

See Comment 101-251 on 12-3.4.5.1 (Log #308), Comment 101-253 on 12-3.4.5.3 (Log #309), and Comment I01-279 on 12-3.4.5.4 (Log #14). COMMITTEE COMMENT: Action taken on Comment I01-251, I01-253, and 101-279 should sat isfy the intent of the Submitter.

(Log #200) lOt - 236 - (12-3.4.5): Accept in Principle SUBMITTER: Edwin S. Green, Louisvi l le, KY COMMENT ON PROPOSAL NO.: 101-454, 455, 456 RECOMMENDATION: I object to changing 12-3.4.5 (I01 Life Safety Code 1985). Oo not add smoke detector's in patient rooms. SUBSTANTIATION: Accept the recommendations by the Subcommittee on Health Care Occupancies to reject this excessive and costly change. This Subcommittee is certainly more qualif ied to recommend changes to the Life Safety Code For Hospital Occupancies than are special interest groups. This w i l l be an exorbitantly costly change that w i l l not serve the public interest. COMMITTEE ACTION: Accept in Principle.

See Comment I01-25I on 12-3.4.5.1 (Log #308), Comment I01-253 on 12-3.4.5.3 (Log #309), and Comment I01-279 on 12-3.4.5.4 (Log #14). COMMITTEE COMHENT: Action taken on Comment I01-251, 101-253, and 101-279 should sat isfy the intent of the Submitter.

(Log #16) 101 - 237 - (12-3.4.5): Accept in Principle SUBMITTER: Omer G. Lamothe, Federation of American Hospitals COMMENT ON PROPOSAL NO.: I01-4S4, 455, 456 RECOMMENDATION: Do not change existing 12-3.4.5 (I01 Life Safety Code 1985). SVBSTANTIATION: I. Proposed change was rejected by Subcommittee on Health Occupancies af ter lengthy consideration of BCMC report on the subject.

2. Presignaling has always been considered a hazard in health care Fac i l i t ies .

3. Corridor and/or room smoke detectors are excessive, costly to instal l and maintain.

4. Hospitals are in a di f ferent class from nursing homes as Far as staff ing and training are concerned. COMMITTEE ACTION: Accept in Principle.

See Comment I01-251 on 12 3.4.5.1 (Log #308), Comment 101-253 on 12-3.4.5.3 (Log #309), and Comment I01-279 on 12-3.4.5.4 (Log #14). ~OMMITTEE COMMENT: Action taken on Comment I01-251, 101-253, and I01-279 should sat isfy the intent of the Submitter.

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(Log #202) I01 - 238 - (12-3.4.5): Accept in Principle $UBMITTER: Gary L. Vance, Louisvi l le, KY COMMENT ON PROPOSAL NO.: 101-454, 455, 45G RECOMMENDATION: Make no change to 12 3.4.5 (lOl Life Safety Code 1985). $VBSTANTIATION: A) A presignaling Fire alarm system is not in the best interest of patient safety because i t does not a ler t a l l s ta f f who must act quickly to i n i t i a t e their Fire plan. Because of False alarms with smoke detectors, the s ta f f w i l l get into the habit of checking out each alarm before they w i l l feel Free to place an alarm to the Fife department. I f there is a real Fire, minutes can elapse, creating confusion among the s ta f f .

B) A re la t i ve ly Few patient room Fatal i t ies do not j u s t i f y the substantial cost burden on a l l patients imposed by this change. COMMITTEE ACTION: Accept in Principle.

See Comment I01-251 on 12-3.4.5.1 (Log #308), Comment I01-253 on 12-3,4.5.3 (Log #309), and Comment I01-279 on 12-3.4.5.4 (Log #14). COMMITTEE COMMENT: Action taken on Comment I01-251, 101-253, and I01-279 should sat isfy the intent of the Submitter.

(Log #284) I01 - 239 - (12-3.4.5): Accept in Principle SUBMITTER: Lee Roy Ash, Louisvi l le, KY COMMENT ON PROPOSAL NO.: 101-454, 455, 456 RECOMMENDATION: Make no change to 12-3.4.5 (I01 Life Safety Code 1985). SUBSTANTIATION: A recent study commissioned by AHA demonstrates that NFPA records show that typical hospital Fires are not of the nature or type that are most successfully controlled by smoke detectors. COMMITTEE ACTION: Accept ~n Principle.

See Comment I01-251 on 12-3.4.5.1 (Log #308), Comment I01-253 on 12-3.4.5.3 (Log #309), and Comment I01-279 on 12-3.4.5.4 (Log #14). COMMITTEE COMMENT: Action taken on Comment I01-251, I01-253, and I01-279 should sat isfy the intent of the Submitter.

(Log #82) I01 -- 240 - (12-3.4.5): Accept in Principle SUBMITTER: Roger C. Mellem, Washington, DC COMMENT ON PROPOSAL NO.: I01 449 through 456 RECOMMENDATION: None. SUBSTANTIATION: I feel i t shows poor judgement to overrule a very knowledgeable Subcommittee, whose members a re i n t i m a t e l y f a m i l i a r w~th r e q u i r e m e n t s f o r good p a t i e n t c a r e and s a f e t y . There a l s o seems to be an overriding interest in insta l l ing sprinklers throughout a l l health care bulldings. I refer to Exceptions to detectors in Favor of automatic sprinkler systems, which probably protect property and Fire Fighters more than they protect dependent patients during the earl iest moments of a Fire emergency. Pre-alarm systems should not be used in patient care Fac i l i t ies . Nelther should automatic closers on patient room doors. Furthermore, the "equivalency" system of evaluating buildings and their quali t ies of safety to protect inhabitants seems to be disregarded in Favor of adding more water piping throughout buildings to throw water at a time when patients might already have been cut down by unseen and unfelt products of combustion. COMMITTEE ACTION: Accept in Prlnclple.

See Comment I01-251 on 12-3.4.5.1 (Log #308), Comment 101-253 on 12-3.4.5.3 (Log #309), and Comment 101-279 on 12-3.4.5.4 (Log #14). COMMITTEE COMMEN!: Action taken on Comment I01-251, 101-253, and 101-279 should sat isfy the intent of the Submitter.

(Log #255) 101 - 241 - (12-3.4.5): Reject SUBMITTER: John Behrens, Huntington Beach, CA ~_O_MMENT ON PROPOSAL NO.: 101-452 RECOMMENDATION: Reject Proposal I01-452. ~UBSTANTIATION: Should the Committee on Safety to Life eventually reject Proposal I01-455 on smoke detectors in patient sleeping rooms, the Committee is then relying on these corridor smoke detectors to pick up early warning for the patient sleeping rooms and this comment w i l l give the Committee an opportunity to reconsider this proposal in l ight of any Further action taken on Proposal I01-455. ~OMMITTEE ACT!Q~: Reject. C~O_MMITTEE COMMENT: The 30 Ft spacing provisions of this paragraph were established in the Life Safety Code prior to other standards being established on spacing. NOW that spacing standards are established in other documents this is no longer needed in this Code.

(Log #554) 101 - 242 - (12-3.4.5 and 12-3,4.5.1): Accept in Principle =S_UBMITTER: Roll Jensen, P.E., ,]ames Antell, A.I.A., R o l f Jensen & A s s o c i a t e s , I n c . ~OHMENT ON PROPOSAL NO.: 101-450 RECOMMENDATION: R e j e c t P roposa l 101-450. ~VBSTANTIATION: See comments on P r o p o s a l s 101-454 and 101-455 . ~OMMITTEE ACTION: Accep t i n P r i n c i p l e .

See A c t i o n on Comment 101 253 on 1 2 - 3 , 4 , 5 . 3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101 253 should sat isfy the intent of the Submitter.

(Log #46) I01 - 243 - (12-3.4.5 and 12-3.4.5.I): Accept in Principle S UBMITTER: Autumn H. Blakeley, Milwaukee, WI ~OMMENT ON PROPOSAL NO.: 101-450 RECOMMENDATION: Delete the entire paragraph:

• '12-3.4.5 Detection. 12-3.4.5.1 Patient Sleeping Rooms. Patient sleep~ng

rooms shall be provided with a smoke detector comrlying with requirements of UL 217 or UL 268 permanently connected to house current. Such detectors shall provide visual display on corridor side of each patient room and shall provide audible and visual alarm at the nursing station serving that room. Where such detectors and related devices are not combined with the nurse call system, the total system w i l l be e lec t r i ca l l y supervised.

12-3.4.5.2 Corridors. No change From wording of the original 12-3.4.5." SUBSTANTIATION: This provision overrules the Subcommittee on Health Care Occupancies which duly considered this proposal and rejected i t on the basis of Fire record, reasonableness, and impact on s ta f f . COMMITTEE ACTION: Accept in Principle.

See Action on Comment I01-253 on 12-3.4.5.3 (Log #309). _C_QMMITTEE COMMENT: The action taken on Comment 101-253 should sat is fy the intent of the submitter.

(Log #268) 101 - 244 - (12-3.4.5, 12-3.4.5.1, 12-3.4.5.2): Accept in Prlnciple ~LVBMITTER: Major Mike Daniel, US Army COMMENT ON PROPOSAL NO.: 101-454 RECOMMENDATION: Reject Proposal I01-454, p. 347, TCR. SUBSTANTIATION: The compartmentation concept has been and continues to be extremely effect ive in preventing multiple Fatal i t ies in hospitals -- this has proven to hold true in both low and high rise Fac i l i t ies . Even though this is true, we are now required to provide automatic sprinkler protection throughout new high rise hospitals irrespective of constructio~ type.

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The proposal in question w i l l now mandate smoke detectors throughout a l l corridors in a l l nonsprinklered hospitals irrespective of the compartmentation provided. The substantiation given essential ly is that the requirement exists in other sleeping occupancies SO why exempt health care. Chapter 16, New Hotels and Dormitories, is spec i f ica l ly referenced. Would you l ike to compare the staf f ing rat ios between hospitals and hotels/dormitories, to include s ta f f locations and responsibi l i t ies? The comparison is ludicrous. I ts l ike comparing apples and oranges. And better yet, where do we stop? Are we headed for hospitals protected throughout by compartmentation, an automatic sprinkler system, and an automatic smoke detection system? I t certainly appears so. l 'm sure that someone w i l l see some humor in that thinking that no one would even attempt to go to that extreme. Well, For those skeptics, let me be ludicrous for a moment and also refer to Chapter 16, spec i f ica l ly Proposals 101-595 and I01 596 on page 376 of the TCR. And then what? Why not provide a halon system throughout or back up sprinkler and smoke detection system just in case the primary systems Fail. Where do we stop? On that part icular point, I rest my case.

Let's talk dollars for a moment. There are those of us who can p ro f i t Financially From specific code changes, and there are those of us who would earnestly l i ke to have the safest Fac i l i t y possible For the protection of patients and property but happen to be in a position where the cost impact is not d i rec t ly v is ib le . Then there are those of us who s i t in the middle Forced to deal with the cost-benefit side of protection provided/needed/justified versus real d o l l a r s expended - i n o t h e r words , t hose o f us who have to dea l w i t h the r e a l w o r l d . FOr as l o n g as I can remember, one o f t he b i g g e s t economic p rob lems Fac lng ou r n a t i o n has been and c o n t i n u e s to be the r i s i n g c o s t o f h e a l t h c a r e . What does t h a t have to do w i t h us? T h i s p roposed Code change, and any change t h a t we make For t h a t m a t t e r , has t he p o t e n t i a l to impac t s i g n i f i c a n t l y on t he f i n a n c e s o f the h e a l t h ca re i n d u s t r y . T h i s i s no t o n l y t r u e f o r new c o n s t r u c t i o n , b u t , based on the p r o v i s i o n s o f p a r a g r a p h 1 4 . 6 o f t he Code, t he r e q u i r e m e n t wou ld a l s o e x i s t For e x i s t l n g h o s p i t a l s u n d e r g o l n g r e n o v a t i o n / m o d e r n i z a t i o n p r o j e c t s . T h i s added c o s t c o u l d tend t o d i s c o u r a g e o r even p r o h i b i t m o d e r n i z a t i o n o r r e n o v a t i o n t h e r e b y be ing i n t o t a l c o n f l i c t w i t h the i n t e n t o f the L i f e S a f e t y Code. And f o r t hose o f you who do no t see the d o l l a r s expended d i rect ly , I can guarantee you that you w i l l see them indi rect ly for the cost of health care that YOU must pay in the Future. The hospitals have no alternative but to pass these costs on to the consumer. The next time you complain about a b~ll that YOU receive For health care, stop and ask yourself i f you helped contribute to that cost. Then ask yourself i f i t was real ly j us t i f l ed . The bottom l ine is that there comes a time when we must stop. We must, therefore, examine every change we make very careful ly from a cost-benefit standpoint. In other words, any changes we make must be to ta l l y j us t i f i ed and substantiated. Here we must ask ourselves the question, w i l l corridor smoke detectors help us prevent mult iple Fatal i t ies From f i r e in hospitals? The answer is "who knows." The track record of the hospital industry speaks For i t s e l f . Past experience indicates that the problem of mult iple Fatal i t ies From Fire in hospitals has essential ly been al leviated wlth current requirements. Where then is the j us t i f i ca t i on For the proposed a d d i t i o n a l p r o t e c t i o n ? The answer i s t h a t i t canno t be j u s t i f i e d . The q u e s t i o n o f t he s i n g l e f a t a l i t y o b v i o u s l y a r i s e s a t t h i s p o i n t . To t h a t I wou ld l i k e t o be a b l e t o say t h a t I have d e v i s e d a sys tem to p r e v e n t any and a l l l o s s o f l i f e due to F i r e - - bu t I c a n ' t . I t i s a w o n d e r f u l g o a l , bu t u n f o r t u n a t e l y i t i s u n a t t a i n a b l e . We must , t h e n , seek t o m i n i m i z e t hese i n c i d e n t s . I wou ld l i k e to s t r e s s to YOU a t t h i s p o i n t t h a t t he key to m i n i m i z i n g the s i n g l e f a t a l i t y e p i s o d e i s n o t n e c e s s a r i l y an a u t o m a t i c smoke d e t e c t i o n sys tem, a u t o m a t i c s p r i n k l e r s , a u t o m a t i c doo r c l o s e r s , o r o t h e r such b u i l d i n g F e a t u r e s . The key t o m i n i m i z i n g t he s i n g l e f a t a l i t y l i e s i n s t a f f t r a i n i n g . You can have every protection Feature available on the market today instal led in your Faci l i ty , and you are s t i l l going to have Fatal i t ies i f the s ta f f is not properly trained to respond during Fife.

As For e a r l y d e t e c t i o n , I wou ld j u s t l l k e t o remlnd you t h a t e v e r y s t a f f member i s equ ipped w i t h one o f t h e b e s t smoke d e t e c t o r s i n t he w o r l d - - t he nose. And i t J u s t happens t o be one t h a t d o e s n ' t have a p roven t r a c k record of costly and extremely aggravating False alarms. We must, then, come to a point where we stop trying to design buildings to compensate for s ta f f inadequacies. The j u s t i f i c a t i o n is just not there to s u b s t a n t i a t e t h e r e q u i r e m e n t f o r smoke d e t e c t o r s t h r o u g h o u t a l l h o s p i t a l c o r r i d o r s . I wou ld l i k e t o r e i t e r a t e t h a t " j u s t because we have i t i n o t h e r s l e e p i n g o c c u p a n c i e s " i s no t a s u b s t a n t i a t i o n f o r r e q u i r i n g i t i n h o s p i t a l s .

As a f i n a l n o t e , I have a l s o heard the excuse used t h a t we must do t h i s t o come i n t o sync w i t h t he Model B u i l d i n g Codes. My response t o t h a t i s t h a t we a re a consensus organization wri t ing consensus codes and standards. The variety of input and experience golng into the codes and standards developed and adopted by the NFPA is unsurpassed. Perhaps the BCMC should consider bringing the Model Codes in l ine with NFPA Codes and Standards instead of trying to Force Feed us the requirements of the Model Codes. With that, I strongly urge you to reject the submitted Proposal I01-454 thereby deleting the proposed new requirement For smoke detectors ~n hospital corridors. COMMITTEE ACTION: Accept in Principle.

See Comment ]01-251 on 12 3.4.5.I and Exceptlon (Log #308) . COMMITTEE COMMENT: The a c t i o n t aken on Comment 101-25 ] (Log #308) s h o u l d s a t i s f y t he i n t e n t o f t he S u b m i t t e r .

(Log #553) I01 245 - (12-3.4.5, 12-3.4.5.1, 12-3.4.5.2): Accept in Prlnciple SUBMITTER: Roll Jensen, P.E., James Antel l , A.I.A., RolF Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-454 RECOMMENDATION: Reject Proposal I01-454. SUBSTANTIATION: Proposal I01-454 extends the requirements for corridor smoke detectors ~nto a l l nonsprlnklered hospitals. The only reason stated for the requirement is in the BCHC submittal (Proposal I01-451) which states, "The Board sees no Just i f i ca t ion For exempting nonsprlnklered hospitals from the corridor detection provisions." This is not a proper reason For the Life Safety Code to increase the r e q u l r e m e n t s f o r an occupancy . NO c o s t b e n e f l t a n a l y s i s o r l o s s e ~ p e r i e n c e was s u b m i t t e d to j u s t i f y t he a d d l t l o n a l r e q u i r e m e n t . COMMITTEE ACTI_ON: Accep t i n P r i n c i p l e .

See Comment I01 251 on 1 2 - 3 . 4 . 5 . 1 and E x c e p t i o n (Log #308 ) . COMMITTEE COMMENT: The a c t i o n taken on Comment I0 ] 25] (Log #308) s h o J l d s a t i s f y t he i n t e n t o f the S u b m i t t e r .

(Log #301) I01 246 - (12-3.4.5, 12 3.4.5.1 and 12-3.4.5.2): Accept in Principle SUBMITTER: Marvin J. Fischer, Brooklyn, NY COMMENT ON PROPOSAL NO.: I01-454 RECOMMENDATION: This proposal should be rejected. SUBSTANTIATION: I. Section 12-3.5 requires that a l l health care Fac i l i t i es be f u l l y sprinklered.

2. Or ig inal ly when sprinklers were proposed we argued t h a t t h e y were u n n e c e s s a r y . In f a c t , i f we were i n t e r e s t e d i n p a t i e n t s a f e t y and p r o p e r t y damage r e d u c t i o n , smoke d e t e c t o r s m i g h t be used s i n c e a l l h o s p i t a l s a re r e q u i r e d t o have a t r a i n e d f i r e response team and smoke d e t e c t o r s w i l l a l a r m b e f o r e s p r i n k l e r s . T h i s was r e j e c t e d by t he Commi t tee s t a t i n g i n a d e q u a c i e s w i t h smoke d e t e c t o r s . Now t h a t s p r i n k l e r s a re r e q u i r e d , t he smoke d e t e c t o r appears t o have s u d d e n l y come i n t o i t s own. Hav ing b o t h s p r i n k l e r and smoke d e t e c t o r s seems to be the b e l t and suspenders app roach . Bo th s h o u l d no t be r e q u i r e d . Many j u r i s d i c t i o n s s t i l l r e q u i r e t h e c o m p a r t m e n t a l i z a t i o n approach t o c o n s t r u c t i o n . To have t h i s , s p r i n k l e r s and smoke d e t e c t o r s i s an e x c e s s i v e se t o f r e q u i r e m e n t s .

309

3. Stat is t ics collected by the American Hospital Association indicate that the number of deaths that could have been prevented with the use of smoke detectors in patient rooms was very small, either by bed count or patient day count. (miniscule over a f ive year period.)

4. The substantiation that is being used, "to conform to the model building codes", is an improper one. The proposal should stand on i ts own merit.

5. This proposal should be rejected and Further studied while a more uniform approach is taken v is .a .v is , compartmentalization, sprinklers and smoke d e t e c t o r . P r o v i s i o n s must be made to take i n t o accoun t other local law. COMMITTEE ACTION: Accept in Principle.

See Comment 101-251 on 12-3.4.5.I and Exception (Log #308) , COMMITTEE COMMENT: The a c t i o n taken on Comment I01 251 (Log #308) s h o u l d s a t i s f y t he i n t e n t o f t he S u b m i t t e r .

(Log #44) I01 - 247 - (12-3.4.5, 12-3.4.5.1 and 12-3.4.5.2): Accept in Principle SUBMITTER: Autumn H. Blakeley, Milwaukee, WI COMMENT ON PROPOSAL NO.: 101-454 RECOMMENDATION: Delete the entire paragraph. Revise 12-3.4.5 to read as follows:

12 3.4.5 Detection. 12-3.4.5.1 Corrldors. An approved automatic smoke

d e t e c t i o n system s h a l l be i n s t a l l e d i n a l l c o r r i d o r s and s h a l l a c t i v a t e the F i r e a l a r m system i n acco rdance w i t h 7 6 . 2 .

E x c e p t i o n : B u l l d i n g s p r o t e c t e d t h r o u g h o u t by an approved s u p e r v i s e d a u t o m a t i c s p r l n k l e r system i n acco rdance w l t h S e c t i o n 7 -7 .

12-3.4.5.2 Spaces Open to Corrldors. See 12-3.6.1. SUBSTANTIATION: This provision overrules the Subcommittee on Health Care Occupancies which decided i t to be expensive and not warranted by f i r e experience. COMMITTEE ACTION: Accept in Principle.

See Comment I01-251 on 12-3.4.5.1 and Exception (Log #308). COMMITTEE COMMENT: The action taken on Comment I01-251 (Log #308) should sat isfy the intent of the Submitter.

(Log #12) 101 - 248 - (12-3.4.5.1): Accept in Principle ~BMITTER: J. Richard Fruth, Hayes, Large, Suckling, Fruth & Wedge Architects COMMENT ON PROPOSAL NO.: I01-454 RECOMMENDATION: Delete proposed paragraph 12 3.4.5.1. SUBSTANTIATION: There is not a proven need For the insta l la t ion of corridor smoke detectors in hospitals. I f there is a need For smoke detectors, then such smoke detectors should be provided for early warning, and this requirement should be independent of the presence of a f i r e suppression system. The 24 hour staFflng and presence o f smoke d e t e c t o r s as p a r t o f t he smoke p a r t i t i o n system r e q u i r e d on e v e r y s l e e p i n g F l o o r i s su f f ic ient protection For nursing unlts in hospitals. COMMITTEE ACTION: Accept in Principle.

See Comment I01-251 on 12 3.4.5.1 and Exception (Log #308 ) . COMMITTEE COMMENT: The action taken on Comment 101-251 (Log #308) shoul~ sat isfy the intent of the Submitter.

(Log #345) I01 - 249 - (12-3.4.5.1): Accept in Principle ~UBMITTER: Peter I. Bentivegria, Bala Cynwyd, PA COM___MENT ON PROPOSAL NO.: I01-450 RECOMMENDATION: Delete entire change. Leave Code as is. SUBSTANTIATION: Connection of smoke detectors to nurse cal l system w i l l result in needless false alarms, unnecessary burden for nurses. Need not substantiated by s ta t is t ics . Ins ta l la t ion too costly. Presignal systems poor c h o i c e .

COMMITTEE ACTION: Accept in Principle. See Action on Comment 101-253 on 12-3.4.5.3 (Log

#309). COMMITTEE COMMENT: The action taken on Comment I01-253 should sat isfy the intent of the submitter.

(Log #31) I01 250 - ( 1 2 - 3 . 4 . 5 . 1 E x c e p t i o n ) : Accep t i n P a r t SUBMITTER: Joseph A. O r o u i n , S i m p l e x Time Recorder Co. COMMENT ON PROPOSAL NO.: 1 0 ] - 4 5 4 RECOMMENDATION: Replace t he E x c e p t l o n to 1 2 - 3 . 4 . 5 . 1 w i t h the E x c e p t i o n app roved i n p r o p o s a l I Q I - 4 5 3 . SUBSTANTIATION: There i s no s u b s t a n t i a t i o n f o r t he d e l e t i o n o f a c o r r i d o r smoke d e t e c t i o n sys tem when s p r i n k l e r s a re used. S p r i n k l e r s w i l l no t p r o v i d e t he e a r l y w a r n i n g r e q u l r e d to a l e r t t he s t a f f For p a t i e n t e v a c u a t i o n , p a r t i c u l a r l y in a s m o u l d e r i n g f l r e . COMMITTEE ACTION: Accept i n P a r t .

See A c t i o n on Proposa l 101-251 on 1 2 - 3 . 4 . 5 . I and E x c e p t i o n (Log #308 ) . COMMITTEE COMMENT: The Commi t tee has recommended t he d e l e t i o n o f t he E x c e p t i o n f o r s p r i n k l e r p r o t e c t i o n and has r e t a i n e d t he E x c e p t i o n For c o r r i d o r d e t e c t o r s when room d e t e c t o r s a re p r o v i d e d . However , t he Commi t tee has made m o d i f i c a t i o n s to 1 2 - 3 . 4 . 5 . 1 , See Comment lO l 251 on 1 2 - 3 . 4 . 5 (Log #308 ) .

(Log #308) 101 - 251 - ( 1 2 - 3 , 4 . 5 . 1 and E x c e p t i o n ) : Accep t In P r i n c i p l e SUBMITTER: Douglas S. E r i c k s o n , Amer i can H o s p l t a l Assn. COMMENT ON PROPOSAL NO_: 101-454 RECOMMENDATION: Rev ise 12 3 . 4 . 5 . 1 to r e f l e c t the l anguage i n the 1985 e d l t i o n o f NFPA I01 .

1 2 - 3 . 4 . 5 , 1 C o r r i d o r s . An approved a u t o m a t i c smoke d e t e c t i o n sys tem s h a l l be i n s t a l l e d ~n a l l corridors of n u r s i n g homes and l i m i t e d ca re f a c l l ~ t l e s . Such sys tems s h a l l be i n s t a l l e d ~n acco rdance w i t h 7 -6 .

E x c e p t i o n : Where each p a t i e n t s l e e p i n g room is p r o t e c t e d by such an approved d e t e c t i o n system and a l o c a l d e t e c t o r i s p r o v i d e d a t t he smoke b a r r i e r and h o r i z o n t a l e x i t s , such c o r r l d o r sys tems w i l l no t be r e q u i r e d on t he p a t i e n t s l e e p i n g room F l o o r s . SUBSTANTIATION: A d i s t i n c t i o n needs to be made between a c u t e ca re ( h o s p i t a l s ) F a c i l i t i e s , n u r s i n g homes, l i m i t e d - c a r e , and h o s p i c e f a c i l i t i e s . The s t a f f i n g r a t i o s a re d r a s t l c a l l y d i f f e r e n t and t h e r e f o r e the need f o r hardware i s a l s o much d i f f e r e n t . A r e c e n t s t u d y conduc ted by the Amer ican O r g a n i z a t i o n o f Nurse E x e c u t i v e s o f t he Amer ican H o s p i t a l A s s o c i a t i o n shows a d r a m a t i c i n c r e a s i n g i n the n u r s i n g s t a f f t o p a t i e n t r a t i o . In 1980 t he n u r s i n g s t a f f t o p a t i e n t r a t i o was 50 nu rses to e v e r y I00 p a t i e n t s ; i n 1986 t h a t r a t i o had r l s e n to 85 nurses to e v e r y I00 p a t i e n t s ,

H i s t o r i c a l l y , t he LSC has a lways g i v e n c r e d i t to s t a f f as a key e lemen t i n t he p r o t e c t i o n o f p a t i e n t s f r o m the e f f e c t s o f f i r e and smoke. I t seems to me that with an increased nursing staff to patient ratio along with all the other staff (security, engineering, r e s p i r a t o r y , s a f e t y ) who respond t o a F i r e w a r n i n g s i g n a l , t he Code shou ld be l o o k i n g a t d e c r e a s i n g h a r d w a r e .

As o f t o d a y ' s d a t e , we as an i n d u s t r y , h a v e n ' t seen any needs assessment o t h e r t han t he p e r c e i v e d need to c o o r d i n a t e model codes. Th~s reason i s no t adequa te to mandate a system t h a t t he T e c h n l c a l Commi t tee o f I01 dropped back ~n 1976. COMMITTEE ACTION: Accept in P r i n c i p l e ,

Rev ise 1 2 - 3 . 4 . 5 to read as F o l l o w s : 12 3 . 4 . 5 D e t e c t i o n . 12 3 . 4 . 5 . I C o r r i d o r s . An app roved a u t o m a t i c smoke

d e t e c t i o n system s h a l l be i n s t a l l e d i n a l l c o r r i d o r s o f n u r s i n g homes and l i m i t e d ca re f a c i l i t i e s . Such sys tem s h a l l be i n s t a l l e d i n acco rdance S e c t i o n 7 - 6 .

E x c e p t i o n : Where each p a t i e n t s l e e p i n g room i s p r o t e c t e d by an approved smoke d e t e c t i o n sys tem and a smoke d e t e c t o r i s p r o v i d e d a t smoke b a r r i e r s and h o r i z o n t a l e x i t s , such c o r r i d o r sys tems w i l l no t be r e q u i r e d on t he p a t i e n t s l e e p i n g room F l o o r s . COMMITTEE COMMENT: The Commi t tee ag rees w i t h the i n t e n t o f t he S u b m i t t e r however , t he Commi t tee w i shes t o c l a r i f y t he i n t e n t o f t h e E x c e p t i o n .

310

(Log #191) IOI - 252 - (12-3.4.5.1 Exception (New) and 12-3.4.5.3 Exception (New)): Reject SUBMITTER: William R. Wilson, Jones Mah Gaskill Rhodes COMMENT ON PROPOSAL NO.: 101-449, 450, 451 RECOMMENDATION: Add to each:

Exception: Fac i l i t ies in which a no-smoking policy is promulgated and enforced in a l l patient sleeping rooms. SUBSTANTIATION: The careless use of smoking materials is apparently the major cause of fires in patient sleeping rooms. Removing this cause (a remedy which is the increasing trend in public buildings, and par t icu lar ly health care f a c i l i t i e s ) is a preferable exception to the expensive and cumbersome solution of providing a smoke detector or automatic door closer For such rooms. I f such provisions are included in codes, i t is only logical to provide exceptions when the appropriate hazard is removed by enforced policy. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This paragraph deals with design material and when reviewing plans such a policy could not be properly ver i f ied.

4. Unwarranted Burden. Accord ing to r ecen t NFPA data, es t ima ted t o t a l c i v i l i a n f i r e deaths in F a c i l i t i e s Car ing For the S ick , the 1980-1984 combined t o t a l was 30.3. Of t h i s es t ima te 23.2 were i n t i m a t e w i t h the F i r e and t h e r e f o r e under a c o n d i t i o n in which smoke d e t e c t o r s are e s p e c i a l l y i n e f f e c t i v e ( I I were in rooms w i t h smoke d e t e c t o r s ) . Th is r e s u l t s in an estimated 7.1 deaths, (an average of 1.4 deaths per year) where fatal victims were not intimate to the Fire.

During this same time period, hospitals provided 1,888,530,508 patient days of service (377,706,102 patient days per year). Consequently, the probabi l i ty of any given patient being saved by the intervention of a smoke detector in a patient room is less than one in 269,790.072.

In considering that potential ly tens of mil l ions of dollars could be spent on the acquisition, insta l lat ion, maintenance, and testing of smoke detectors in Patient rooms compared to the anticipated safety rat io (1:269,790,072), ~t becomes clear that many more l ives could be saved i f that money was invested in medical services. COMMITTEE ACTION: Accept.

(Log #309) I0I - 253 - (12-3.4.5.3): Accept SUBMITTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO=: I01 455

I RECOMMENDATION: Delete new paragraph 12-3.4.5.3. SUBSTANTIATION: This proposal contradicts long standing NFPA philosophies, is redundant of existing systems, and poses unwarranted o p e r a t i n g and maintenance burdens on h e a l t h care F a c i l i t i e s .

I . C o n t r a d i c t i o n . The NFPA has a long s tand ing ph i l osophy tha t argues aga ins t the use o f p res igna l a la rm systems (see NFPA 72A). Th is proposal contradicts this philosophy in that i t requires that the alarm signal on the corridor side of the patient room and at the nursing station, but not at the Fire service. ( I t is presumed that the authors of the proposal realized that a direct signal to the Fire service would be impractical because of the unmanagable c o n d i t i o n s brought about by unwanted a larms; the same unmanagable c o n d i t i o n s t h a t w i l l c o n f r o n t h o s p i t a l s t a f f . )

2. Redundancy. Th is proposal i s redundant o f e x i s t i n g systems tha t have proven records o f h igh l e v e l s o f sa fe t y . P a t i e n t s a f e t y is ensured by around the c lock s t a f f i n g by t r a i n e d p r o f e s s i o n a l s . P a t i e n t p r o t e c t i o n is a c t u a l ] i ~ Q as the nurse to p a t i e n t r a t i o has increased more than SO percen t in the past f i v e years . Beyond t h i s F i r s t l i n e o f defense, hospitals currently have redundant systems that include automatic alarm and extinguishment systems (Center For Fire Research data show that the respond time of corridor detectors, which are currently required in care-of aged f a c i l i t i e s , is less than one minute longer than room detectors in a flaming Fire situation involving a bed in a patient room).

3. ~uestionable Merit in Practice. Because SmOke detectors are most ef fect ive in conditions involving smoldering Fires and are much less effect ive in conditions involving flaming Fires, their effectiveness in patient rooms is l imited. Analysis of hospital Fire data indicates that the s~gnificant majority of the Fatal victims were intimate with ignit ion. Consequently, smoldering f l res do not seem to contribute to the majority of Fatal Fires in health care Faci l i t ies ,

The number of unwanted alarms w i l l be high and unmanagable. Industry surveys confirm that unwanted alarms dull the response of s ta f f and tend to create a "cry wolf" syndrome in an already Fast-paced nursing unit. Integration of smoke detectors systems and nurse cal l systems w i l l create confusion among s ta f f regarding real Fire emergencies and routine nurse cal ls (bed pans, comfort, refreshments, TV adjustments, and so for th) . Again, unwanted alarms w i l l further aggrevate this confusion.

(Log #73) 101 - 254 - (12 3 . 4 . 5 . 3 ) : Accept ~n P r i n c i p l e SOBMITTEe: Carl Draughon, Ephraim McDowell Regional Medical Center COMMENT ON PROPOSAL NO.: I01 454 RECOMMENDATION: Delete text as follows:

" P a t i e n t S leep ing Rooms. P a t i e n t s l e e p l n g rooms s h a l l be prov ided w i t h a smoke d e t e c t o r comply ing ~ i t h the requ i rements o f UL 217 or UL 268 permanent ly connected to house c u r r e n t . Such d e t e c t o r s s h a l l p rov ide a v i s u a l d i s p l a y on the c o r r i d o r s ide o f each p a t i e n t room and sha l l p rov ide an a u d i b l e and v i s u a l alarm at the nursing station attending that room. Such detector and related devices may be combined with the nursing call system and the total system need not be e lec t r i ca l l y supervised. The room detector may be used to close the door in accordance with 12-3.6.3.3.

Exception: In rooms equipped with automatic door closing devices with integral smoke detectors on the room side, the integral detector may substitute in accordance with i ts l is t ing For the required smoke detector provlded i t performs the required alert ing Functions." SUBSTANTIATION The proposal w i l l have a very high cost impact on the health care system averaging, in our case, $I,000 per detector with continued high m a i n t e n a n c e costs.

The incidents of False alarms w i l l increase wlth a corresponding drop in s ta f f response, reduced con f idence in the t o t a l F i re a la rm system, and a very nega t i ve impact on the h o s p l t a l s r e l a t l o n s h i p w i t h the l oca l f i r e depar tment . This w i l l have a more pronounced nega t i ve e f f e c t i f the l o c a l F i r e depar tment i s manned p a r t i a l l y or t o t a l l y by v o l u n t e e r s .

As repo r ted in the NFPA's F i re J o u r n a l , most h o s p i t a l f i res recently have been due to a combination of smoking and oxygen produc ing a F i r e and /o r e x p l o s i o n . The proposed change would not he lp in these cases. The goal o f the proposal can be met by s t r i c t en forcement o f a h o s p i t a l ' s smoking p o l i c y and proper a d m i n i s t r a t i o n o f oxygen. Th is proposal w i l l c rea te a sense of security f o r patients, v is i to rs , and s ta f f that is not based on real l i f e occurrences and opens the door For major abuse of the smoking policy and lax oxygen administration. COMMITTEE ACTION: Accept in Principle.

See Action on Comment I01-253 on i2-3.¢.5.3 (Log #309). COMMITTEE COMMEN!: The action taken on Comment lOl 253 (Log #309) should sat isfy the intent of the Submitter.

(Log #269) 101 - 255 - (12-3.4.5.3): Accept in Principle SUBMITTER: Major Mike Daniel, US Army COMMENT ON PROPOSAL NO.: I01-455 RECOMMENDATION: Reject Proposal lOI-4S5, p. 347, TCR.

311

SUBSTANTIATION: What is essent ia l l y being proposed here is a presignal system - - a system which has been and should continue to be prohibi ted in Health Care Occupancies. Not only that, but the proposal also requires a visual display on the cor r idor side of each pat ient room, not to be confused with the nurse ca l l display provided in the same locat ion, and an audible and visual alarm at the nurses s ta t ion , not to be confused with the other ca l l s , alarms, and codes - - to include l i f e and death medical emergencies -- also coming in to the nurses s ta t ion. Are you kidding me? We have been extremely e f f ec t i ve in preventing mul t ip le Fa ta l i t i e s in hospitals u t i l i z i n g the compartmentation concept combined with the current detection and alarm requirements. The substant iat ion admittedly addresses the single Fata l i t y , but th is system has a serlous potent ia l f o r backf i r ing in a real l i f e scenario.

This added confusion, coupled with the imminent loss of valuable time in n o t i f i c a t i o n of the Fire Department a s s o c i a t e d w i t h such a sys tem, c o u l d v e r y e a s i l y r e s u l t i n m u l t i p l e f a t a l i t i e s . And what abou t c o m b i n i n g i t w i t h t he nu rse c a l l system? T h i s wou ld r e s u l t i n even more c o n f u s i o n than p r o v i d i n g a s e p a r a t e sys tem - - no t t o m e n t i o n the added expense to the c o s t o f t he nu rse c a l l System (deJa vu and " h o s p i t a l g r a d e " r e c e p t a c l e s , t o o ! ) Where i s the j u s t i f i c a t i o n ? There i s none! In F a c t , t he system c o u l d a c t u a l l y do more harm than good. Once an a la rm sounds and i s i d e n t i f i e d as a p r o b l e m i n a s p e c i f i c room, the n a t u r a l r e a c t i o n w i l l be t o go d i r e c t l y to the room to ~ n v e s t i g a t e .

L e t ' s say a F i r e s c e n a r i o i s d ~ s c o v e r e d . Then the d i l emma h i t s . Do I sound t he F i r e a l a r m o r do I a t t e m p t t o rescue my p a t i e n t ? We a l l know t h e answer t o t h a t - t he nurse w i l l no t l e a v e t h a t p a t i e n t . L e t ' s say t h a t the p a t i e n t i s s u c c e s s f u l l y removed From the room a f t e r s e v e r a l a t t e m p t s . By t h i s t i m e , the f i r e is too hot to close the door but never fear, the Fire Department w i l l come to the rescue - or w i l l they? The alarm was never sounded. There is now not enough time to evacuate the remainlng patients on the ward . The ne t r e s u l t : m u l t i p l e F a t a l i t i e s , Then why no t t i e t he d e t e c t o r i n t o t he F i r e a l a r m sys tem to a v o i d t h i s de lay? Sure , t he F i r e Depa r tmen t d o e s n ' t mind r e s p o n d i n g to numerous Fa lse a l a rms d a i l y . F i n a l l y , you w i l l j u s t s t a r t r e c e i v i n g a b i l l For e v e r y False alarm v i s i t , and, out of human nature, the response time w i l l get slower and slower due to a perceived false threat - kind of l i k e crylng "wo l f . " And For those of you who think that the automatic door c l o s e r i s t he answer , beware! Not everyone knows to check a c l o s e d door For hea t t r a n s f e r b e f o r e open ing i t in a suspected f i r e scenario. I t could easi ly be opened to a flashover s i tua t ion in addi t ion to increasing response t i m e .

Also consider t ry ing to remove a pat ient From a Fire and smoke f i l l e d room with a closed door opening into the room behind you. Most of us would have a hard enough time w~th the door open. And F ina l ly , put yoursel f in the posi t ion of the pat ient . You are in bed, and a Fire s tar ts . The f i r e and smoke are bu i ld ing, but you know that help w i l l come through that open door at any minute u n t i l you see that door s ta r t to close by i t s e l f , slowly cut t ing o f f your contact with the outside and your hope For rescue.

Let 's ta lk dol lars fo r a moment. There are those of us who can p r o f i t f i n a n c i a l l y f r o m spec i f l c code changes, and there are those of us who would earnestly l i k e to have the safest F a c i l i t y possible For the protect ion of patients and property but happen to be in a pos i t ion where the cost impact is not d i r e c t l y v i s i b l e . Then there are those of us who s i t in the middle forced to deal with the cost -benef i t side of protect ion provided/needed/Justi f ied versus real do l la rs expended - - in other words, those of us who have to deal with the real world. For as long as I can remember, one of the biggest economic problems facing our nation has been and continues to be the r i s ing cost of health care.

What does that have to do with us? This proposed code change, and any change that we make For that matter, has the potent ial to impact s i g n i f i c a n t l y on the finances of the health care industry. This is not only t rue fo r new construct ion, but, based on the provisions of paragraph l-4.G of the Code, the requirement would also ex is t fo r ex is t ing hospitals

undergoing renovation/modernization projects. This added cost could tend to discourage or even prohibit modernization or renovation thereby being in total conflict with the intent of the Life Safety Code. And For those of you who do not see the dollars expended directly, I can guarantee you that you will see them i nd i r ec t l y For the cost of health care that you must pay in the Future. The hospitals have no a l te rna t i ve but to pass these costs on to the consumer. The next time you complain about a b i l l that you receive fo r health care, stop and ask yoursel f i f you helped c o n t r i b u t e t o t h a t c o s t . Then ask y o u r s e l f i f i t was r e a l l y j u s t i f i e d .

The bo t t om l i n e i s t h a t t h e r e comes a t i m e when we must s t o p . We must , t h e r e f o r e , examine e v e r y change we make very c a r e f u l l y From a c o s t benefit s t a n d p o i n t . In other words, any changes we make must be totally justified and substantiated. This one is not! The track record of the hospital industry speaks For itself. Past experience indicates that the problem of m u l t i p l e F a t a l i t i e s From F i r e in h o s p i t a l s has e s s e n t i a l l y been a l l e v i a t e d w i t h c u r r e n t r e q u i r e m e n t s . As f o r t he s i n g l e F a t a l i t y , I wou ld l i k e to be a b l e t o say t h a t I have d e v i s e d a system to p r e v e n t any and a l l l o s s o f l i f e due to F i r e bu t I c a n ' t . I t i s a w o n d e r f u l g o a l , bu t u n f o r t u n a t e l y i t i s u n a t t a i n a b l e . We must , t hen , seek to m i n i m i z e t hese i n c i d e n t s . I wou ld l i k e to s t r e s s t o you a t t h i s p o i n t t h a t t he key to minimizing the single Fata l i t y episode is not n e c e s s a r i l y an a u t o m a t i c smoke d e t e c t i o n sys tem, a u t o m a t i c s p r i n k l e r s , a u t o m a t i c door c l o s e r s , o r o t h e r such b u i l d i n g F e a t u r e s . The key t o m i n i m i z i n g t he s i n g l e F a t a l i t y l i e s i n s t a f f t r a i n i n g . You can have e v e r y p r o t e c t i o n F e a t u r e a v a i l a b l e on t he marke t t o d a y ins ta l led in your f a c i l i t y , and you are s t i l l golng to have Fa ta l i t i es i f the s t a f f is not properly t rained to respond during f i r e . As f o r early detect ion, I would jus t l i k e to remind you that every s t a f f member is equipped with one of the best smoke detectors in the world -- the nose. And i t jus t happens to be one that doesn't have a proven track record of cost ly and e x t r e m e l y a g g r a v a t i n g f a l s e a l a r m s . We must , t h e n , come to a p o i n t where we Stop t r y i n g t o d e s i g n bui ldings to compensate For s t a f f inadequacies. Where do we stop? We cannot af ford to i n s t a l l every system avai lable in our f a c i l i t l e s . Even i f we could, someone would s t i l l propose a backup, and then a backup to the backup -- i t goes on and on. Enough is enough! There is no j u s t i f i c a t i o n For th is change!

AS a f i na l note, I have also heard the excuse used that we must do th is to come into sync with the Model Bui lding Codes. But, where did th is one come from? Anyway, my response to t h a t 1s t h a t we a re a consensus o r g a n i z a t i o n w r i t i n g consensus codes and s t a n d a r d s . The v a r i e t y o f i n p u t and e x p e r i e n c e go ing i n t o t he codes and s t a n d a r d s deve loped and adop ted by t he NFPA is u n s u r p a s s e d . Perhaps the BCMC s h o u l d c o n s i d e r b r i n g i n g t he Model Codes i n l i n e w i t h NFPA codes and s t a n d a r d s i n s t e a d o f t r y i n g to Force Feed us t he r e q u i r e m e n t s o f t he Model Codes. Wi th t h a t , I s t r o n g l y u rge you to r e j e c t t he s u b m i t t e d p r o p o s a l 101-455 t h e r e b y d e l e t i n g t he p roposed new r e q u i r e m e n t For smoke d e t e c t o r s i n a l l P a t i e n t s l e e p i n g rooms. COMMITTEE ACTION: Accep t i n P r i n c i p l e .

See A c t i o n on Comment 101-253 on 12 3 . 4 . 5 . 3 (Log # 3 0 9 ) , COMMITTEE COMMENT: The a c t i o n t aken on Comment 101-253 (Log #309) s h o u l d s a t i s f y the i n t e n t o f t he 5 u b m i t t e r .

(Log #492) 101 - 256 - (12-3.4.5.3) : Accept in Pr inc ip le SUBMITTER: Walter A. Col l ins, US Public Health Service COMMENT ON PROPOSAL NO.: I0l=455 RECOMMENDATION: Delete new paragraph 12 3.4.5.3. SUBSTANTIATION: This proposal requires smoke detectors in each pat ient sleeping room, visual display on the cor r idor side and audible and visual signals at the nurse's s ta t ion. I t also allows th is system to be combined with the nurse ca l l system, does not require i t to signal the Fire service and may be used to close the pat ient room door. The results of f u l l scale Fire tests and s t a t i s t i c s strongly indicates that smoke detectors alone are not completely e f f ec t i ve in

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preventing f i r e deaths which occur in health care occupancies. Generally, deaths occur because of intimate contact with f i r e on bedding or clothing. Consequently, deaths usually result no matter what detection system is present. q0MMITTEE ACTION: Accept in Principle.

See Action on Comment I01-253 on 12-3.4.5.3 (Log #309). q0MMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should sat isfy the intent of the Submitter.

(Log #369) 101 - 257 - (12-3.4.S.3): Accept in Principle ~BMITTER: Richard G. Roskos, Greene Memorial Hospital, Inc. COMMENT ON PROPOSA~ N0~: 101-455 RECOMMENDATION: Please do not implement the proposed changes. SUBSTANTIATION: I t is our understanding that proposed changes to the Life Safety Code (NFPA I01) would require the use of smoke detectors in patient rooms. We feel the proposed changes would not improve patient care and would only increase hospital and community cost, Hospital cost would include the i n i t i a l equipment cost as well as the continuing maintenance cost and the cost associated with the additional false alarms. The tax payers are also affected by the False alarms every time the local Fire department responds to the alarm.

We Feel that hospitals are adequately protected by the existing f i r e safety Systems and more in this case is not better. COMMITTEE ACTION: Accept in Principle.

See Action on Comment I01-253 on 12-3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should satisfy the intent of the Submitter.

(Log #370) 101 - 258 - (12-3.4.5.3): Accept in Principle SUBMITTER: Robert L. Guthrie, FrankFord Hospital, PA q0MMENT ON PROPOSAL NO.: I01-45S RECOMMENDATION: I am writ ing in order to express my concern regarding a proposed change to the Life Safety Code (NFPA I01) that would mandate the use of smoke detectors in a l l hospital patient rooms. As outlined, this proposal would s imi lar ly require that a l l smoke detectors be tied into the Master Fire Alarm System or a pre-signal f i r e alarm system.

I strongly recommend against the implementation of the proposed changes to the existing Life Safety Code (NFPA 101). SUBSTANTIATION: The implementation of such a change would entail considerable hardship and expense for individual health care inst i tut ions while imposing no additional safety For their inhabitants, A recently commissioned study by the American Hospital Association demonstrates through NFPA records that typical hospital f i res are not of the nature or type that are most successfully controlled by smoke detectors. Additionally, a major concern exists regarding the increased potential for False alarms. Unwanted or False alarms contribute to apathetic attitudes on the part of hospital s ta f f , the public, and the local f i r e services in responding to Fire alarms. The implementation of this proposal would dramatically expand the number of false alarms, accelerate this apathy and escalate the Potential for injury and loss of l i f e in the event of an actual Fire. And f i n a l l y , the excessive, yet unjustif ied cost of implementing the systems proposed by this NFPA change must be considered. Costs beyond the i n i t i a l ins ta l la t ion would s imi lar ly be entailed for ongoing maintenance and inspection services. Thank you for your attention to this matter, and for the opportunity to comment on this important issue. COMMITTEE_ACTION: Accept in Principle

See Action on Comment I01-253 on 12-3.4.5.3 (Log #309). C~ITTEE COMMENT: The a c t i o n taken on Comment 101-253 (Log #309) should satisfy the intent of the Submitter.

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(Log #300) 10l - 259 - (12-3.4.5.3): Accept in Principle SUBMITTER: Marvin J. Fischer, Brooklyn, NY COMMENT ON PROPOSAL NQ~: I01-455 RECOMMENDATION: This proposal should be rejected. SUBSTANTIATION: I. Original ly when sprinklers were proposed we argued that they were unnecessary. In Fact, i f we were interested in patient safety and property damage reduction, smoke detectors might be used since a l l hospitals are required to have a trained f i r e response team and smoke detectors w i l l alarm before sprlnklers. This was rejected by the Committee stating inadequacies with smoke detectors. Now that sprinklers are requlred, the smoke detector appears to have suddently come into i ts own. Having both sprinkler and smoke detectors seems to be the belt and suspenders approach. Both should not be required. Many jur isdict ions s t i l l require the compartmentalization approach to construction. Tc have this, sprinklers and smoke detectors is an e~cesslve set of requirements.

2. Statistics collected by the American Hospital Association indicate that the number of deaths that could have been prevented with the use of smoke detectors in patient rooms was very small, either by bed count or patient day count. (Miniscule over a Five year period.)

3. The substantiation that is belng used, "to conform to the model building codes," is an improper one. The proposal should stand on its own merit.

4. This proposal should be rejected and Further" studied while a more uniform approach is taken v is .a.v is , compartmentalization, sprlnklers and smoke detector. Provisions must be made to take into account other local laws. COMMITTEE ACTION: Accept in Principle.

See Action on Con~ent I01-253 on 12-3.4.S.3 (Log #309). COMMITTEE COMHENT: The action taken on Comment I01-253 (Log #309) should sat isfy the intent of the Submitter.

(Log #286) 10l - 260 - (12=3.¢.5.3): Accept in Principle SUBMITTER: Ray Taylor, ARA Living Centers, Inc. COMMENT ON PROPOSAL NO.: I01-455 RECOMMENDATION: Reject Proposal I01-455. SUBSTANTIATION: I am recommending that the proposal be rejected. There appears to be only two substantiations supporting the proposal. The reasons cited in Edwlna J u i l l e t ' s substantiation is an enforcement problem and can be dealt with on a f a c i l l t y level. The BCMC substantiating statement simply states that the Single patient f i r e death In a health care Fac i l i t y occurs in the patient room. Where is documentation provided that the death would have been prevented with patient room detectors? How many single death Fac i l i t ies referenced by BCMC are a result of a patient intlmate wlth ignit ion and could not have been saved with room '~moke detectors? Until such documentation can be provided, the Committee should accept the Subcommittee's recommendation and reject this costly and unjusti f ied proposal. COMMITTEE ACTION: Accept in Principle.

See Action on Comment 101-253 on 12-3.4,5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should sat is fy the intent of the Submitter.

(Log #212) 101 - 261 - (12-3.4.5.3): Accept in Principle SUBMITTER: Don Idzik, Grancare Nursing Center COMMENT ON PROPOSAL NO.: lOl-455 RECOMMENDATION: Reject proposal. SUBSTANTIATION: According to the Board for the Coordination of Model Building Codes, they j u s t i f y the patient room detectors because the vast majority of fatal f i res in health care f a c i l i t i e s occur in the patient rooms. How many Fatal f i res do we have in nursing homes? Does this number warrant patient room detectors? Because of false alarms and the cost associated with insta l la t ion and maintenance of smoke detectors, I feel that, i f this proposal is accepted, i t w i l l create more problems throughout the health care industry than solve.

qOMMITTEE ATTIC: Accept in Principle. See Action on Comment 101-253 on 12-3.4.5.3 (Log

#309). ~MITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should sat isfy the intent of the Submitter.

(Log #211) lot - 262 - (12-3.4.5.3): Accept in Principle SUBMITTER: Jerry Tretwold, Harmony House COMMENT ON PROPOSAL NO:: 101-455 RECOMMENDATION: Reject proposal (paragraph 12-3.4.5.3 (New)). SUBSTANTIATION: I recommend the Technical Committee on Safety to Life reject the proposal to ins ta l l patient room detectors for the Following reasons:

I. The BCMC substantiation does not document that patient room detectors is the solution.

2. Edwina J u i l l e t ' s substantiation is beyond the purpose of the Life Safety Code i f the jus t i f i ca t ion is to prevent property damage and injury.

3. False and nuisance smoke detector alarms are going to increase which may result in disconnecting Of the detectors. COMMITTEE ACTION: Accept in Principle.

See Action on Comment 101-253 on 12 3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should sat isfy the intent of the Submitter.

(Log #201) lot - 263 - (12-3.4.5.3): Accept in Principle SUBMITTER: Del Callaway, FoIsom Convalescent Hospital COMMENT ON PROPOSAL NO.: 101-455 RECOMMENDATION: Reject Proposal lOt 455. SUBSTANTIATIOn: The proposal is too vague as to i ts intent and appears to need additional study. The Subcommittee of Building Service and Fire Protection Equipment in their Proposal I01-449 indicates that they have coordinated this proposal without confl ict ing with Section 7-6. I t appears that these detectors are intended to be single station detectors which w i l l , in addition to the requirements contained in the proposal, require an additional audible device in the room in accordance with 7-6.2.7. What effect will this audible device have on elderly patients in nursing homes? The type of audible device at the nurses call station iS not specified as well as the light at the nurses call station and outside the room. Can these visual lights and audible devices be common with other nurses call functions? This proposal iS too vague and will probably be misinterpreted and should be rejected. ~TTEE ACTION: Accept in Principle.

See Action on Comment I01-253 on 12-3.4.5.3 (Log #3Of). COMMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should sat isfy the intent of the Submitter.

(Log #501) I01 - 264 - (12-3.4.5.3): Accept in Principle SUBMITTER: Mike Thompson, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-455 RECOMMENDATION: Reject Proposal I01-455. SVBSTANTIATION: The requirement For patient room smoke detectors is simply not jus t i f ied by Edwina J u i l l e t ' s or BCMC's substantiation. Edwina J u i l l e t ' s substantiation is based on a lack of responsible enforcement or management in some health care f a c i l i t i e s and should not be adopted to penalize f a c i l i t i e s with working no smoking policies in patient rooms. AS for the BCMC substantiation, as pointed out by several Technical Committee members, there appears to be a fundamental change in the Chapter l philosophy. The change is philosophy should not be solely considered in Chapter 12. The proposed section as written leaves many unanswered questions and causes much confusion in practice. When the detectors are tied into the nurses call station, must the audible signal be dist inct ive from a normal nurses call signal? What is meant by "visual alarm"? A

dist inct ive l ight For the smoke detectors, a room number or both? I f a UL 217 detector is used, do we want one with a bu i l t - i n alarm? What effect does the detector with the bu i l t - i n alarm have on the patient who cannot get out of bed when i t operated needlessly?

The AHCA recently conducted a survey of i ts member nursing homes. The survey results indicate that f a c i l i t i e s with patient room detectors experience approximately 4 times as many needless smoke detector alarms (average of 35 needless alarms per Fac i l i ty per year) then do Fac i l i t ies without patient room detectors. I t is evident from the survey that patient rooms are conducive to False (needless) alarms because of their size and environment. Reported causes of the needless alarms included such causes as hairsPray, hair dryers, vaporizers, and open windows. False alarms of this type and magnitude are only going to result in misuse and ignorance of the system.

Presumably, the reason For permitting the detectors to be tied into the nurses cal l system is to reduce the potential for False alarms thru the Fac i l i ty Fire alarm system and automatic not i f icat ion of the Fire department. This may not be the case. Nursing home management have indicated to me that they w i l l be instructing their s ta f f to i n i t i a te the Fac i l i ty Fire alarm when receiving a patient room detector simply because i t is important that the entire s ta f f be notif ied when there is a Fire and secondly, they do not want their s ta f f making decisions to evacuate patient(s) or abandon the patient(s) to go and i n i t i a t e the Fac i l i ty Fire alarm i f a room Fire is discovered. ~OMMITTEE ACTION: Accept in Principle.

See Action on Comment I01-253 on 12-3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment I01-253 (Log #309) should sat is fy the intent of the Submitter.

(Log #441) lOl - 265 - (12-3.4.5.3): Accept in Principle ~UBMITTER: James E. D~kes, Fort Worth, TX COMMENT ON PROPOSAL NO.: I01-455 RECOMMENDATION: Delete the requirement to require smoke detectors in patient sleeping rooms. This new section is not required. SUBSTANTIATION: I f u l l y concur that smoking is a problem in our modern society. But, why should we place additional burdens on the Health Care Industry for the cost associated with Nurse Call Systems and the d e t e c t o r s t h e m s e l v e s . The answer i s s t r i c t e n f o r c e m e n t o f smoking p o l i c i e s i n the f a c i l i t i e s , no t i n e x p e n s i v e equ ipmen t i n an a rea t h a t i s s u p e r v i s e d 24 h o u r s / d a y , I f u l l / b e l i e v e t h a t once a d e t e c t o r i s a c t i v a t e d , t he n u r s i n g s t a f f w i l l be more conce rned w i t h r emov ing t he p a t i e n t t h a n a c t i v a t i n g the f i r e a l a r m . I do no t concu r w i t h a p r e - s i g n a l d e v i c e ~n t he H e a l t h Care I n d u s t r y . COMMIT_TEE ACTION: Accep t i n P r i n c i p l e .

See A c t i o n on Comment I 0 1 - 2 5 3 on 1 2 - 3 . 4 . 5 . 3 (Log #309). ~OMMITTEEE COMMENT: The action taken on Comment I01-253 (Log #309) should sat is fy the intent of the Submitter.

(Log #371) I01 - 266 - ( 1 2 - 3 . 4 . 5 . 3 ) : Accep t i n P r i n c i p l e SUBMITTER: John S u l l i v a n , Communi ty H o s p i t a l ~OMMENT ON PROPOSAL NO~: 101-455 RECOMMENDATION: I earnestly request that you withdraw your proposed revision. SUBSTANTIATION: I am writ ing in opposition to the current NFPA proposal to revise the Life Safety Code to require the use of smoke detectors in hospital patient rooms.

First and foremost, I do not believe that any benefit to human l i f e would result From the passage of this requirement. Secondly, at a time when hospitals are part icular ly hard pressed from a standpoint of reimbursement, the insta l la t ion, maintenance, and inspection costs associated with the additional smoke detectors is ent i re ly prohibit ive. Additionally, while we even now e n c o u n t e r " w o l f , w o l f " a t t i t u d e s From o u r s t a f f and l o c a l f i r e d e p a r t m e n t r e l a t i v e t o f a l s e a l a r m s , t h i s p r o b l e m wou ld be g r e a t l y m u l t i p l i e d w i t h t he p resence o f smoke d e t e c t o r s i n each room.

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COMMITTEE ACTION: Accept in Principle. See Action on Comment I01-253 on 12-3.4.5.3 (Log

#309). COMMITTEE COMMENT: The a c t i o n taken on Comment 101-253 (Log #309) should sat is fy the intent oF the Submitter.

COMMITTEE ACTION: Accept in Principle. See Action on Comment I01-253 on 12-3.4.5.3 (Log

#309). COMMITTEE COMMENT: The action taken on Comment I01-253 (Log #309) should sat is fy the intent of the Submitter.

(Log #379) 101 - 267 - (12-3.4.5.3): Accept in Principle SUBMITTER: H.E. Nelson, NBS COMMENT ON PROPOSAL NO.: 101-455 RECOMMENDATION: Delete. SUBSTANTIATION: I. This proposal assumes that early detection in sleeping rooms w i l l provide lead time suf f ic ient to safeguard individuals in that room. Since most deaths of patients in the room of the f i r e origin occur From Fires intimate to the victim, the key assumption is not necessarily true.

2. Even i f the assumption were valid, this action would constitute a major change in the Code objective, see my negative comment on the Committee bal lot. COMMITTEE ACTION: Accept in Principle.

See Action on Comment 101-253 on 12-3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment I01-253 (Log #309) should sat is fy the intent of the Submitter.

(Log #419) 10l -- 268 - (12-3.4.5.3): Accept in Principle SUBMITTER: Edward M. Shedlock, Gainesville, FL COMMENT ON PROPOSAL NO.: 101-455 RECOMMENDATION: Delete this paragraph. SUBSTANTIATION: Proposal I01-455 (and I01-450) require, in new construction, that smoke detectors be installed in a l l patient sleeping rooms. I disagree with the adoption of thls proposal for the Following reasons:

a. I believe that most Fires in patient sleeping rooms are started because of improper handling of smoking materials. The vast majority of medical centers s t r i c t l y enforce their smoking policy and have no problem with Fires in patient sleeping rooms. To require a l l new construction to instal l these detectors is not j us t i f i ed by the record.

b. Too many questions remain unanswered. Would quick response sprinkler heads be an acceptable alternative (to smoke detectors)? This issue is addressed in the proposed Chapter 21. Every other Fire or smoke detecting device in a hospital must be tied into the Fire alarm system. Why not the patient sleeping room smoke detectors? Unreliable? With the patient room doors open, how much time is gained with smoke detectors in the sleeping rooms, especially i f detectors are installed in the corridors? Will this requirement apply to c r i t i ca l care areas (MICU, CCU, etc,)? Patients do sleep there but i t seems rather ridiculous to require detectors when s ta f f is in the room at a l l times (and smoking is rarely a problem here).

c. The cost of instal l ing the detectors, while considerable, is not the signif icant issue. The maintenance and testing of the detector system w i l l cost a medical center much more in the long term. We should realize that cost is an issue; otherwise, why not require the detectors for existing construction?

d. The Subcommittee on Health Care Occupancies rejected these proposals. For the main Committee to overrule the Subcommittee, there should be extraordinary jus t i f i ca t ion . That jus t i f i ca t ion has not been provided. The Subcommittee has looked at this issue for years. For the main Committee to overrule seems to be arbi trary.

e. Final ly, and most importantly, these proposals do not address the cause of f i res in patient sleeping rooms; that is, misuse of smoking materials. Instal l ing smoke detectors is not going to reduce the number of Fires. What may be needed is education regarding the improper handling of smoking materials to include enforcement of smoking policies and training of s ta f f .

(Log #43) I01 - 269 - (12-3.4.5.3): Accept in Principle SUBMITTER: Autumn H. Blakeley, Milwaukee, WI COMMENT ON_PROPOSAL NO.: 101-455 RECOMMENDATION: Delete the entire paragraph as follows:

"Add a new 12-3.4.5.4 to read: 12-3.4.5.3 Patient Sleeping Rooms. Patient sleeping

rooms shall be provided with a smoke detector complying with the requirements of UL 217 or UL 268 permanently connected to house current. Such detectors shall provide a visual display on the corridor side of each patient room and shall provide an audible and visual alarm at the nursing station attending that room. Such detector and related devices may be combined with the nursing call system and the total system need not be e lec t r ica l ly supervised. The room detector may be used to close the door in accordance with 12 3.6.3.3.

Exception: In rooms equipped with automatic door closing devices with integral smoke detectors on the room side, the integral detector may substitute, in accordance with i ts l is t ing, For the required smoke detector provided i t performs the required alert ing Functions." SUBSTANTIATION: This provision overrules the Subcommittee on Health Care Occupancies which decided the aggravation of False alarms could adversely effect s ta f f reaction to a real situation. COMMITTEE ACTION: Accept in Principle.

See Action on Comment 101-253 on 12-3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101 253 (Log #309) should sat isfy the intent of the Submitter.

(Log #51) I01 - 270 - (12-3.4.5.3): Accept in Principle $VBMITTER: Joseph Gasbarre, Elk County General Hospital COMMENT ON PROPOSAL NO.: I01-45S RECOMMENDATION: This le t te r is a response to your proposal to change the Life Safety Code (NFPA 101) to mandate the use of smoke detectors in patient rooms.

Hospitals today are under increasing pressure to hold or reduce costs in order to survive under Medicare reimbursement guidelines. Small hospitals such as ours, have had to make some drastic decisions ~n order to accomplish this task. Your proposal w i l l put a tremendous cost burden on our ins t i tu t ion in order to comply with this requirement. I cannot begln to estimate what the cost would be to ins ta l l , maintain, and inspect the additional smoke detectors which we would require at Elk County General.

Even more important is the potential For an increase in False alarm situations at our hospital. Being a small rural hospital, we are dependant on a borough volunteer f i r e department. In the past we have had numerous false alarms which could have strained the relationship between the hospital and Fire department. Having to take these volunteer individuals away From jobs or family gatherings to respond to a false alarm is not conducive to a good working relationship. By adding smoke detectors to patient rooms, we increase the potential for False alarms, and at the same time, do not create a s ign i f icant ly safer environment For the patient.

In recent days, ar t ic les have come to my attention that some Fire departments are considering fines or penalties for those businesses and inst i tut ions who consistently issue false alarms to the local f i r e departments because of malfunctions, carelessness or smoking in restricted areas. You must consider this situation when deciding on your proposal. SUBSTANTIATION: I would ask the Committee to consider a l l of the above situations before rendering a decision, But I think the most important Factor would be that even with the insta l la t ion we would not create a safer environment but may create the complete opposite, That is, placing the patient at r isk by instal l ing a more sophisticated system which w i l l result in numerous False alarms and higher potential for inquiry. Thank you for your consideration.

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COMMITTEE ACTION: Accept in Principle. See Action on Comment 101-253 on 12-3.4.5.3 (Log

#309). ~ T T E E COMMENT: The action taken on Comment 101-2S3 (Log #309) should sat isfy the intent of the Submitter.

(Log #13) I01 - 271 - (12-3.4.5.3): Accept in Principle SUBMITTER: J. Richard Fruth, Hayes, Large, Suckling, Fruth & Wedge Architects COMMENT 0N PROPOSAL NO=: I01-455 RECOMMENDATION: Delete proposed paragraph 12-3.4.5.3", SUBSTANTIATION: The requirement For smoke detectors in patient rooms seems to raise the objective of the Code to provide protection against single loss of l i f e in a Fire si tuation. The cost of this change w i l l be very high, and the a b i l i t y of this change to e f fec t ive ly increase the safety of the building is questionable. Our First concern is the number of False alarms which can be expected From such a system. In h o s p i t a l s we have experienced False alarms From casual smoking, rubbing alcohol and construction d i r t in corr idor- insta l led detection systems. We expect a vast increase of False alarms with systems instal led in patient rooms. The False alarm w i l l become a nuisance for the s ta f f which we expect w i l l result in distrust of the Fire alarm system and a tendency to ignore those alarms which emanate From the nursing unit. In addition, i f the alarm is sounded in the room, the activation of False alarms w i l l raise the anxiety of the patient, which w i l l be detrimental to the patients' well being.

AS to costs, there are two items to be considered. The i n i t i a l cost of construction w i l l be higher with the installat~on of such a system, par t icu lar ly when the system needs to be integrated with a nurse call system. Even greater, however, w i l l be the COSt to maintain such a system requiring inspection and cleaning of detection devices in each patient room. I t is our eyperience that nurse cal l Systems of the sophistication requlred to acconv.~odate a Fire alarm signal are extremely d i f f i c u l t to debug and make Fully operational. This experience supports our bel ie f that both First and operating costs w i l l be higher. COMMITTEE ACTION: Accept in Prlnciple.

See Ac t i on on Comment I01-253 on 1 2 - 3 . 4 . 5 . 3 (Log #309). COMMITTEE COMMENT: The a c t i o n taken on Comment 101-253 (Log #309) should s a t i s f y the i n t e n t o f the S u b m i t t e r .

(Log #329) I01 - 272 - C12-3.4.5.3): Accept in Principle SUBMITIER: Richard D. Strub, Hillhaven Corp. COMMENT ON PROPOSAL NO±: 101-q55 RECOMMENDATION: Delete entire section/paragraph. SUBSTANTIATION: Hillhaven operates nursing homes in 42 states, We feel that the proposed requirement is unnecessary and unworkable. The addition of such a volume of addltional smoke detectors would s ign i f i cant ly mult iply the number of false alarms and create continued confusion For s ta f f and residents. Present smoke detector requirements have proven to be more than adequate. COMMITTEE ACTION: Accept in Principle.

See Action on Comment I0]-253 on ]2-3,4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should sat isfy the intent of the Subm~tter.

(Log #502) 101 - 273 - (12-3.4.5.3): Accept in Principle SUBMITTER: Thomas W. Jaeger, Gage-Babcock & Assoc., Inc. COMMENT ON PROPOSAL N0=: I01-455 RECOMMENDATION: Reject this major new requirement. SUBSTANTIATION: As a member of the Health Care Subcommittee, i t should be pointed out that the Subcommittee reviewed this proposed new requirement and unanimously rejected the requirement. As the or iginal Submitter of the "health care package" to BCMC along with representatives of the American Hospital

Association, the patient room smoke detector requirement was not part of the package. The two largest health care trade associations, the American Health Care Association and the American Hospital Association, oppose this requirement and both have c lear ly stated this For the public record. The American Health Care Association recently completed a survey on nursing home smoke detectors with 621 f a c i l i t i e s from 30 states responding to the survey. Although a l l the results from the survey cannot be discussed in this substantiation, the survey clearly showed that we can anticipate approximately 35 False alarms per year per f a c i l i t y (G5 beds) from the room detectors, The survey also showed that the False alarms resulted in disconnection of the Fire department d i r e c t connec t ion , d i sconnec t l on o f the smoke d e t e c t o r s From the b u i l d i n g F i re a larm system and a " c r y - w o l f " syndrome.

The Committee on Sa fe t y to L i f e s t a tes t h a t t h e i r acceptance is based on substantiation provided ~n other p roposa ls . There i s no s u b s t a n t i a t i o n con ta ined in any o f the p roposa ls to document t ha t smoke d e t e c t o r s w i l l reduce p a t i e n t losses in hea l t h care F a c i l i t i e s . Proposal 101-449 s ta tes tha t p a t i e n t smoke de tec to r s should be required in the name of uniformity. Uniformity is not technical substantiation for adoption of this major new requirement and Four wrongs don't make a r ight ! COMMITTEE ACTION: Accept in Principle.

See Action on Comment 101-253 on 12-3.4.5.3 (Log #309). COMMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should satisfy the intent of the Submitter.

(Log #555) lOl - 274 - (12 3 . 4 . 5 . 3 ) : Accept in P r i n c i p l e SUBMITTER: Ro l l Oensen, P.E. , James A n t e l l , A . I . A . , RolF Jensen& Assoc ia tes , Inc. COMMENT ON PROPOSAL NO.: I01-455 RECOMMENDATION: Rejec t Proposal I01-455. SUBSTANTIATION: Proposal I01-455 r e q u i r e s smoke d e t e c t i o n in p a t i e n t s leep ing rooms. The proposed change r e q u i r e s the d e t e c t o r to p rov ide a v~sual d i s p l a y in the c o r r i d o r and an aud ib l e and v i s u a l a larm at the nurs ing s t a t i o n . Th is requ i rement would app ly in both s p r i n k l e r e d and n o n s p r i n k l e r e d b u i l d i n g s . I b e l i e v e t h i s requ i rement is o v e r l y r e s t r i c t i v e . No s u b s t a n t i a t i n g data was submi t ted i n d i c a t i n g the need For smoke d e t e c t o r s in p a t i e n t s leep ing rooms. Even ~f smoke d e t e c t o r s were proven necessary, the p r o v i s l o n s o f t h i s proposed sec t i on would extend the requ i rements to a v i s u a l d i s p l a y in the c o r r i d o r and a connec t ion to the nurses s t a t i o n , This adds s i g n i f i c a n t l y to the cos t and the c o m p l e x i t y o f the i n s t a l l a t i o n , and has not been analyzed to determine the b e n e f i t .

The r a m i f i c a t i o n s o f p r o v i d i n g smoke d e t e c t i o n have not ye t been f u l l y i n v e s t i g a t e d . Is the Committee propos ing t h a t the d e t e c t o r sound in the room, or on ly a t the nurses s t a t i o n ? I f i t i s to sound on l y at the nurses s t a t i o n , a system-operated d e t e c t o r connected to a superv i sed l i s t e d d e t e c t i o n system w i l l be r e q u i r e d . Th is adds s i g n i f i c a n t l y to the cos t . I f i t is to sound in the room, i t w i l l a l e r t a p a t i e n t who may be unable to move. Unwanted alarms sounding in p a t i e n t rooms may a f f e c t the hea l t h o f c r i t i c a l l y i l l p a t i e n t s .

Is the connec t ion to nurses c a l l s t a t i o n r e q u i r e d to cause a d is t inc t signal, or may i t be combined with the other nurses calls? A separate signal w i l l add s ign i f i can t ly to the cost, wh~le a combined signal may only cause confusion. The intent of the language in the proposal is unclear.

IF the detector is required to be t ied- in to the nurses station, must i t also a ler t the f l r e department? Many jur isd ic t ions w i l l interpret the w i r i n g as a "system" and t h e r e f o r e r e q u i r e m o n i t o r i n g by a c e n t r a l s t a t i o n or o the r permanent ly a t tended location. Again, this may require the system to be l is ted, and s ign i f i cant ly increase the cost.

The Subcommittee on Health Care Occupancies has debated the issue of smoke detectors in patient rooms For years. Their work has generally been regarded as result ing in well-documented and rational f i r e protection. They have been consistent in recognizing hazards and dealing with them. Why has the Committee chosen to overrule them in this instance?

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COMMITTEE ACTION: Accept in Principle. See Action on Comment I01-253 on 12 3.4.5.3 (Log

#309). COMMITTEE COMMENT: The action taken on Comment 101-253 (Log #309) should sat isfy the intent of the Submitter.

(Log #32) 101 - 275 - (12-3.4.5.3): Reject SUBMITTER: Joseph A. Drouin, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO.: 101-455 RECOMMENDATION: Revise f i r s t sentence to read as fol lows:

12-3.4.5.3 Patient sleeping rooms shall be provided with a smoke detector complying with the requirements of UL 217 permanently connected to house current or UL 268 e lec t r i ca l l y interconnected to a Fire alarm system. SUBSTANTIATION: C lar i f i ca t ion , UL 268 detectors are sys tem t ype d e t e c t o r s t h a t a re r e q u i r e d to be connec ted to a f i r e alarm control panel. They are not connected to house current.

This revision was adopted by the Standard Building Code. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action on Comment I01-253 on 12-3.4.5.3 (Log #309).

(Log #192) I01 - 276 - (12-3.4.5.3): Reject SUBMITTER: Jonas L. Horehart, Natlonal Inst i tutes of Health COMMENT ON PROPOSAL NO.: 101-455 I RECOMMENDATION: Delete the last sentence about using the room smoke detector to close the door. Delete the Exception about integral smoke detectors in door closers. SUBSTANTIATION: Closing of a patient bedroom door by activation of a smoke detector could result in patients being closed in the room with the fire. See the third sentence of the Committee Comment for Proposal lOl 465 which expresses the Committee's feeling about automatic closers. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee has deleted this paragraph. See Comment 101-253 on 12-3.4.5.3 (Log I #309). I

(Log #457) 101 - 277 - (12-3.4.5.3 Exception): Reject SUBMITTER: William E. KofFel, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO_: lOI-4S5 RECOMMENDATION: Add a new Exception and renumber the Exception in the proposal as Exception No. 2. The new Exception shall read as follows:

Exception No. l : Smoke detectors are not required in patient sleeping rooms in which l is ted quick response sprinklers are instal led. SUBSTANTIATION: NFPA f l r e data, Full scale f i r e tests and independent investigations o£ health care f i r e incidents do not support the requirement for smoke detectors in patient sleeping rooms. A study prepared For the American Society for Hospital Engineering, "Estimating the Effectiveness of State-of-the-Art Detectors and Automatic Sprinklers on Li fe Safety in Health Care Occupancies" indicates that current technology may not be able to s ign i f i can t l y reduce the small number of f i r e f a t a l i t i e s which occur i n health care f a c i l i t i e s since most victims are intimate with ign i t ion. The study continues to indicate that i f any device is l i ke ly to impact on the number of f a t a l i t i e s , i t is c lear ly the quick response sprinkler. Therefore, although the smoke detector requirement cannot be substantiated, i f the Committee elects to require smoke detectors at least give the option to use a device which w i l l most l i ke ly provide a greater level of protection. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The proposed paragraph 12-3.4.5.3 has been deleted. See action on Comment I01-253 on 12-3.4.5.3 (Log #309).

(Log #289) 101 - 278 - (12-3.4.5.3 Exception No. 2 (New)): Reject $UBMITTER: E l l i o t t S. Guttman, Catherine McAuley Health Center COMMENT ON PROPOSAL NO.: I01-451, 455 RECOMMENDATION: Add an additional Exception to provisions of 12-3.4.5.3 as Follows:

Exception No, 2: In patient sleeping rooms equipped with quick response sprinklers connected to an approved automatic sprinkler system, the smoke detector may be eliminated. SUBSTANTIATION: While the presence of smoke detectors in patient sleeping rooms w i l l provide for early detection, i t has not proven that i t w i l l substantial ly reduce f i r e f a t a l i t i e s in the room of or ig in. The u t i l i z a t i o n of the quick response sprinkler in l ieu of the smoke detector w i l l not only provide For earl), detection but also prompt containment. By providing the designer and owner the option of using either (or both), the concerns of the Subcommittee on Health Care and the Committee on Safety to Li fe have been addressed without mandatory redundant systems. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This paragraph h a s been recommended for deletion by the Committee. See Comment 101-253 on 12-3.4.5.3 (Log #309).

(Log #14) I01 - 279 - (12-3.4.5.4): Accept SUBMITTER: J. R~chard Fruth, Hayes, Large, Suckling, Fruth & Wedge Architects COMMENT ON PROPOSAL NQ~: 101-456 RECOMMENDATION: Delete proposed paragraph 12-3.4..5.4. SUBSTANTIATION: The need for heat detectors in a space already protected by one-hour construction has not been j us t i f i ed . The purpose of the one hour construction should be to contain a f i r e within the room of or ig in. COMMITTEE ACTION: Accept.

(Log #310) 101 - 280 - (12-3.4.5.4): Accept SUBMITTER: Douglas S. Erickson, American Hospital Assn, COMMENT ON PROPOSAL NO.: lOl 456 RECOMMENDATION: Delete proposed paragraph 12-3.4.5.4 (New). ~UBSTANTIATION: The exist ing LSC Sections 12-3.2.1 and 13-3.2.1 adequately cover the requirements For hazardous areas and have demonstrated the i r effectiveness For more than 10 years. The authors provide no documentation that the exist ing requirements have been inadequate or that undetected f i res have Occur red i n t hese a r e a s . F u r t h e r , t h i s p r o p o s a l c o n f l i c t s w i t h the r e q u i r e m e n t to a u t o m a t i c a l l y n o t i f y b u i l d i n g occupan t s ( i n t h i s case s t a f f ) . F i r s t l y , t h i s p r o p o s a l c o n f l i c t s w i t h Log #334, 101-455 w h i c h has been accep ted i n p r i n c i p l e . S e c o n d l y , where i s t he j u s t i f i c a t i o n , t h a t we a re e x p e r i e n c i n g f i r e s i n t h e s e a reas and t h a t t hese F i r e s a re g o i n g u n d e t e c t e d . ~OMHITTEE ACTION: Accep t .

(Log #270) 101 - 281 - (12-3.4.5.4): Accept SUBMITTER: Major Hike Daniel, US Army COMMENT ON PROPOSAL NO.: 101 456 RECOMMENDATION: Reject Proposal I01-456, p. 347, TCR. SUBSTANTIATION: Here we are again faced with a proposed new requirement. The substantiation given: to a ler t the s ta f f of a f i r e pr ior to the Fire breaching the wall. We already require either one hour protection or sprinklers in hazardous areas. Is th is a problem? I f i t is, I'm not aware of i t . I f i t i s n ' t , then why are we even considering i t . I f the hazardous area is located in an occupied zone of the f a c i l i t y , the s ta f f w i l l obviously be aware of i t before i t breaches the wall - - probably even before the heat detector is activated. Even i f i t happens to be in an unoccupied zone of the f a c i l i t y , we s t i l l design our f a c i l i t i e s so that i t could be detected and extinguished before a l i f e threatening si tuat ion could evolve. That's why we have vert ical Separations, horizontal separations, smoke barriers, corr idor wall

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requirements, etc. What more do you want? Why don't we just go ahead and design our f a c i l i t i e s with total compartmentation, sprinklers throughout, smoke detectors throughout, heat detectors throughout, and then provide backup systems For each just in case one fa i ls? We must f i r s t j us t i f y the need before we implement the requirement. You should also keep in m~nd that you are s ign i f icant ly increasing the cost of modernization/renovation projects with thls change in philosophy regarding hazardous areas (based on the provisions of paragraph I-4.6 of the Code). Unless there is concrete evidence to j u s t i f y and substantiate that there ~s indeed a problem, I strongly urge you to reject Proposal I01-456 thereby deleting the proposed new requirement for heat detectors in nonsprinklered haza rdous a r e a s . COMMITTEE ACTION: Accept.

(Log #302) I01 - 282 - (12-3.4.5.4): Accept SUBMITTER: Marvin J. Fischer, Brooklyn, NY COMMENT ON PROPOSAL NO.: 101-456

i RECOMMENDATION: This proposal should be rejected. SUBSTANTIATION: I. Section 12-3.5 requlres that a l l health care f a c l l i t i e s be f u l l y sprinklered.

2. Origlnal ly when sprinklers were proposed we argued that they were unnecessary. In Fact, i f we were interested in patient safety and property damage reduction, smoke detectors might be used since al l hospitals are required to have a trained Fire response team and smoke detectors w i l l alarm before sprinklers. This was rejected by the Committee stating inadequacies with smoke detectors. Now that sprinklers are required, the smoke detector appears to have suddenly come into i ts own. Having both sprinkler and smoke detectors seems to be the belt and suspenders app roach . Both shou ld no t be r e q u i r e d . Many j u r i s d i c t i o n s s t i l l r e q u i r e the c o m p a r t m e n t a l i z a t i o n app roach t o c o n s t r u c t i o n . To have t h i s , s p r i n k l e r s and smoke d e t e c t o r s i s an e x c e s s i v e se t o f r e q u i r e m e n t s .

3. S t a t i s t i c s c o l l e c t e d by the Amer l can H o s p i t a l A s s o c i a t i o n i n d i c a t e t h a t the number o f dea ths t h a t c o u l d have been p r e v e n t e d w i t h t he use o f smoke d e t e c t o r s i n p a t i e n t rooms was v e r y s m a l l , e i t h e r by bed coun t o r p a t i e n t day coun t . ( M i n i s c u l e o v e r a F i v e y e a r p e r i o d . )

4. The s u b s t a n t i a t i o n t h a t i s b e i n g used, " t o c o n f o r m to the model b u i l d i n g c o d e s " , i s an i m p r o p e r one, The p r o p o s a l shou ld s tand on i t s own m e r i t .

5. T h i s p r o p o s a l shou ld be r e j e c t e d and f u r t h e r s t u d i e d w h i l e a more u n i f o r m approach i s taken v i s . a . v i s , c o m p a r t m e n t a l i z a t i o n , s p r i n k l e r s and smoke d e t e c t o r . P r o v i s i o n s must be made t o t ake i n t o accoun t o t h e r l o c a l l aw. COMMITTEE ACTION: Accep t .

SUBSTANTIATION: Given that the proposal says to revise 12-3.5 and shows suggested wording only for 12-3.5.1 and 12 3.5.2, i t is unclear i f the Committee intended to retain or delete current 12-3.5.3 through 12-3.5.5. COMMITTEE ACTION: Accept.

(Log #273) 101 285 - (12 3.5.1 and 13-3.5.1): Reject SUBMITTER: Daniel M. McGee, American Iron and Steel Inst i tu te COHMENT ON PROPOSAL NO,: I01-458 RECOMMENDATION: Move the proposed new provislon to Chapter G, Features of Fire Protection, as Section 6-5.8, reading as Follows:

G-5.8 In Types I and I I construction, when approved by . . . . SUBSTANTIATION: The need For, and j us t i f i ca t i on for , the proposed provision is not occupancy sensitive hence, i t should be made applicable to a l l occupancies. I f there is a val id reason to omit sprinklers From a space, i . e . , a telephone swltching closet, that reason is valid in a l l occupancies. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The proposed expansion to including the w o r d i n g i n Chap te r 6 wou ld be an u n l n t e n d e d and s i g n i f i c a n t b r o a d e n i n g o f t he scope o£ the provis ion t h a t was no t i n t e n d e d by t he Commi t tee ,

(Log #557) 101 286 - (12-3.5.I Exception and 13 3.5.1 Exception): Reject SUBMITTER: RolF Jensen, P.E., James Antel l , A.I .A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101 458 RECOMMENDATION: Reject Proposal I01-458 for inclusion in Chapters 12 and 13.

Add an Exception to Section 7-7.1.I as Follows: Exception: When approved by the authority having

ju r isd ic t ion , al ternat ive protection measures may be substituted for sprinkler protection in specified areas without causing a building to be classif ied as non sprinklered. SUBSTANTIATION: The concept of al ternat ive protection methods applies to a l l occupancies and construction types. This proposal c l a r i f i e s the intent in broader, simpler terms without res t r ic t lng occupancy, c o n s t r u c t i o n , o r o t h e r f a c t o r s . COMMITTEE ACTION: R e j e c t . COMMITTEE COMMENT: See Comml t tee A c t i o n on Comment 101 287 on 1 2 - 3 . 5 . 1 E x c e p t i o n and 1 3 - 3 . 5 . 1 E x c e p t i o n (Log #447 ) . I n a d d i t i o n t h i s comment wou ld p r o v i d e a s i g n i f i c a n t b r o a d e n i n g o f t h i s E x c e p t i o n wh i ch has no t had p u b l i c r e v i e w .

(Log #503) 101 - 283 - (12-3.4.5.4): Accept 5UBMITTER: Mike Thompson, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101 456 RECOMMENDATION: Delete proposed 12-3.4.5.~. SUBSTANTIATION: Adequate substantiation has not been provided by BCMC to warrant ins ta l la t ion of heat detectors in conjunction with rated enclosures in hazardous areas. I have not seen documentation of Fires breaching a l hour or 2 hour f i r e wall pr ior to nursing s ta f f becoming aware of the Fire that would j u s t i f y the proposal. COMMITTEE ACTION: Accept.

(Log #148) 101 - 284 - (12-3.5): Accept ~UBMITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: 101-457

I RECOMMENDATION: Retain current 12-3.5.3, 12 3.5.4 and

(Log #447) 101 - 287 - ( 1 2 - 3 . 5 . 1 E x c e p t i o n and 1 3 - 3 . 5 . 1 E x c e p t i o n ) : R e j e c t SUBMITTER: Kenne th F a u l s t i c h , Wash ing ton , DC COMMENT ON PROPOSAL NO.: 101-458 RECOMMENDATION: Delete the proposed new Exceptions. SUBSTANTIATION: I t is my understanding that this Exception was proposed to please those who don't want sprinklers in certain areas of a hospltal. By allowing this Exception, the myths and legends about accidental discharge of sprinkler heads in operating suites, nurseries, etc. w i l l l i ve on. This is no place for the Code to state an Exception which is already allowed in Section I-5. I f there are persons who Fear sprinklers in sensitive rooms, i t would be more appropriate to educate them then to perpetuate these misconceptions regarding the operation and r e l i a b i l i t y of sprinkler heads. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This Exception creates the c r i t e r i a and guidance to l im i t those areas where the authority having j u r i sd ic t ion can allow eliminating automatic sprinkler protection.

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(Log #427) 101 - 288 - (12-3.5.I Exception and 13-3.5.1 Exception): Reject SUBMITTER: Peter Lamb, East Lyme Fire Marshal's OFfice, CT COMMENT ON PROPOSAL NO.: I01-458 RECOMMENDATION: Reject Proposal I01-458. SUBSTANTIATION: Section I-5 c lear ly allows equivalent protection to be provided and 7-7.3 clear ly allows alternative automatic extinguishing equipment to be substituted for automatic sprinklers. This Exception is encouraging, something which the Committee on Safety to Life has fought hard against; that is the unsubstantlated removal of automatic sprinklers from various areas of hospitals. NO documented evidence has been provided which just i f ies these exemptions and the Committee on Safety to Life should not encourage i t through this specific exemption. Should the authority having jur isd ic t ion want to grant certain exemptions, Chapters 1 through 7 provide suf f ic ient lat i tude For this. COMMITTEE ACTION: Reject. COMMITTEE COMHEN!: See the Committee Comment on Comment I01-287 on 12-3.5.1 Exception and 13-3.5.1 Exception (Log #447).

(Log #556) I01 - 289 (12-3.5.2): Accept in Principle SUBMITTER: RoIF Jensen, P.E., James Ante]l, A.I.A., Roll Jensen& Associates, Inc. COMMENT ON PROPOSAL NO.: 101-457 RECOMMENDATION: Revise 12-3.5.2 to read as Follows:

12-3.5.2 Where this code permits exceptions For Fully sprinklered health care occupancies, the sprinkler system shall be:

(a) In complete accordance with Section 7-7. (b) E lect r ica l ly connected to the f i r e alarm system

and , (c) Fully supervised.

SUBSTANTIATION: The primary reason for the revised text is to clear up bulky language. However, two technical changes are also included:

I. Portions of a hospital are not l ight hazard occupancies. Therefore, this section should not address only l ight hazard.

2. I f sprinkler tradeoFfs are being ut i l ized, the system should be properly designed even i f the sprinklers are not otherwise required by code. COMMITTEE ACTION: Accept in Principle.

Do as proposed by the Submitter For both 12-3.5.2 and 13-3.5.2. COMMITTEE COMMENT: The Committee agrees with the Submitter but notes this must be done for both Chapters 12 and 13.

(Log #274) I01 - 290 - (12-3.5.2 and 13-3.5.2): Reject SUBMITTER: Daniel M. McGee, American Iron and Steel Inst i tu te COMMENT ON PROPOSAL NO.: I01-459 RECOMMENDATION: Hove the proposed new provision to Chapter 6, Features of Fire Protection, as Section G-5.8, reading as follows:

6-5.8 In Types I and I I construction, when approved by . . . . SUBSTANTIATION: See statement on AISI comment on Proposal No. 458. COMMITTEE ACTION: Reject. q0HMITTEE COMMENT: See Committee Comment on Comment ]01-285 on 12-3.5.1 and 13-3.5.1 (Log #273).

(Log #558) 101 - 291 - (12-3.5.2 Exception and 13-3.5.2 Exception): Reject $UBMITTER: Roll Jensen, P.E., James Ante]l, A.I.A., Rolf Jensen& Associates, Inc. COMHENT ON PROPOSAL NO.: I01-459 RECOMMENDATION: Reject Proposal 101-459. Incorporate concept in Chapter 7.

SUBSTANTIATION: See comments on Proposals I01-458. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment I01-286 on 12-3.S.l Exception and 13-3.5.1 Exception (Log #557).

(Log #428) 101 - 292 - (12-3.5.2 Exception and 13-3.5.2 Exception): Reject SUBMITTER: Peter Lamb, East Lyme Fire Marshal's Office, CT COMMENT ON PROPOSAL NO.: I01-459 RECOMMENDATION: Reject Proposal I01-459. SUBSTANTIATION: Section I-5 c lear ly allows equivalent protection to be provided and 7-7.3 clearly allows alternative automatic extinguishing equipment to be substituted for automatic sprinklers. This E<ception is encouraging, something which the Committee on Safety to Life has Fought hard against; that is the unsubstantiated removal of automatic sprinklers From various areas of hospitals. No documented evidence has been provided which jus t i f i es these exemptions and the Committee on Safety to Life should not encourage i t through this specific exemption. Should the authority having Jurisdictlon want to grant certain exemptions, Chapters I through 7 provide suf f ic ient lat i tude For this. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Comment on Comment I01-287 on 12-3.5.I Exception and 13-3.5,1 Exception (Log #447).

(Log #559) lOl - 293 - (12-3.5.2, 13-3.5.2, 14 3.5.2, and 15-3.5.2): Accept in Principle SUBMITTER: RoIF Jensen, P.E., James Ante]l, A.I.A., PoIF Jensen& Associates, Inc. COMMENT ON PROPOSAL NO.: IO1-460 RECOMMENDATION: Accept Proposal 101 460. SUBSTANTIATION: NFPA 13 defines hazard classi f icat ions for automatic sprinkler systems, not NFPA lOl. Not a l l health care areas are l ight hazard in nature. COMMITTEE ACTION: Accept in Principle.

With respect to Chapters 12 and 13 see Committee Action on Comment I01-289 on 12-3.5.2 (Log #556). With respect to Chapters 14 and 15, replace current 14-3.5.2 and 75-3.5.2 with the Following:

14-3.5.2 (15-3.5.2) Where this Code permits exceptions for Fully sprinklered detention and correctional occupancies, the sprinkler system shall be:

(a) In complete accordance with Section 7-7, (b) Elect r ica l ly connected to the f i r e alarm system,

and (c) Fully supervised.

COMMITTEE COMMENT: The above Committee Action and the Committee Action taken on Comment 101 28g (Log #556) should satisfy the intent of the Submitter.

(Log #311) 101 - 294 - (12-3.6.1): Accept SUBHITTEQ: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: 101-462 RECOMMENDATION: Reinstate Exception No. 2 to Section 12-3.6.1.

Exception No. 2: Corridor part i t ions may terminate at ceilings which are not an integral part of a Floor .

' i a i through (e) SUBSTANTIATION: The deletion of thls Exception eliminates a design option that has been previously allowed and technically accepted. The Submitters provide no demonstrated need or documented support for this proposed change. Their comments that this provision would allow a one hour wall to terminate at a membrane with unknown f i r e rating and that the change would f a c i l i t a t e coordination with model codes are not suf f ic ient to eliminate this important design option. COMMITTEE ACTION: Accept.

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(Log #560) 101 - 295 - (12 3.6.1 Exception No. 7): Reject SUBMITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-463 RECOMMENDATION: Reject Proposal I01-463. SUBSTANTIATION: The PrOposed change to l im i t combustibles to quantities or arrangements such that "a f u l l y developed f i r e is unl ikely to occur" is vague and unenforceable. This language is inappropriate For the Code. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Comment on Comment I01-296 on 12-3.6.1 Exception NO. 7 (Log #458).

(Log #458) 101 296 (12-3.6.I E~ception No. 7): Reject SUBMITTER: William E. KofFel, KoFFel Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-463 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: The proposed text is not enforceable. There are too many variables to be considered in evaluating whether the furnishings are such that a Fully developed Fire is unl ikely to occur. The issue is compounded by the fact that a national ly recognized test standard does not exist . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that the technology is available to test the Furnishings and that such testing is an option, not a mandate.

(Log #312) I01 - 297 - (12-3.6.1 Exception No. 7): Reject SUBMITTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: I01-463 RECOMMENDATION: Delete proposed Exception No. 7 (e). SUBSTANTIATION: There is no generally accepted standard for minimizing the quantity of and arranging furni ture and furnishings in such a manner that a Fully developed f i r e is unl ikely to occur.

As there is a task group appointed on the issue of Furniture and Furnishing combustibi l i ty we should hold this recon~nendation For Further study, allowlng that task force the time to prepare i ts arguments. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Comment on Comment 101-296 on 12-3.6.I Exception No. 7 (LOg #~58).

(Log #272) 101 298 - (12-3.6.3 and 12-3.6.4): Accept SUBHITTER: Major Hike Daniel, US Army COMMENT ON PROPOSAL NO.: I01-465 RECOHMENDAT~: Reject Proposal I01 465, p. 349, TCR. SUBSTANTIATION: To show support For the Committee Action in i t s reject ion of the proposal, Commenter f u l l y concurs with the action and concerns of the Committee. COMMITTEE ACTION: Accept. COMMITTEE COMMENT: The Committee thanks the Submitter For his support.

(Log #313) 101 - 299 - (12-3.6.3 and 12-3.6.4): Accept SUBMITTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: I01-466 RECOMMENDATION: Support the Committee's action on this proposal. SUBSTANTIATION: The Committee should be commended For thei r work in rewrit ing these paragraphs. COMMITTEE ACTION: Accept. COMMITTEE COMMENT: The Committee thanks the Submitter for his support.

(Log #429) lOl - 300 - (12-3.6,3.1 Exception NO. 2 and 12-3.6.3.2 Exception): Reject SOBMITTER: Peter Lamb, East Lyme Fire Marshal's Office. CT COMMENT ON PROPOSAL NO.: I01-466 RECOMMENDATION: Revise 12-3.6.3,1 Exception No. 2 and 12-3.6.3.2 Exception by deleting "sink closets."

SUBSTANTIATION: The only difference between a sink closet and a jan i to r ' s closet is the amount of time i t takes the jan i to r that has occupied a new building to build some shelves and put storage in there. This is an unreal ist ic Exception which is determental to an otherwise valid Exception (see Comment on I01-504 also). COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Normal inspections are intended to F~nd this misuse of a space, and to order corrections made.

(Log #256. 257) lOl - 301 - (12-3.6.3.4 and Exceptions No. I and 2 (New)): Reject SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: I01-466 RECOMMENDATION: Revise 12-3.G.3.4 to read:

12 3.6,3.q All doors to habitable rooms shall be automatlc closing by smoke detection in accordance with 5-2.1 Exception. All other doors shall be self-closing or automatic closing in accordance with 5-2.1.8.

Exception No. I: Doer closing devices are not required on doors to patient sleeping rooms in buildings protected throughout by an approved, supervised automatic sprinkler system instal led ~n accordance with Section 7-7.

Exception NO. 2: In buildings protected throughout by an approved, supervised automatic sprinkler system, doors required to be automatic closing may be either automatic closing or self-closing in accordance with 5 - 2 . 1 . 8 .

S U B S T A N T I A T I O N : T h e C o m m i t t e e h a s n o t p r o v i d e d a n y

substantiation as to the problem of putting closers on doors that do not involve patient sleeping rooms. In recognition of this problem, the Board For the Coordination of Model Codes is recommending elimination of these closers on patient sleeping room doors in buildings that are Fully sprinklered. History continues to repeat i t s e l f in nonsprinklered properties with doors being l e f t open and exposing patients in other areas o n the Fire Floor as well as o n other f loors. The Fire history continues to show the problem with patient room doors not being closed in nonsprinklered Fac i l i t ies . ~OMHITTEE ACTION: Reject. COMMITTEE COHMEN!: The Committee Feels that the Staff ing provided can close the doors. Although automatic closers do not present a l l the problems of sel f closers the Committee Feels that the Following problems are su f f i c ien t to reject this comment:

I. Once a Fire is detected and doors close i t w i l l be more d i f f i c u l t For s ta f f to locate the room in which the Fire is located.

2. Conditions within the room deteriorate Faster with the door closed giving s ta f f less time to rescue patients.

3. With the door continually trying to close af ter smoke detection i t w i l l be much more d i f f i c u l t For s ta f f to remove the patients in the room resulting in s ta f f propping open the door in order to perform the rescues and thereby defeating the intent of the closer.

(Log # 1 ~,9) I01 - 302 - (12-3.6.5): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories qOMMENT ON PROPOSAL NO.: I01-466

[ RECOMMENDATION: Delete current 12-3.G.5. SUBSTANTIATION: Given that the proposal addresses only 12-3.6.3 and 12-3.6.4 but deals with wording of current 12-3.6.5, i t is unclear as to what to do with current 12-3.6.5. COMMITTEE ACTION: Accept.

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(Log #2S8) 101 - 303 - (12-3.7.6 and 12-3.7.7): Accept in Principle SUBMITTER: John Behrens, Huntington Beach, CA qOMMENT ON PROPOSAL NO.: 101-468 REqOMMENDATION: Delete 12-3.7.6 and 12-3.7.7 and substitute the Following: 12-3.7.6 to read as printed as 12-3.7.5 in Proposal 101-471.

SUBSTANTIATION: Proposal I01-468 had two paragraphs, 12-3.7.6 and 12-3.7.7 that addressed the same subject. In the Committee Action i t did not add the second sentence to 12-3.7.6 but maintained 12-3.7.7 as printed. The double printing error here generates confusion. In addition, Proposal I01-471 completely rewrote the section on doors and appears to be the wording which the Committee desires. COMMITTEE ACTIOn: Accept in Principle.

The Committee agrees with the intent of the Submitter. In order to c l a r i f y the Committee's Actions on 12-3.7.5, 12-3.7.6, 12-3.7.7 and 12-3.7.8 the Following is a complete draft of those paragraphs.

12-3.7.5 Doors in smoke barriers shall be substantial doors, such as l 3/4 in. (4.4 cm) thick, solid bounded wood core or construction that w i l l resist Fire For at least 20 minutes. Cross corridor openings in smoke barriers shall be protected by a pair of swinging doors or a horizontal sliding door, complying with 5-2.1.14. Swinging doors shall be arranged so that each door w i l l swing in a direction opposite from the other. The minimum door leaf width fo r swinging doors shall be as follows:

(a) hospitals and nursing homes: 44 in. ( l . l m) (b) hospitals For psychiatric care and limited care

Fac i l i t ies : 34 in. (86.¢ cm) The minimum clear opening For horizontal sliding

doors shall be as Follows: (a) hospitals and nursing homes: 88 in. (2.2 m) (b) hospitals For psychiatric care and limited care

Fac i l i t ies : G8 in. (1.7 m) 12-3.7.6 Doors in smoke barriers shall comply with

6-3.3 and shall be sel f closing or automatic closing in accordance with 12-2.2.2.6.

12 3.7.7 Vision panels of approved transparent wired glass not exceeding 1296 sq in. (.84 sq m) in steel or other approved metal Frames shall be provided in each cross corridor swinging door and at each cross corridor horizontal sliding door in a smoke barr ier.

12-3.7.8 Rabbets, bevels, or astragals are required at the meeting edges, and stops are required at the head and sides of door frames in smoke barriers. Positive latching hardware is not required. Center mullions are prohibited. COMMITTEE COMMENT: The Conm~ittee agrees with the intent of the Submitter and feels that reprinting the Four paragraphs in question w i l l clar i fy the intent of the Committee and i ts actions over several proposals.

(Log #448) I01 -- 304 - (12-3.7.3): Reject SUBMITTER: Kenneth FauIstich, Washington, DC ~OMMENT ON PROPOSAL NO.: lOI-46B RECOMMENDATION: Revise paragraph 12-3.7.3 to add a second sentence to read as follows:

"Engineered smoke control systems shall not be permitted in l ieu of smoke dampers." SUBSTANTIATION: Proposal Nos. 474 and 477, which have been accepted, have deleted the Exception For engineered smoke control systems for openable windows and bevels, etc. at the meeting edge of smoke barrier doors. I f i t is the intent of the Subcommittee to eliminate this trade o f f for these situations, i t would seem appropriate to eliminate the same trade o f f for smoke dampers as is currently allowed by Exception NO. 1 to paragraph 6-3.5.1. ~MMITTEE ACTION: Reject. qOMMITTEE COMMENT: The Committee has accepted Comment I01-307 on 12-3.8.1 (Log #314) and thereby is allowing recognition of engineered smoke control systems. See the substantiation provided by the Submitter of Comment I01-307 (Log #314)~

(Log #339) I01 - 305 - (12-3.7.7): Accept in Principle ~J_BMITTER: Howard Boyd, Nashville, TN COMMENT ON PROPOSAL NO.: I01-472 RECOMMENDATION: Revise as follows:

12-3.7.7 Vision panels of approved transparent wired glass not exceeding 1296 sq in. (9.84 sq m) in approved metal frames shall be provided in each (cross corridor) door in a smoke barrier. SUBSTANTIATION: All doors in a smoke barrier may not be cross corridor doors. Present wording requires vision panel in doors in corridor walls.

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qOMMITTEE ACTION: Accept in Principle. See the Committee Action taken on Comment 101-303 on

12-3.7.6 and 12-3.7.7 (Log #258). qOMMITTEE COMMENT: The action taken on Comment I01-303 (Log #258) should sat isfy the intent of the Submitter.

(Log #561) 101 - 306 - (12-3.7.7): Accept in Principle SUBMITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen& Associates, Inc. COMMENT ON PROPOSAL NO.: I01-468 RECOMMENDATION: Delete 12-3.7.7. SUBSTANTIATION: This section is identical to 12--3.7.6 as printed in the TCR. I t is therefore an edi tor ia l correction only. qOMMITTEE AqTION: Accept in Principle.

See action taken on Comment I01-303 on 12-3.7.6 and 12-3.7.7 (Log #258). COMMITTEE COMMENT: The Committee feels that the action taken on Comment I01-303 (Log #258) should sat is fy the intent of the Submitter.

(Log #314) 101 - 307 - (12-3.8.1 Exception No. 4): Accept SUBMITTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: I01-477

I RECOMMENDATION: Reject the accepted proposal. SUBSTANTIATION: Properly engineered smoke control systems w i l l operate adequately and we shouldn't condemn a concept because o f some poor designs. NFPA 92A is being developed as a gu~del~ne in des ign ing smoke c o n t r o l systems so r a t h e r thaT~ "Jump the gun" l e t ' s wa i t u n t i l the exper ts have spoken, COMMIMTEE ACTION: Accept.

(Log #315) I01 - 308 - { 1 2 - 4 . 2 ) : Accept SUBMITTER: Douglas S. Er lckson. American Hosp i ta l Assn. COMMENT ON PROPOSAL NO.: 101-479

I RECOMMENDATION: Reject the accepted paragraph. SUBSTANTIATION: High r i s e hea l th care F a c i l i t i e s are a l ready requ i red to comply w i th most o f the p r o v i s i o n s of Section 30-8. Compliance is not always in the same Form called For within the Code, however, our needs are much d i f ferent than high rise of f ice buildings, condominiums or apartments. The entire philosophy within a health care occupancy suggests an approach d i f ferent than required by 30-8. COMMITTEE ACTION: Accept.

(Log #459) 101 - 309 - (12-4.2): Accept SUBMITTER: William E. KoFfel, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-479 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: We recognize that high rise buildings present d i f f i c u l t y in evacuating the occupants. However, health care occupancies are designed based on a defend in place concept due to the d i f f i c u l t y in evacuation regardless of the building's height. The requirements proposed in Section 30-8 which are applicable to health care occupancies have already been incorporated into Chapter 12. No additional requirements are necessary nor has adequate substantiation been provided indicating the need For additional requirements. COMMITTEE ACTION: Accept.

(Log #380) 101 - 310 - (12-4.2): Accept $UBMITTER: H.E. Nelson, NBS COMMENT ON PROPOSAL N~.: I01-479 REqOMMENDATION: Delete. SUBSTANTIATION: The requirements in Section 30-8 are inappropriate for health care Fac i l i t ies . The protection needed for health care f a c i l i t i e s , including those in high-rise buildings, is well provided for in Chapters 12 and 13 without this cross reference. COMMITTEE ACTION: Accept.

(Log #562) 101 - 311 - (12-4.2): Accept SUBMITTER: Roll Jansen, P.E., James Antell, A.I.A., Roll Jansen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-479 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The high-rise provisions were added by the Main Committee with no review by the Sub-committee. This comment is being submitted to allow the Sub-committee to review the proposal and make changes to coincide with the specific needs of the occupancy group. COMMITTEE ACTION: Accept.

(Log #180) I01 - 312 - (12-4.2): Reject $UBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: 101-479 RECOMMENDATION: Insert, before the actual sentence with the requirement, a boldface type heading "High Rise Buildings." SUBSTANTIATION: The boldface type heading w i l l call attention to the new requirement and set i t o f f as a separate subject from the items which precede and fol low i t . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee has accepted Comment 101-308 on 12-4.2 (Log #315) thereby ellminating this section.

(Log #504) 101 - 313 - (12-4.2 Exceptions No. I and 2 (New)): Reject SUBMITTER: Mike Thompson, American Health Care Assn. COMMENT ON PROPOSAL NO.: I01-479 RECOMMENDATION: Add two Exceptions to 12-4.2 as follows:

Exception No. I: Compliance with Section 30-8.3.1 is not required.

Exception No. 2: Emergency l~ghting shall comply with Section 12-2.9. SUBSTANTIATION: A voiced alarm system, whether i t be a pre-taped message or paging, should not be used to not i fy health care patients of a f i r e , part icular ly i f they are unable to respond to the voice commands. A voice system wi l l lead to confusion and possible panic among individuals in a health care f a c i l i t y . Emergency l ighting is handled d i f fe ren t ly in 12-2.9 and should be referenced as an Exception to the requirements of 30-8.4. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee has accepted Comment 101-308 on 12-4.2 (Log #315) therefore the Exceptions are unnecessary.

(Log #150) 101 - 314 - (12 -6 .1 .6 .5 and 1 3 - 6 . 1 . 6 . 5 ) : Accept SUBMITTER: John A. Sharry , Lawrence-Livermore Labo ra to r i es qOMMENT ON PROPOSAL NO_.: 101-484 RECOMMENDATION: Correct to use possessive Form with the spelling "authori ty 's". SUBSTANTIATION: Correction to use possessive form. COMMITTEE ACTION: Accept.

(Log #160) I01 - 315 - (12-6.2.2): Accept $UBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-485 RECOMMENDATION: Delete a l l of current 12-6.2.11. SUBSTANTIATION: The Committee proposal, on which this comment is being made, places a l l the acceptable means of egress components for this occupancy and their associated "special features" together in the 2.2 section of this occupancy chapter. Some of the

proposed wording for this expanded 2.2 section comes from the 2.11 Special Features portion of the current (1985 edition) chapter, Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #151) I01 - 316 - (12-6.2.8 and 13-6.2.8): Accept SUBMITTER: John A. Sharry. Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NQ~: 101-486 RECOMMENDATION: Retain the boldface heading from the current edition which reads: "Il lumination of Means of Egress". SUBSTANTIATION: From the proposed wording i t is unclear i f the current boldface heading is to be retained or deleted. COMMITTEE ACTION: Accept.

(Log #563) I01 - 317 - (12-6.3.7.5): Reject yUBMITTER: Rolf Jensen, P.E., James Antell, A.I.A., Roll Jensen& Associates, Inc. COMMENT ON PROPOSAL NO.: I01-491 RECOMMENDATION: Accept Proposal I01-491. SUBSTANTIATION: 150 f t l imi t is unduly res t r i c t i ve without any benefit. I f a size l imi t is set, ~t should be based on occupant travel distance, not physical building dimensions. The protection level required is nearly the same as For in-Patient areas. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The l imitat ion in maximum compartment length actually approaches 300 Ft due to the Exception provided and the Committee feels this is a practical l imi t where patients are, at times, not capable of se l f preservatlon.

(Log #147) I01 - 318 - (13 - I . I . I . 2 ) : Accept SUBMITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: 101-401 RECOMMENDATION: For 13- I . I . I .2 delete the words "the design of" so as to read:

"This chapter establishes l i f e safety requirements for a l l existing hospitals . . . . " ~UBSTANTIATION: The words "the design of" should apply only to 12-I.I.1.2 for new construction. COMMITTEE ACTION: Accept.

(Log #316) 101 - 319 - (13-1.1.4.6): Accept in Principle SUBMITTER: Douglas S. Erickson, American Hospital Assn. COMMENT ON PROPOSAL NO.: 101-492 RECOMMENDATION: Add a new 12-I.I.4.2, renumbering the subsequent paragraphs.

12-1 .1 .4 .2 In modern iza t ion p r o j e c t s and renova t i ons to e x i s t i n g f a c i l i t i e s , on ly t ha t p o r t i o n o f the t o t a l F a c i l i t y a f f e c t e d by the p r o j e c t sha l l comply w i t h the p r o v i s i o n s o f Chapter 12 in accordance w i t h Sect ion I-4.6.

SUBSTANTIATION: Health care occupancies are unique to other occupancies in that we are constantly modernizing existing structures. As technology or the public need for health care changes, hospitals have to renovate in order to maintain current with the state of the art , thereby providing the highest level of quality care. A major obstacle to our constant modernization is the local or state authority having jur isd ic t ion mandating we bring the entire complex up to current "new" standards. I t is important to understand that those areas of a building that are not undergoing renovation are s t i l l in f u l l compliance with acceptable editions of the Code. Because of the possible f inancial implications of this impractical request hospitals may need to reconsider their renovation programs, thwarting their obligations to meet the medical needs of thei r communities.

322

The wording change w i l l allow health care f a c i l i t i e s to elevate thei r buildings to the "new" Code requirements in accordance with a long range/master plan. COMMITTEE ACTION: Accept in Principle.

Revise 13-I.I.4.6 to read as Follows: 13-I.I .4.6 In modernization projects and renovations

to existing Fac i l i t ies , only that portion of the total Fac i l i t y affected by the project need comply to the provision of Chapter IZ in accordance with I-4.6.

Exception: Existing health care occupancies 75 f t or more in height shall not be required to comply with the sprinkler provision applicable to new construction when undergoing modernization to renovations provided al l other applicable provisions of this Code are met. COMMITTEE COMMENT: The Committee agrees with the intent of the Submitter but has combined this with another previously accepted proposal. Also see Committee Comment on Comment I01-201 on 12-I.I.4.2 (Log #303).

(Log #64) TO1 - 320 - (13-I . I .4.6) : Accept in Principle SUBMITTER: Thomas D. Mattern, UCLA Neuropsychiatric Hospital COMMENT ON PROPOSAL NO.: 101-492 RECOMMENDATION: I t is my understanding that this proposal has been referred to the Subcommittee on Administration of the Life Safety Code, and in so doing, the Committee re3ected this proposal with the comment that "the current method of defining new construction is adequate".

The Subcommittee's action on this proposal must be questioned in their rejection For the Following reasons:

Wh~le there are two sections covering "Health Care Occupancies"

I. Chapter 12 "New" 2. Chapter 13 "Existing" There is not in either of these chapters any clear

def in i t ion as to when an "existing Health Care occupancy", in the process of modernization, passes a point that requirements for compliance with a l l aspects of the current Life Safety Code should be met.

Although reference under 12-I. I .4, is made to I-4.5 and I-4.6, i t is apparent that by referr ing this proposal to the Administrative Subcommittee, that these two sections are not as clearly defined as the Subcommittee on Health Care occupancies would l ike to see. I must conclude that although the Subcommittee "believes the current method of defining new construction is adequate" they by thei r actions believe that a more comprehensive def in i t ion is required.

As the original Submitter of this proposal, I Feel that reconsideration by the Subcommittee on Health Care occupancies is required and i f any action is taken i t should be in the Form of "Accept in Principle" with modifications to the original proposal as the Subcommittee feels appropriate. SUBSTANTIATe: The Health Care Industry today is undergoing ma3or changes due to modern technologies and the need For competitiveness within the marketplace.

In order For hospitals to meet the demands of the patients they serve, continual upgrading and modernization is required.

One of the major obstacles faced by Hospital Planning Committees is to define at what point they pass beyond the scope of "modernization", and enter the area of "new construction". As noted in the original proposal, this also appears to be an unclearly defined area For authorit ies having jur isdict ion. In order not to t o t a l l y s t i f l e the competitive nature of the Health Care Industry due to the inab i l i t y to progress at a rate dictated by our changing times, and the ab i l i t y to provide aesthetically pleasing atmospheres for the patients we serve without major cost increases to these patients, that would be required i f "new construction" standards were to be enforced because of unclear def ini t ions. For these reasons I Feel that reconsideration of the Committee's action is appropriate. COMMITTEE ACTION: Accept in Principle.

No action needed. See Committee Action taken on Comment I01-319 on

13-1.1.4.6 (Log #316).

COMMITTEE_COMMENT: The Committee feels that the action taken on Comment 101-319 (Log #316) should meet the overall intent of the Submitter.

(Log #271) I01 - 321 - (13-1.1.4.6): Reject SUBMITTER: Major Mike Daniel, US Army COMMENT ON PROPOSAL NO~: 101-493 RECOMMENDATION: In the Exception, change the words "sprinkler provision" to "high rise building provisions". The text would then read as follows:

13-1.1.4.6 Modernization or Renovation. Any alteration, or any instal lat ions of new equipment, shall comply with I-4.6.

Exception: Existing health care occupancies ~75 f t in height shall not be required to comply with the high rise building provisions applicable to new construction when undergoing modernization or renovation provided a l l other applicable provisions of this Code are met. SUBSTANTIATION: The substantiation essential ly remains the same as for my previously accepted proposal (I01-493) with one additional comment. With the acceptance of Proposals I01-479 and lot 920 creating a new Section 30-8 applicable to new health care occupancies, the same confusion and problems can be anticipated with Fire alarm system requirements as previously identi f ied For automatic sprinkler systems. This change w i l l a l lev iate that confusion, keep the Fire alarm provisions with new health care occupancies as or ig ina l ly intended, and also avoid any problems with misinterpretation. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee has taken action, through Comment lOl 308 on 12-4.2 (Log #315), that deletes the section on high rise provisions and therefore this revision is unnecessary.

(Log #161) 101 - 322 - 13-2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO=: I01-494

I RECOMMENDATION: Delete a l l of current 13-2.11. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places a l l the acceptable means of egress components For this occupancy and their associated "special Features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording For this expanded 2.2 section comes From the 2.11 Special Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #6G) 101 - 323 - (13-3.2.I): Reject SUBMITTER: Thomas D. Mattern, UCLA Neuropsychiatric Hospital COMMENT ON PROPOSAL NO.: I01-500 RECOMMENDATION: While there is general agreement, I Feel that the proposed wording is too res t r i c t i ve as i t relates to Laundries. Change to read:

"Commercial laundries greater than 200 sq Ft". SUBSTANTIATION: While I have general agreement with the Committee's actions, I Feel that 100 sq f t becomes too res t r ic t ive without a Further def in i t ion of a "laundry".

Psychiatric hospitals are required to provide a "home environment" For their patients. In order to meet this requirement, and what is also considered a part of the therapeutic treatment for patients, small "laundry" Fac i l i t ies consisting of a washer and dryer are required. The Feasib i l i ty of inserting these two machines in I00 sq f t of space becomes unrealistic:, and in most cases occupy spaces of 150 to 200 sq Ft.

In addition, where washers and dryers are located on patient units, these locations are generally under" direct supervision of s ta f f assigned to the patient care area and are not used For the laundering of hospital supplied materials ( i . e . , sheets, pillowcases, etc.) but rather For patient personal clothing.

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By regulat ions governing l icensing and accredi ta t ion, a l l laundry areas are to be inspected and monitored da i l y For bui ld up of l i n t or other combustible m a t e r i a l .

In my e leven years o f exper ience w i th t h i s type o f s e t t i n g , on ly one minor " f i r e " has occur red , and t h a t incident was caused by an overheated motor on a washing machine.

I t is my opinion that the Committee reconsider th is spec i f i c item w i th in the proposed standard. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Comment prowded on Comment I01 218 on 12-3.2~1 (Log #65). In addit ]on see the Committee Action taken on Comment I01 216 on 12-3.2.1 (Log #306).

(Log #460) I01 - 324 - ( 13 -3 .6 .1 Excep t lon , 13 -3 .6 .2 Excep t i on , 13 -3 .6 .3 Excep t ion and A - 1 3 - 3 . 6 ) : Accept SUBMITTER: W i l l i a m E. KoFFel, KoFfe l Assoc. , Inc . COMMENT ON PROPOSAL NO.: 101-505 RECOMMENDATION: Rejec t the p roposa l . SUBSTANTIATION: The proposal i nc ludes no s p e c i f i c t e s t procedure nor does a n a t i o n a l l y accepted procedure e x i s t . D e t a i l s such as specimen s i ze and i r r a d i a n c e w i l l a f f e c t the measured heat r e l ease . No s u b s t a n t i a t i o n has been p rov ided For the use o f a net peak r a t e o f heat re lease . " F i r e Behav io r o f Upho ls te red F u r n i t u r e " (NBS Monograph 173) c l e a r l y states that a 180 second averaging period For a bench scale test yielded the best co r re la t ion with Ful l -sca le tests. CO MH!TTEE_ACTION: Accept.

(Log #317) l o t - 325 - (13 3.G. I E,,cept~on. 13-3 .6 .Z Excep t ion and 13 -3 .6 .3 E x c e p t i o n ) : Accept SUBMITTER: Douglas S. E r l ckson , Amerlcan Hosp i t a l Assn. COMMENT ON PROPOSAL NO.: 101-505 RECOMMENDATION: Reject the accepted proposal. SUBSTANTIATION: As of the wr i t i ng of th is proposal, there is not a standard Fire test For evaluating f u rn i t u re or Furnishings. Although we are not f u l l y against regulat ing the types of Furnishings wi th in health care occupancies, we are strongly recommending th is proposal be held For fu r the r study un t i l the appointed furnishings task Force develops c r i t e r i a and establishes test ing guidel ines. COMMITTEE ACTION: Accept.

(Log #275) I01 - 326 - (13-3.6.1 Exception, 13-3.6.2 Exception, and 13-3.6.3 Exception): Reject SUBHITTER: Daniel M. McGee, American Iron and Steel I n s t i t u t e COMMENT ON PROPOSAL NOd: I01-505 RECOMMENDATION: Revise the proposed Exception to c l a r i f y the type of nongire-rated p a r t i t i o n permitted.

Exception: Areas of health care . . . by . . . nonf i re- ra ted noncombustible pa r t i t i ons . . . . SUBSTANTIATION: Intent of the modi f icat ion is to permit nonf i re- ra ted p a r t i t i o n where the f i r e load is low. To maintain that low Fire load, i t is important to keep the f i r e load of the structure low also. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee has accepted Co~nent 101-325 on 13-3.6.1 Exception, 13-3.6.2 Exception and 13-3.6.3 Exception (Log #317) th is el iminates the Exception in to ta l and therefore these modi f icat ions would be inappropriate.

(Log #10) 101 - 327 - ( 1 3 - 3 . 6 . | Excep t ion , 13 3 .6 .2 Excep t ion and 13 -3 .6 .3 E x c e p t i o n ) : Reject SUBMITTER: Hal Cohen, Lebanon, PA COMMENT ON PROPOSAL N O~: 101-505 RECOMMENDATION: Provide bet ter explanation i,~ Appendix.

SUBSTANTIATION: Although the intent is good, the Exception w i l l be e i ther uselessly or dangerously applied. From a pract ica l standpoint, an Architect/Engineer can not take out h is /her "500 kw tester" For peak rate of heat release. More than l i k e l y , an Archi tect would use the exception and an Engineer would guess. I f possible, the Technical Committee should add in the Appendix A reference document that would explain how to do the ca lcu la t lon. Unfortunately, Fire protect ion engineering is net at a point where net peak rate of heat release is an everyday c o n v e r s a t i o n . COMMITTEE ACTION: Re jec t . ~ M I T T E E COMMENT: The Committee has accepted Comment 101-325 on 13-3 .6 .1 Excep t ion , 13 -3 .6 .2 Excep t i on , and 13 -3 .6 .3 Except ion (Log #317). This comment e l i m i n a t e s t h i s Except ion and t h e r e f o r e the expanded appendix m a t e r i a l is unnecessary.

(Log #564) I01 - 328 (13-3.G.I, Exception, 13 3.6.2, Exception, 13-3.6.3, Exception, A-13-3.6): Accept SUBMITTER: R o l l Jensen. P .E . , James A n t e l l , A . I . A . , RolF Jensen& Assoc ia tes , Inc . COHMENT ON PROPOSAL NO.: I01 505 RECOMMENDATION: Reject Proposal 10]-505. SUBS_TANTIATION: I t is Far beyond the c a p a b i l i t i e s o f most o f the users o f t h i s Code to determine whether Fu rn i sh ings w i l l "produce a maximum, i ns tan taneous , net peak ra te o f heat r e l ease o f 500 kw." The requ l rement is unen fo rceab le . COMMITTEE ACTION: Accept .

(Log #430) I01 - 329 (13-3.6.3): Reject SUBMITTER: Peter L~ab, East Lyme Fire Marshal's OFFice, CT COMMENT ON PROPOSAL NO.: 101-504 RECOMMENDATION: In 13-3.6.3.1 Exception NO. 2 and 13-3.6.3.2 Exception, delete the term "sink c losets". SUBSTANTIATION: I t is jus t a matter of time before a "sink closet" becomes a " j a n i t o r ' s c loset" and has combustibles stored wi th in i t . The inclusion of slnk c l o s e t s in t h i s l i s t is d e t r i m e n t a l to an o the rw ise v a l i d Excep t ion . IF the s ink c l o s e t oDes. in Fact, not con ta i n Flammable or combus t ib le m a t e r i a l s , i t can be exempted under the " s im i l a r a u x i l i a r y spaces." COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Normal inspections are intended to f ind th is misuse of a space, and to order correct ions made.

(Log #403) I01 - 330 - (13 3.7.1 and 1 3 - 3 . 7 . 2 ) : Reject SUBHITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: 101-506 RECOMMENDATION: Revise 13-3.7.1 to read:

13-3.7.1 Regardless of bui ld ing construction type smoke barr iers shal l be provided as Follows:

(a) To d iv ide every story used fo r sleeping rooms fo r more than 30 health care occupants into at least two compartments, and

(b) To subd i v i de every s t o r y such tha t n e i t h e r the length nor width og any compartment exceeds 150 f t (45 m).

Exception No. l : No change. Exception No. 2: No change. 13-3.7.2 Delete,

SUBSTANTIATION: The reduction in smoke compartmentation requirements has not been j u s t i f i e d by the Committee. This is not a c l a r i f i c a t i o n as p r io r edi t ions of the Code c lear l y required subdivision. TO quote from the 1967 ed i t ion of the Code, I0-2.3.1.2 which s p e c i f i c a l l y applied to ex is t ing f a c i l i t i e s states, "no more than 150 Feet of corr idor length without smoke barr iers or hor izontal ex i ts shall be permit ted." This has been cont inual ly 6owngraded by the Subcommittee without j u s t i f i c a t i o n .

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COMMITTEE ACTION: Reject. COMMITTEE COMMENT: In the Committee's interpretation this is not a down grading of the Fire protection provided from prior editions of the Code. The Committee feels that there were various interpretations of this paragraph and that Proposal I01-506 is intended to c l a r i f y the intent of the Committee with regard to requirements of smoke barriers. The Committee Feels that the protection provided by this meets the level of safety intended by the Code for existing buildings.

(Log #162) I01 - 331 - (13-6.2.11): Accept SUBMITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-509

I RECOMMENDATION: Delete a l l of current 13 6.2.11. SUBSTANTIATION: The Committee proposal, on which this comment is being made, places a l l the acceptable means of egress components for this occupancy and their associated "special features" together in the 2.2 section of this occupancy chapter. Some of the proposed w o r d i n g f o r t h i s expanded 2 .2 s e c t i o n comes f r o m the 2.11 S p e c i a l Fea tu res p o r t i o n o f t he c u r r e n t (1985 e d i t i o n ) c h a p t e r . W i t h o u t the p roposed d e l e t i o n s t he r e q u i r e m e n t s wou ld appear t w i c e and s e r v e to con fuse t he u s e r . COMMITTEE ACTION: Accep t .

(Log #431) I01 - 332 - (14 2 .4 and 1 5 - 2 . 4 ) : Accep t SUBMITTER: P e t e r Lamb, East Lyme F i r e M a r s h a l ' s O f f i c e , CT COMMENT ON PROPOSAL NO.: I01 517

I RECOMMENDATION: R e j e c t P r o p o s a l 101 517. SUBSTANTIATION: The r e v i s i o n by the Subcommi t tee c o u l d r e s u l t i n no e x i t s b e i n g r e q u i r e d on the uppe r s t o r y o f a b u i l d i n g o r From a f i r e compa r tmen t . U n t i l t h i s can be f u r t h e r c l a r i f i e d i n F u t u r e e d i t i o n s , i t wou ld be b e t t e r to r ema in w i t h t he p r e s e n t t e x t i n t he Code. COMMITTEE ACTION: Accep t .

(Log #565) I01 - 333 - (14-2.4.1 and 15 2.4.1): Accept in Principle $UBMITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-517 RECOMMENDATION: Add at the end of the sentence:

" f loor of the building when the common path of travel exceeds the distances specified in 14-2.5.3 (15-2.5.3)." See comments on Log #519. SUBSTANTIATION: The current revised wording would require two means of egress From a cell t i e r regardless of the travel distance. The current wording would conf l ic t with the Committee's substantiation For Comment #519 (14-2.5.3). COMMITTEE ACTION: Accept in Principle.

I In current (1985 edition) 14-2.4.1 and 15-2.4.1 change the word " f loor" to "story". COMMITTEE COMMENT: Given the Committee Action on Comment I01-332 on 14-2.4 and 15-2.4 (Log #431) which w i l l retain current wording of the 14-2.4 and 15-2.4 paragraphs, the above change should meet the Commenter's intent.

(Log #566) I01 - 334 - (14-2.5.3): Accept in Principle SUBMITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-519 RECOMMENDATION: Insert a new 15-2.5.3 to coincide with 14-2.5.3. Renumber current 15-2.5.3 as 15-2.5.4. SUBSTANTIATION: The change is necessary to maintain consistency between requirements for new and existing f a c i l i t i e s . The requirement should apply to both.

COMMITTEE ACTION: Accept in Principle. Insert a new 15-2.5.3 as Follows: 15 2.5.3 No common path of travel shall exceed 50 f t

(15 m). Exception No. I: A common path of travel may be

permitted for the f i r s t lO0 f t (30 m) in a building protected throughout by an approved automatic sprinkler system in accordance with Section 7-7.

Exception No. 2: Multi level residential housing units in which each Floor level, considered separately, has at least one half of i ts individual required ex i t capacity accessible by ex i t access leading d i rect ly out of that level without traversing another communicating f loor level.

Exception No. 3: Existing excessive common paths of travel may be continued in use subject to the approval of the authority having jur isd ic t ion and the travel distance requirements of 15-2.6. COMMITTEE COMMENT: The Committee is concerned that existing detention and correctional occupancies not go unregulated with respect to common paths of travel, but does not want to throw existing buildings into noncompliance by requlring compl~ance with the stringent proposed requirements For new construction. As such, proposed Exception No. 2 will allow longer common paths of travel on levels of existing multilevel residential housing areas which are arranged per the requirements of 15-3.1.2. Exception No. 3 will recognize existing excessive common paths of travel with permission of the authority having jur isdict ion. This should meet the Commenter's intent of not let t ing existing buildings go unregulated with respect to common paths of travel.

(Log #163) I01 - 335 - ( 1 4 - 2 . 1 1 . 1 1 ) : Accep t SUBMITTER: John A. S h a r r y , Lawrence L i v e r m o r e Laboratories COMMENT ON PROPOSAL NO.: 101-514 RECOMMENDATION: Delete current 14-2.11.11. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places all the acceptable means of egress components For this occupancy and their associated "special Features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording for this expanded 2.2 section comes From the 2.11 Special Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #486) I01 - 336 - (14-3.1.2(d)): Accept SUBMITTER: William Prindle, Prindle Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-522 RECOMMENDATION: Delete the following:

(d) A complete automatic sprinkler system shall be provided throughout the housing area i f the area within the perimeter walls, measured as a horizontal projection, is less than 2,500 sq Ft. SUBSTANTIATION: l ) The computer model used to determine untenable heat and impaired v i s i b i l i t y , as I understand, rel ies on the introduction of Flammable liquids to achieve cell f i r e flashover. The probabil i ty of inmates having access to flammable liquids is remote. Perhaps Code requirements to ban storage of flammable liquids within the security perimeter of corrections and detention f a c i l i t i e s would be more appropriate and further reduce the risk of inmate access to flammable l iquids.

2) The proposed Code language w i l l encourage design and construction of larger cell/dayroom pods to avoid the Fully sprinklered requirements. Large correctional and detention f a c i l i t i e s with large numbers of inmates within d i f fer ing security c lassi f icat ions w i l l be able to accommodate the larger cell/dayroom pods with few risks. The smaller detention Fac i l i t ies may risk the integration of d i f fer ing security c lassi f icat ions within the larger cell/dayroom pods, resulting in the possible increase of violent inmate behaviour towards each other.

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3) There is no documentation From Fire losses to demonstrate the r isk of the unsprinklered small cell/dayroom pod design. However, the r isk of integrat ing incompatible inmate securi ty c lass i f i ca t ions is well known among larger advanced practice correct ional /detent ion systems. The primary r isk is with the smaller, less than state of the art detention system that demands of i t s archi tect to avoid spr inklers at a l l costs. COMMITTEE ACTION: Accept.

I Accept, and also delete the associated appendi~ note A-14-3.1.2(d). COMMITTEE COMMENT: The Fuel load wi th in the rooms and not the overal l room/pod size is the issue of concern. Restrict ions on Fuel load wi th in sleeping rooms per current 31-5.2 and on other detention and correct ional occupancy furnishings per current 31-5.4 help minimize the potential For f lashover. See Committee Action on Comment I01-337 on 14-3.1.2(d) (Log #461). Also see TCR Proposal No. I01-519 on common path of t ravel l im i ta t i ons .

(Log ~461) 101 - 337 - ( 1 4 - 3 . 1 . 2 ( d ) ) : Accep t i n P r i n c i p l e SUBMITTER: W i l l i a m E. K o F f e l , K o f f e l Assoc . , I n c . COMMENT ON PROPOSAL NO.: 101-522 RECOMMENDATION: D e l e t e the p roposed pa rag raph 1 4 - 3 . 1 . 2 ( d ) and the r e l a t e d Append i x no te . Add a new paragraph to read as Follows:

14-3.2.3 Sleeping rooms which do not comply with the p r o v i s i o n s o f 3 1 - 5 . 2 and 3 1 - 5 . 4 a re seve re hazard a r e a s .

Renumber ex is t ing paragraph 14 3.2.3 as 14 3.2.4. SUBSTANTIATION: Computer Fire models indicate that conditions in pods of less than 2500 sq f t may become untenable wi th in one minute of Flashover wi th in a ce l l , assuming the ce l l door is open to the pod. However, i f the provisions of 31-5.2 and 31-5.4 are s t r i c t l y adhered to, the ce l l may not be capable of f lashover. As such, the hazard whlch a small pod may represent is t o t a l l y dependent upon the a b i l i t y to achieve Flashover in the ce l l . COMMITTEE ACTION: Accept in Pr inc ip le .

Delete proposed 14-3.1.2(d) and i t s associated appendix note. Add an appendlx note to current 14-3.2.1 to read:

A-14-3.2.1 Furnishings are usual ly the f i r s t items igni ted in the detention and correct ional environment. The type, quanti ty and arrangement of f u rn i tu re and other combustibles are important Factors in determining how Fast the f i r e w i l l develop. Furnishings including upholstered items and wood items, such as wardrobes, desks and bookshelves, may provide s u f f i c i e n t fuel to resu l t in room Flashover. (Flashover refers to Full Fire involvement of a l l combustibles wi th in a room once su f f i c i en t heat has been b u i l t up wi th in the room.)

Combustible loading, in any room opening onto a resident ia l housing area, should be l imi ted to reduce the potential for room f lashover. Rooms in which Fuel loads are not cont ro l led, thereby creating a potent ia l For f lashover, should be considered hazardous areas. I f the separation option of 14 3.2.1 is selected, doors to such rooms including sleeping rooms should be se l f closing. COMMITTEE COMMENT: With respect to delet ing proposed 14-3.2.1(d) and i t s associated appendix note, see the Committee Action on Comment 101 33G on 14 3.1.2(d) (Log #486). Rather than adding a new 14-3.2.3, the Committee believes that current 14 3.2.1, dealing with protection of hazardous areas, already allows rooms with combustibles, w i th in res ident ia l housing areas, to be protected as hazardous areas. The new appendix note, suggested by the Committee, c l a r i f i e s the Committee's concern with combustible loadings that could resul t in room f lashover. The Committee Action should sat is fy the Commenter's in tent .

(Log #567) I01 - 338 - (14-3.5.5(a) ) : Accept SUBMITTER: Roll Jensen, P.E., James Ante l l , A . I .A . , Rol l Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-531 RECOMMENDATION: Revise 14-3.5.5(a) and 15-3.5.5(a) to read:

(a) Class I standpipe systems . . . " .

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SUBSTANTIATION: The s u b s t a n t i a t i o n f o r t he p r o p o s a l i n d i c a t e d t h a t t he Commi t tee i n t e n d e d t h a t 2 - I / 2 i n . hose be a v a i l a b l e i n any d e t e n t i o n and c o r r e c t i o n a l occupancy . T h i s s i z e hose i s u t i l i z e d by t he f i r e s e r v i c e . T y p i c a l l y , t he f i r e s e r v i c e b r i n g s i n t h e i r own hose wh i ch they know has been m a i n t a i n e d and t e s t e d , In most f u l l y s p r i n k l e r e d b u i l d i n g s , 2 - I / 2 i n . hose wou ld neve r have a use. I f t he Commi t tee i n t e n d s For s t a f f to u t i l i z e the 2 - I / 2 i n . hose f o r F i r e f l gh t l ng , extensive t ra in ing would be required.

The requirement For 2- I /2 in. hose would put an unnecessary burden on the design of the detention F a c i l i t y , e.g. , secure enclosures FOr hoses, and the level of maintenance required fo r periodlc test ing of hoses. COMMITTEE ACTION: Accept.

I The w o r d i n g w i l l t hen read : " ( a ) C lass I s t a n d p i p e sys tems s h a l l be p r o v i d e d

• . . , , .

(Log #395) I01 - 339 - ( 1 4 - 3 . 7 . 2 ) : Accep t i n P r i n c i p l e SUBMITTER: Kenneth Bush, Eas ton , MD COMMENT ON PROPOSAL NO.: 101-532 RECOMMENDATION: Rev ise 1 4 - 3 . 7 , 2 to r ead :

1 4 - 3 . 7 . 2 When smoke b a r r i e r s a re r e q u i r e d by 1 4 - 3 . 7 . 1 , a d d i t i o n a l smoke b a r r i e r s s h a l l be p r o v i d e d so as: . . . . SUBSTANTIATION: E d i t o r i a l , to use b e t t e r t e r m i n o l o g y . COMMITTEE ACTION: Accept i n P r i n c i p l e .

Do as Commenter has sugges ted bu t a l s o d e l e t e the word " a d d i t i o n a l " • COMMITTEE COMMENT: The Committee agrees that the revised wording proposed by the Commenter c l a r i f i e s and uses bet ter terminology but deleted the word "add i t iona l " as Further improvement.

(Log #568) I01 - 340 - ( 1 4 - 3 . 7 . 5 and 1 4 - 2 . 1 1 . 6 ) : R e j e c t SUBMITTER: R o l l Jensen, P . E . , James A n t e l l , A . I . A . , R o l l Jensen & A s s o c i a t e s , I n c . COMMENT ON PROPOSAL NO.: 101-540 RECOMMENDATION: R e j e c t p r o p o s a l . SUBSTANTIATION: S ince the Code p e r m i t s manual u n l o c k i n g o f e x i t s , i t shou ld a l s o p e r m i t manual u n l o c k i n g o f smoke b a f f l e r f o r c o n s i s t e n c y . D e t e n t i o n f a c i l i t i e s a re be lng des igned where inmates have c o n t r o l o v e r t h e i r r e s p e c t i v e c e l l d o o r . The doors unde r s t a f f c o n t r o l i n c l u d e the doors t h r o u g h smoke b a r r i e r s , h o r i z o n t a l e x l t s and o t h e r e x i t d o o r s . I f t he C o m m i t t e e ' s i n t e n t i s t o l i m i t the number o f i nma tes t h a t must be m a n u a l l y r e l e a s e d From c e l l s , t he E x c e p t i o n t o 14 2 . 1 1 . 6 shou ld be r e w r i t t e n , COMMITTEE ACTION: R e j e c t . COMMITTEE COMMENT: The Commi t tee b e l i e v e s t h a t smoke b a r r i e r s and e x i t s shou ld be t r e a t e d d i f f e r e n t l y . A smoke b a r r i e r a l l o w s h o r i z o n t a l movement to a secu re a rea v e r s u s an e x i t door wh i ch can a l l o w movement to an unsecu red o u t s i d e a rea . The smoke b a r r i e r doo r , i n o t h e r t han Use C o n d i t i o n V, s h o u l d no t be m a n u a l l y l o c k e d .

(Log #569) lOl - 341 - ( 1 4 - 4 . 2 , 14 4 . 3 ) : Accep t i n P a r t SUBMITTER: RolF Jensen, P . E . , James A n t e l l , A . I . A . , RolF Jensen & A s s o c i a t e s , I n c i COMMENT ON PROPOSAL NO.: 101-543 RECOMMENDATION: R e j e c t p r o p o s a l . SUBSTANTIATION: The h i g h r i s e p r o v i s i o n s were added by t h e Main Commi t tee w i t h no r e v i e w by t he S u b - c o m m i t t e e s . T h i s comment i s be ing s u b m i t t e d t o a l l o w t h e Sub -commi t t ee to r e v i e w t he p r o p o s a l and make changes t o c o i n c i d e w i t h t h e s p e c i f i c needs o f t he occupancy g roup . COMMITTEE ACTION: Accept i n P a r t .

See Commi t tee A c t i o n on Comment 101-342 on 1 4 - 4 . 3 (Log # 4 6 2 ) . COMMITTEE COMMENT: The Commi t tee A c t i o n and Commi t tee Comment on Comment 101-342 (Log #462) e x p l a i n t he C o m m i t t e e ' s t h i n k i n g on t h e s u b j e c t .

(Log #462) I01 - 342 - (14-4.3): Accept in Part SUBMITTER: William E. Koffel, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-543 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: We recognize that high-rise buildings present evacuation d i f f i c u l t i e s . However, detention and correctional occupancies are designed as a defend in place concept due to the d i f f i c u l t y in evacuation regardless of the building's height, The requirements proposed in Section 30-8 which are applicable to detention and correctional occupancies have already been incorporated into Chapter 14. In Fact, the Subcommittee reviewed the BCMC report and developed Subcommittee proposals accordingly. COMMITTEE ACTION: Accept in Part.

Do not reference Section 30 8 in ent irety, but insert a new 14-3.5.1 and appendix item A 14-3.5.1 and add a 14-4.3 cross r e fe rence as f o l l o w s :

14-3 .5 .1 H~gh r i s e b u i l d i n g s s h a l l comply w i th the au tomat i c s p r i n k l e r requ i rements o f 30 -8 .2 .

Renumber e x i s t i n g 14-3 .5 .1 and subsequent paragraphs as necessary.

A-14 3.5.1 For purposes o f p r o v i d i n g con t r o l va lves and water f l o w dev ices , m u l t i l e v e l r e s i d e n t i a l housing areas comply ing w i t h 14 3 .1 .2 are cons idered to be a s i n g l e f l o o r .

14-4.3 High Rise Buildings. See 14-3.5.1. COMMITTEE COMMENT: High rise detention and correctional occupancies, in general, need to be sprinklered. The other high rise provislons of proposed Section 30-8 are not needed as substantiated by the Commenter.

(Log #171 lOl - 343 - (14 4.3): Accept in Part ~UBMITTER: E. Eugene Mi l ler , C.M. Security Products, Inc. COMMENT ON PROPOSAL NO.: 101-543 RECOMMENDATION: Reject proposal. SUBSTANTIATION: This proposal is inappropriate for detention and correctional occupancies. COMMITTEE ACTION: Accept in Part.

See Committee Action on Comment I01-342 on 14-4.3 (Log #462). COMMITTEE COMMENT: The Committee Action and Committee Comment on Comment I01-342 (Log #462) explain the Committee's thinking on the subject.

(Log #381) lOl - 344 - (14-4.31: Accept in Part SUBMITTER: H.E. Nelson, NBS COMMENT ON PROPOSAL NO.: I01-543 RECOMMENDATION: Delete. SUBSTANTIATION: The requirements in Section 30-8 are inappropriate for detention and correctional occupancies. The proper protection For such occupancies, including those in high-rise building, is included in Chapters 14 and 15 without this cross reference. COMMITTEE ACTION: Accept in Part.

See Committee Action on Comment lOl 342 on 14-4.3 (Log #462). COMMITTEE COMMENT: The Committee Action and Commlttee Comment on Comment I01-342 (Log #462) explain the Committee's thinking on the subject.

(Log #505) 101 - 345 - (14-4,3): Accept in Part SUBMITTER: Mike Thompson, Gage Babcock & Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-543 RECOMMENDATION: Reject proposal I01-543. SUBSTANTIATION: There are many features in a detention and correctional occupancy that are not conducive to the high-rise requirements of Section 30-8. A sprinkler valve and water Flow device is not necessary on each f loor due to s ta f f supervision, and in many cases, sprinkler system designs in correctional f a c i l i t i e s are not conducive to f loor control valves and Flow switches, such as the "bird cage" sprinkler

system design used in many f a c i l i t i e s with stacked cells and t iers. Voice communication systems should not be provided because of restr icted egress of occupants. A two-way telephone system serves l i t t l e purpose due to communication systems installed for the security force. A central control station is generally provided for security Forces which encompass most of the features of Section 30-8.5. COMMITTEE ACTION: Accept in Part.

See Committee Action on Comment 101-342 on 14-4.3 (Log #462). COMMITTEE COMMENT: The Committee Action and Committee Comment on Comment I01-342 (Log #462) explain the Committee's thinking on the subject. Additionally, the sprinkler requirement applies only to new construction and, therefore, the requirement for f loor control valves and water Flow devices is important and necessary For annunciation of f loor level.

(Log #181) 101 346 - ( 14 -4 .31 : Accept SUBMITTER: John A. Sharry , Lawrence-L ivermore L a b o r a t o r i e s COMMENT ON PROPOSAL NO.: 101-543 RECOMMENDATION: I n s e r t , be fo re the ac tua l sentence w i t h the requ i remen t , a bo ld face type heading "H igh -R ise B u i l d i n g s . " SUBSTANTIATION: The bo ld face type heading w i l l c a l l a t t e n t i o n to the new requ i rement a~d set i t o f f as a separate sub jec t From the i tems which precede and f o l l o w i t . COMMITTEE ACTION: Accept. COMMITTEE COMMENT: Also see Committee Ac t i on on Comment 101-342 on 14-4.3 (Log #462).

(Log #164) 101 - 347 - ( 15 -2 .11 .91 : Accept SUBMITTER: John A. Shar ry , Lawrence-L ivermore L a b o r a t o r i e s COMMENT ON PROPOSAL NO.: I01 545 RECOMMENDATION: Dele te c u r r e n t 15 -2 .11 .9 . SUBSTANTIATION: The Committee Proposa l , on which t h i s comment is being made, places a l l the accep tab le means of egress components For t h i s occupancy and t h e i r assoc ia ted " s p e c i a l f e a t u r e s " t o g e t h e r in the 2.2 sec t i on o f t h i s occupancy chap te r . Some o f the proposed wording For t h i s expanded 2.2 s e c t i o n comes From the 2.11 Spec ia l Features p o r t i o n o f the c u r r e n t (1985 e d i t i o n ) chap te r . Wi thout the proposed d e l e t i o n s the requ i rements would appear tw ice and serve to confuse the user . COMMITTEE ACTION: Accept.

(Log #405) lOl - 348 - (15 3.1.1 Except ion No. 5) : Re jec t SUBMITTER: Harry Brad ley , H y a t t s v l l l e , MD COMMENT ON PROPOSAL NO.: 101-547 RECOMMENDATION: Delete 15-3 .1 .1 Excep t ion NO. 5. SUBSTANTIATION: This is not an Excep t i on . S t a i r s t h a t are to be enclosed as e x i t s are r e q u i r e d to be f u l l y enclosed by Chapter 5, but Chapter G pe rm i t s v e r t i c a l openings to be p ro tec ted by v e r t i c a l b a r r i e r s and does not n e c e s s a r i l y r e q u i r e a f u l l s h a f t ; f o r example, to be enclosed either at the top or at the bottom, thereby protecting the vertical openlng. Exception No. 5 is similar to an Exception that appears in health care that has similar problems, but unfortunately it is not open for comment during this comment period. COMMITTEE ACTION: Reject.

But editorially revise the TCR wording of Exception No. 5 so as to change the word "from" in the last line to "to" so as to read: ". . . from spreading to any other story" and correctly spell the word "impractical". COMMITTEE COMMENT: A stair, if not an exit, need not be enclosed per Chapter 5 and thus the Exception, which is a carry over From the current edition, is applicable. The editorial revisions are to track with the current (1985 edition) wording which was incorrectly copied.

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(Log #393) I01 - 349 - (15-3.7.2): Accept in Principle SUBMITTER: Kenneth Bush, Easton, MD COMMENT ON PROPOSAL NO.: I01-552 RECOMMENDATION: Revise 15-3.7.2 to read as follows:

15-3.7.2 When smoke barriers are required by 15-3.7,1 additional smoke barriers shall be provided so as . . . . SUBSTANTIATION: Editor ial to use better terminology. COMMITTEE ACTION: Accept in Principle.

Do as Commenter has suggested but also delete the word "addit ional". COMMITTEE COMMENT: The Committee agrees that the revised wording proposed by the Commenter c l a r i f i e s and uses better terminology but deleted the word "addit ional" as Further improvement.

(Log #570) IOl - 350 - (15-3.7.5, 15 2.11.6, E~ceptlon): Reject SUBMITTER: Roll Jensen, P.E., James Antel l , A.I.A., Roll Jansen & Associates, Inc. COMMENT ON PROPOSAL NO.: lOl 555 RECOMMENDATION: Delete the last sentence proposed For 15-3.7.5.

Delete the proposed addition to 15 2.11.6. SUBSTANTIATION: See comment to Proposal I01-540, 14-3.7.5 and 14-2.11.6 Exception. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action and Committee Comment on Comment I01 340 on 14-3.7.5 (Log #568) which explain the Committee's thinking on the subject.

(Log #49) I01 - 351 - ( 1 6 - 1 . 1 . 3 ) : Re jec t SUBMITTER: John A. Gannon, I n t e r n a t i o n a l Assn. o f F i re F igh te r s COMMENT ON PROPOSAL NO.: 10| 556 RECOMMENDATION: A l though I agree w l t h the Commi t tee 's d e c i s i o n to r e j e c t the p roposa l , I b e l i e v e the proposal ra i sed enough v a l i d po in t s to J u s t i f y an i n - d e p t h a n a l y s i s o f the evacua t ion concept versus the nonevacuat ion concept as a bas is For sav ing l i v e s when f i res occur in compartmented f i r e res is t ive buildings such as hospitals, hotels, dormitories and apartment housing. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee did an indepth analysis of this. The Committee established a task group to work on appendi~ notes re la t ive to this subject. The Committee stands on i ts or ig inal response to Proposal I01 556 (see page 371 in the TCR). The Committee stays with the rejection of the proposal as requested by the comment submitted but Feels that the indepth analysis has been done.

(Log #294) I01 - 352 - (16 1.5.1, 17 1.5.1, A 16.1.5.1, A-17-1.5.1): Reject SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: lOl 559 RECOMMENDATION: Return to Commlttee for fur ther study. SUBSTANTIATION: No substantiation is presented For change. Will result in enforcement problems given " l igh t hazard" c lass i f icat ion of these occupancies by NFPA 13. Fails to d i f fe ren t ia te between residential occupancies of a permanent nature (with an inherently greater fuel load) From those of a transient occupancy with an incidental fuel load. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that a hotel c lear ly has ordinary hazard contents as defined in 4-2.2.3. A sel f propagating Fire is c lear ly possible and the category of low hazard is therefore not appropriate. These c lassi f icat ions are not appropriate for the design of sprinkler systems, which are controlled by NFPA 13 and could, under that document be considered d i f ferent hazard levels.

(Log #217) I01 353 - (16-1.5.1, 17-1.5.1, A-IB.1.5. l , A-17-I.5.1): Reject SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-559 RECOMMENDATION : Add :

Exception: The contents of hotel guest rooms shall be classi f ied as low hazard in accordance with Section 4-2. SUBSTANTIATION: Hotel rooms with transient occupants do not contain s igni f icant storage associated with other types of residential occupancies houslng permanent occupants. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment I01-352 on IG-l.5.1, 17-1.5.1, A-16-1.5.l and A 17.1.5.I (Log #294).

(Log #571) I01 - 354 - (16-1.5.1, 17-1.5.1): Accept in Principle SUBMITTER: Roll Jensen, P.E., James Antel l , A.I.A., Roll Jensen& Associates, Inc. COMMENT ON PROPOSAL NO.: I01-559 RECOMMENDATION: Delete IG 1.5.I and 17-1.5.1. SUBSTANTIATION: Nowhere else in Chapter IG or 17 is the term "Ord lna ry Hazard" used. By r e f e r r i n g to the d e f i n i t i o n s in Chapter 4, the Code w i l l on ly c rea te con fus i on w i t h regard to NFPA 13 d e f i n i t i o n s . I f i t is decided t h a t t h i s t e x t must remain, the second sentence as pub l i shed in the 1985 L i f e Sa fe ty Code should be con t l nued . COMMITTEE ACTION: Accept in Principle.

To the end of IG 1.5.1 and 17-1.5.1, as shown in the TCR, add:

"For design of sprinkler systems, the c lass i f icat ion of contents in NFPA 13, Standard For the Ins ta l la t ion of Sprinkler Systems, shall apply." COMMITTEE COMMENT: Reinsertion of wording From the 1985 edit ion, dealing with c lass i f icat ion of contents per NFPA ]3 for sprinkler system design purposes, should sat isfy the Commenter's intent.

(Log #295) I01 355 (IG 2 .3 .2 , 1 7 - 2 . 3 . 2 ) : Re3ect SUBMITTER: T. Daly/H. Moore, H i l t o n Hote ls Corp. COMMENT ON PROPOSAL NO.: I01-567 RECOMMENDATION: Delete e n t i r e s e c t l o n . SUBSTANTIATION: E x i t l n g is not s imul taneous f rom street f loor and a l l e~its discharglng onto that level. Exiting is sequential. NO evidence is provlded to support change. Proposal is unworkable for exist lng buildings. Ignores concept of horizontal exi t ing within same building or to adjacent buildings. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This change was essentially an ed i tor ia l change from the pr ior edit ion of the Code and is not a new requirement. Deletion of the requirement would be cons idered new bus iness. I n s u f f i c i e n t s u b s t a n t i a t i o n has been p rov ided to change a long s tand ing p r o v i s i o n .

(Log #572) 101 - 356 - ( 1 6 - 2 . 3 . 2 , 1 7 - 2 . 3 . 2 ) : Reject SUBMITTER: R o l l Jensen, P .E . , James A n t e l l , A . I . A . , R o l l J e n s e n & Assoc ia tes , Inc. COMMENT ON PROPOSAL NO.: 101-567 RECOMMENDATION: Dele te t e x t e n t i r e l y . ~UBSTANTIATION: S t r e e t l e v e l e x i t s i z i n g is not s p e c i f i c ~ l l y a r e s i d e n t i a l occupancy i ssue . Th is should be addressed in Chapter 5, not in the r e s i d e n t i a l occupancy chap te r . Appa ren t l y , t he re has been no con fus ion For o the r occupancies, so the language is unnecessary. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment lot 355 on 16-2.3.2 and 17-2.3.2 (Log #295). Also note that mercantile and business occupancies have a s i m i l a r requ i remen t .

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(Log #573) I01 - 357 - (16-2.3.3) : Accept in Pr inc ip le $UBMITTER: Rolf Jensen, P.E., James An te l l , A . I .A . , Rol l Jensen & Associates, Inc. ~OMMENT ON PROPOSAL NO.: I01-568 RECOMMENDATION: Add Exception as fo l lows:

Exception: Corridors w i th in guest rooms or sui tes. SUBSTANTIATION: Some guest rooms and suites have areas which might be considered as corr idors. There is no need fo r a minimum width of 44 in. w i th in the sui te. COMMITTEE ACTION: Accept in Pr inc ip le .

Add an Exception to read: Exception: Corridors wi th in indiv idual guests rooms

or ind iv idual guest suites. Add an appendix note to read: A-16.2.3.3 Exception. This provision applies to

corr idors w i th in an ~ndividual room or sui te and does not apply where a sui te can be subdivided and rented separately. COMMITTEE COMMENT: The Committee agrees with the in tent of the Submitter but has revised the Exception and added an appendi< to c l a r i f y what the Committee fee ls is the in tent of the Exception.

(Log #574) I01 -- 358 - (16-2.6.2, 17-2.6.2): Accept SUBMITTER: Roll Jensen, P.E., James An te l l , A . I .A . , Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-578 RECOMMENDATION: Revise Exception to read:

Exception: 125 Ft (38.1 m) travel distance is allowed in bui ld ings protected by an automatic spr ink ler system in accordance with 16-3.5.1. ~UBSTANTIATION: Should read, " in accordance with 16-3.5.1." f o r the same reasons given by the Sub-committee For Proposal 576. The reasoning is to c l a r i f y that systems ins ta l led in accordance with 16-3.5.1 are e l i g i b l e for extended travel distances. COMMITTEE ACTION: Accept.

(Log #218) lOl - 359 - (16-2.10.2): Reject $UBMITTER: T. Daly/H. Moore, Hi l ton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-584 RECOMMENDATION: Return to Committee fo r fu r the r study. SUBSTANTIATION: Substantiat ion is incorrect . Ex i t locations must be posted wi th in each guestroom. (See Section 31-6.4 and Model Code Requirements). Signs w i l l su f fer damage and vandalism. This section should be coordinated with BCMC p r io r to enactment. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter has not explained why the substant iat ion is incorrect . The Committee Feels that th is sign w i l l assist occupants in determining exact ly what door is the ex i t . The cost of a luminescent sign compared to the benef i t is low. Regular ex i t signs are also subject to vandalism.

(Log #575) I01 - 360 - (16-2.10.2): Reject SUBMITTER: Roll Jensen, P.E., James An te l l , A . I .A . , Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: lOl 584 RECOMMENDATION: Reject proposal. ~UBSTANTIATION: Low level e x i t signs have not been j u s t i f i e d . The change ant ic ipates that the cor r idor has become smoke-logged p r io r to evacuation. I f the remainder of the Code is fol lowed, i t is un l i ke l y that the corr idor w i l l be smoke-logged. The change also envisions the s ta i rs to be at the end of a cor r idor . I f the entrance to the s ta i rs is perpendicular to the corr idor , the e x i t sign on the door w i l l accomplish l i t t l e purpose. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 101-359 on 16-2.10.2 (Log #218). Also, f i r es have occurred in bui ld ings that are essent ia l l y code complying and smoke has entered the corr idors . The Committee feels that the sign w i l l be benef ic ia l under the condit ions fo r which the sign is being required and may be even more benef ic ia l f o r ex i t s that are not at the end of the corridor.

(Log #576) lOl - 361 - (16-2.10.2): Reject SUBMITTER: Rolf Jensen, P.E., James Ante l l , A . I .A . , Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: ]01-584 RECOMMENDATION: Add an Exception as fo l lows:

Exception: Dormitories. SUBSTANTIATION: The substant iat ion given is that occupants are unfami l ia r with t he i r surroundings in hotels. An Exception fo r dormitor ies should be made since the occupants are Fami l iar with the e x i t locat ions. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Not a l l dormitor ies are in colleges and un ive rs i t i es . There are periods of time when f a m i l i a r i t y i s no t a lways t h e case such as f o r summer sessions and short courses. There can be a high turnover in cer ta in dormitor ies and depending on the bu i ld ing, the ex i ts may not be normally used and therefore not be obvious to the occupants.

(Log #165) 101 - 362 = (16-2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: 101-564 RECOMMENDATION: Delete a l l of current 16-2.11. SUBSTANTIATION: The Committee Proposal, on which th is comment is being made, places a l l the acceptable means of egress components For th ls occupancy and the i r associated "special features" together in the 2.2 section of th is occupancy chapter. Some of the proposed wording fo r th is expanded 2.2 section comes from the 2.11 Special Features port ion of the current (1985 edi t ion) chapter. Without the proposed delet ions the requirements would appear twice and serve to confuse the user• COMMITTEE ACTION: Accept•

(Log #396) I01 - 363 - (16-3.1.2): Reject SUBMITTER: Kenneth Bush, Easton, MD COMMENT ON PROPOSAL NO.: I01-587 RECOMMENDATION: Delete the proposed 16-2.7.2 in i t s en t i re ty . SUBSTANTIATION: Even as revised, paragraph is s t i l l unclear and the purpose of the paragraph is not evident. ~MMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee does not see the problem indicated by the Submitter.

(Log #296) 10] - 364 - (16-3.3.1(a) through (e) and 17-3.3.1(a) through (e) ) : Accept in Part in Pr inc ip le SUBMITTER: T. Daly/H. Moore, H i l ton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-589

• RECOMMENDATION: Revise " (b) " to read: (b) Corridors and lobbies open to corr idors when

such lobbies are at the level of e x i t discharge. SUBSTANTIATION: Not a l l lobbies in hotels are a part of the means of egress. COMMITTEE ACTION: Accept in Part in Pr inc ip le .

Revise 17-3.3.1(b) to read: (b) Corridors and lobbies that are part of an e x i t

access: A or B. ~O_MMITTEE COMMENT: The Committee sees no need to revise Chapter 16 as there was no change from the 1985 Code other than e d i t o r i a l . The Committee does agree that Chapter 17 does need to be revised as the change did increase the requirements which i t should not have. The change performed by the Committee should accomplish th is .

(Log #375) 101 - 365 - (16-3.3.2 and 17-3.3.2): Accept in Pr inc ip le SUBMITTER: T. Daly/H. Moore, Committee on Safety and Fire Protect ion - American Hotel and Motel Assoc. COMMENT ON PROPOSAL NO.: I01-591

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RECOMMENDATION: Revise to read: " I n t e r i o r f l o o r Finish in corr idors and ex i ts in

accordance with Section 6-5 and subject to the l im i ta t ions and modif icat ions therein, shall be Class I or Class I I . " SUBSTANTIATION: For consistency with 1G-3.3.1 and 17-3.3.1 and to indicate that Chapter 6 is the governing chapter on i n t e r i o r f i n i s h requirements. COMMITTEE ACTION: Accept in Pr inc ip le .

No change needed. COMMITTEE COMMENT: The wording in the proposed 1988 Code is consistent between 16-3.3.1 and 16-3.3.2 as well as between 17-3.3.1 and 17-3.3.2. Al l indicate that Section 6 S governs and therefore no change is needed.

(Log #290) 101 - 366 - (16-3.3.3) : Reject SUBMITTER: T. Daly/H. Moore, Hi l ton Hotels Corp. COMMENT ON PROPOSAL NO.: I01-592 RECOMMENDATION: Approve proposal as submitted. Action by Committee does not address proposal as submitted. Ac t i on to p lace in Chapter 31 is i n c o n s l s t e n t s ince comment meant f o r " p u b l i c areas" o f r e s i d e n t i a l occupancies on ly . SUBSTANTIATION: A p p l i c a t i o n o f NFPA 260B as suggested by Committee i s i n c o n s i s t e n t w i t h p roposa l . NFPA 260B requ i res a " t e s t to d e s t r u c t i o n " o f f u r n l t u r e in f i n a l form which is nei ther pract ical nor l i k e l y For small quantity purchases of fu rn i tu re . NFPA 260A F i l l s a vold when small quant i ty purchases are made by al lowing pre test ing of each component which can then be used again and again without Further test ing, thus enhancing Fire safety of these items when used in hotels. F l e x i b l l i t y should be provided to end users to implement e i ther standard depending on quanti ty of fu rn i tu re items purchased. Without such f l e x l b l l i t y i t is l i k e l y t h a t no improvement in f i r e s a f e t y o f upho ls te red F u r n i t u r e w i l l occur in those occupancles f o r small q u a n t i t y purchases. COMMITTEE ACTION; Re jec t . COMMITTEE COMMENT; Thls would r e q u i r e a l l f u r n i t u r e in a l l l o c a t i o n s to be tes ted in accordance w i t h NFPA 260A. The Committee Feels t h a t t h i s would r e s u l t in s i g n i f i c a n t enforcement d i f f i c u l t i e s . The Committee has put in an append ix note For a d v i s o r y purposes and t h i s note i n d i c a t e s the Commit tee 's p re fe rence to r e g u l a t e " p u b l i c a rea" f u r n i t u r e us ing the more c e r t a i n t e s t i n g o f NFPA 260B.

(Log #90) 101 367 - (16-3.5.1) : Accept in Pr inc ip le SUBMITTER: Matthew I . Chibbaro, Montgomery CO. MD Fire Marshal's Of f ice ~MMENT ON PROPOSAL NO.: 101 597 RECOMMENDATION: Retain the requirement fo r res ldent ia l l i s ted spr lnklers in new occupancies as per o r ig ina l recommendations. SUBSTANTIATION: Residential spr ink lers, unl ike others, are spec i f i ca l l y tested to maintain the t e n a b i l i t y in a compartment at a level which w i l l allow a sleeping occupant to survive. The cost fo r addit ional spr inklers and pipe is small compared to the overal l system cost and is more than o f fse t bj the increased l i f e safety. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise 16-3.5.1 by adding the Following sentence: "Sprinklers in guest rooms shall be e i ther approved

res ident ia l spr ink lers or approved quick response spr ink le rs . "

Delete A-16-3.5.1. COMMITTEE COMMENT: The Committee concurs with the Submitter but Feels ti~at in th is use, quick response spr inklers are also acceptable. The Committee Feels that in new construction, there is a d i s t l n c t l i f e safety advantage o f using res ident ia l spr ink lers or quick response spr ink lers in areas of high l i f e safety r isk .

(Log #406) I01 - 368 - (16-3 .5 . I ) : Accept in Pr inc ip le SUBMITTER: Harry Bradley, Hya t t sv i l l e , MD COMMENT ON PROPOSAL NO.: 101-597 RECOMMENDATION: Revise 16-3.5.1 Exception and 17-3.5.1 Exception to read:

Exception: Sprinkler i ns ta l l a t i ons may be omitted in clothes closets not over 24 sq f t (2.2 sq m) and bathrooms not over 55 sq f t (5.1 sq m). SUBSTANTIATION: The terms "small compartmented areas such as" have been deleted, since some archi tects have been including small mechanical rooms, small storage rooms, etc. as small compartmented areas. The Code has c lear ly , over the years, intended th is to apply to bathrooms and closets and not to other areas. To Further extend the use of th is Exception would only increase the c o n f l i c t with NFPA 13. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise the Exception to read: Exception: In guest rooms and in guest room suites,

spr ink le r i ns ta l l a t i ons may be omitted in closets not over 24 sq f t (2.2 sq m) and bathrooms not over 55 sq Ft (S.I sq m). COMMITTEE COMMENT: The Committee agrees with the general in tent of the Submitter. Since most of the rooms mentioned by the S u b m l t t e r are not in guest rooms, the Committee f e e l s the Committee suggested r e v i s i o n s are c l e a r e r and meet the i n t e n t o f the Subm i t t e r .

(Log #18) 101 - 369 - (16-3.5.1): Reject SUBMITTER: Buddy Dewar, Flor ida State Fire Marshal COMMENT ON PROPOSAL NO.: 101 597 RECOMMENDATION: Revise as Follows:

16-3.5.1 All hotels and dormitor ies shall be protected throughout by an approved automatic spr ink le r system ins ta l led in accordance with Section 7 7. SUBSTANTIATION: The L i fe Safety Code provides s i gn i f i can t incentives to i n s t a l l automatic spr ink le r systems but often the incentives are provided without the spr ink le r system ins ta l l ed . I t is v i r t u a l l y impossible to construct a high r ise hotel without spr ink le r systems. I t is imperative to enumerate s p e c i f i c a l l y that spr ink le r systems are required For a l l new hotels or dormitor ies. The Committee may wish to exempt hotels and dormitor ies that are two stor ies or below. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The intent of the comment goes way beyond the or ig ina l scope of Proposal I01-597. See Proposal I01-599 on 16-3.5.2 where the Committee is requi r ing new high r ise bui ld ings to be spr inklered. The Committee plans to discuss mandatory spr ink le r provisions fo r new low r ise and For ex is t ing hotels during the next Code cycle.

(Log #91) 101 - 370 - (16-3.5.1 Exception): Reject SUBMITTER: Matthew I . Chibbaro, Montgomery CO. MD Fire Marshal's Of f ice qOHMENT ON PROPOSAL NO.: 101-598 RECOMMENDATION: Retain the o r ig ina l recommendation in i t s en t i re ty . SUBSTANTIATION: The NFPA 13 section referenced is adequate j u s t i f i c a t i o n fo r the proposed change. The co l l ec t i ve experience which produced NFPA 13 should serve as the Fire record desired by the Residential Subcommittee. Add i t iona l l y , the c o n f l i c t between standards has created enforcement problems. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Comment on Proposal 101-598. Also, i t should be noted that "noncombustible" does not include gypsum board under the NFPA d e f i n i t i o n . This would be un rea l i s t i c in terms of th is Exception. Bathroom van i t ies would also create a problem.

330

(Log #89) lOl - 371 - (16-3.5.1 and 17 3.5.1): Reject SUBMITTER: Matthew I. Chibbaro, Montgomery CO. MD Fire Marshal's Office COMMENT ON PROPOSAL NO.: 101-587 RECOMMENDATION: Under the Exceptions to these paragraphs add:

"Closets which contain mechanical or electr ical equipment such as washers, dryers, Furnaces, heat pumps, or hot water heaters shall be sprinklered regardless of size." SUBSTANTIATION: The omission of sprinklers in closets is based on a small probabil i ty of Fire ignition such as in the case of clothes closets. This reasoning is not valid for closets containing the equipment l isted above. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that individual spaces need to be analysed on a case by case basis. AIso see Comment 101-368 on 16-3.5.1 (Log #406) which w i l l l imi t this Exception to guest rooms for new instal lat ions.

(Log #94) lOl - 372 - (IG-3.5.1, 17-3.5.l and A-17-3.5.1): Accept SUBMITTER: Marshall Klein, Marshall A. Klein & Assoc,, Inc. COMMENT ON PROPOSAL NO.: 101-597 RECOMMENDATION: Reinstate the Exception No. 2 and Appendix items in a l l the above noted proposal sections, which a l l relate to sprinklering these occupancies using the modified NFPA 13 c r i t e r i a outlined in these Exceptions. SUBSTANTIATION: The substantiation of the Main Committee on Safety to Life is that the sprinkler c r i t e r i a stated in this Exception No. 2 is "outside the scope of this document". I agree with the Subcommittee on Residential Occupancies that providing reasonable c r i t e r i a as outlined in this Exception w i l l encourage the use of sprinklers, and thereby increase the l i f e safety in these occupancies. Life safety is within the scope of the "Life Safety Code". This sprinkler Exception alternative is For l i f e safety, not property protection, and therefore is within the scope of the "Li fe Safety Code".

NFPA 13, A-4-1.1.1, states: "This standard contemplates Full sprinkler protection for al l areas. Other NFPA standards which mandate sprinkler instal lat ion may not require sprinklers in al l areas. The requirements of this standard should be used insofar as they are applicable. The authority having jur isdict ion should be consulted in each case." This statement in NFPA 13 shows recognition of the Fact that other NFPA standards ( i . e . , NFPA lOt) may modify sprinkler c r i t e r i a i f the need arises.

Without this reasonable modified sprinkler c r i t e r i a incorporated into the "Li fe Safety Code", sprinklers w i l l not be encouraged in a positive manner to be installed in these residential occupancies. I f we real ly want to provide the best l i f e safety tool we have available today, Exception No. 2 and the Appendix items should be placed into the Code. COMMITTEE ACTION: Accept.

(Log #297) 101 - 373 - (16-3.5.2): Accept SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-599 RECOMMENDATION: Revise to read:

" . . . in accordance with Section 16-3.5.I." SUBSTANTIATION: Section 16-3.5.1 references Section 7-7 but provides for specific Except10ns which would not be allowed in high rise buildings as currently written. COMMITTEE ACTION: Accept.

(Log #577) lot - 374 - (16-3.5.2): Reject SUBMITTER: Roll Oensen, P.E., James Antell, A.I.A., Rolf Oensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-599 RECOMMENDATION: Delete proposed text.

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SUBSTANTIATION: Proposed 16-4.2 w i l l contain requirements For high-rise buildings. There is no need to repeat high-rise provisions throughout the Chapter. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See action taken on Comment I01-378 on 16-4.2 (Log #$78).

(Log #287) lOl - 375 - (16-3.5.2): Reject SUBMITTER: Salvatore A. Gilardi, Jr . , American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: I01-599 RECOMMENDATION: Delete the word "high-rise" from this sentence and add the wording "with in te r io r corridors" to the sentence as to read:

"All buildings with in ter ior corridors shall be protected throughout by an automatic sprinkler system instal led in accordance with Section 7-7." SUBSTANTIATION: Just as the need for automatic sprinkler systems in high-rise hotels and dormitories is well documented and jus t i f i ed , so to is the need for sprinkler systems in low-rise hotels and dormitories with in ter ior corridors.

The Providence College f i r e , the Holiday Inn f i r e in Greece, NY, and the Holiday Inn Fire in Cambridge, Ohio, are only a Few examples where multiple f a t a l i t i e s (I0 in each Fire) have occurred in low-rise buildings with in ter ior corridors.

By requiring sprinkler Systems in high-rise buildings only, we are providing di f ferent levels of l i f e safety to an occupant on the sixth f loor (or any Floor below 75 f t ) of a high-rise building as opposed to that same person on the sixth Floor (or any Floor below 75 f t ) in a low-rise building.

The Committee has stated in i ts comments pertaining to Proposals 101-595 and I01-596 that "A f u l l y sprinklered building with single-station house powered smoke detectors in each sleeping room, provides a level of l i f e safety equivalent, i f not superior, to a nonsprinklered building which has corridor smoke detection in conjunction with single-station house powered detectors in each room."

I f the Committee Feels that a Fully sprinklered building may provide a superior level of l i f e safety as they stated, then this standard should re f lec t just that for a l l hotels and dormitories with in ter ior corridors, not just high-rise buildings. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: This comment introduces new material which has not had an opportunity for public review. The Committee plans to study the concept during the next Code cycle.

(Log #342) 101 - 376 - (16-3.5.3): Accept in Principle SUBMITTER: Donald W. Belles, Belles and ASSOC., Inc. COMMENT ON PROPOSAL NO:: 101-601 RECOMMENDATION: Revise paragraph 16-3.5.3 as Follows:

16-3.5.3 Open a i r parking structures which have not less than 25 percent of the total wall area open to atmosphere at each level u t i l i z ing at least two sides of the structure . . . Code. SUBSTANTIATION: I t is suggested the def in i t ion for open parking structures be altered to agree with NFPA Standard No. 88A which specifies a minimum of 25 percent of the total wall area be open to atmosphere at each level. COMMITTEE ACTION: Accept in Principle.

See action on Comment 101-377 on 16-3.5.3 (Log #276). COMMITTEE COMMENT: The action taken on Comment 101-377 Should sat isfy the intent of the Submitter.

(Log #276) I01 - 377 - (16-3.5.3): Accept in Principle SUBMITTER: Daniel M. McGee, American Iron and Steel Inst i tute COMMENT ON PROPOSAL NO.: 101-601 RECOMMENDATION: Revise proposed new section to read as Follows:

16-3.5.3 Open parking structures meeting the def in i t ion of an open parking structure as defined in NFPA BBA, Standard for Parking Structures need not be sprinklered under this Code.

SUBSTANTIATION: The proposed new Section 16 3.5.3 contained in the TCD is not in conformance with the current requirements of NFPA 88A, Standard for Parking Structures or the model codes. NFPA 88A contains a de f in i t i on of an open parking structure and requirements for separation from other occupancies. Every e f fo r t should be made to avoid creating conf l ic t ing requirements in d i f fe ren t standards. COMMITTEE ACTION: Accept in Principle.

Revise 16-3.5.3 to read as follows: 16-3.5.3 Open a i r parking structures complying with

NFPA 88A, Standard for Parking Sturctures, need not be sprinklered under this Code. COMMITTEE COMMENT: The Committee concurs, in general, with the Submitter but Feels that i f the remaining c r i t e r i a is to be deleted From NFPA I01, f u l l compliance, with NFPA 88A should be mandated.

(Log #19) I01 -- 382 - (17-3.5. I) : Reject SUBHITTER: Buddy Dewar, Florida State Fire Marshal COMMENT ON PROPOSAL NO.: I01-597 RECOMMENDATION: Revise as Follows:

17-3.5.1 All exist ing hotels and dormitories shall be protected throughout by an approved automatic sprinkler system installed within a reasonable time Frame acceptable to the authority having ju r isd ic t lon . SUBSTANTIATION: Same as others submitted by Commenter.

Local jur isd ic t ions should be allowed to negotiate compliance dates. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment 101-369 on 16-3,5.1 (Log #18) .

(Log #578) 101 - 378 - (16-4.2): Accept ~UBMITTER: RolF Jensen, P.E., James Antel l , A.I .A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-608

I RECOMMENDATION: proposal. Reject SUBSTANTIATION: The high-rise provisions were added by the Main Committee with no review by the Sub-committees. This comment is being submitted to allow the Sub-committee to review the proposal and make changes to coincide with the specif ic needs of the OCCupancy group. COMMITTEE ACTION: Accept.

(Log #182) 101 - 379 - (16~4.2): Reject yUBHITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: lOI-G08 RECOMMENDATION: Insert, before the actual sentence w~th the requirement, a boldface type heading "High Rise Buildings." SUBSTANTIATION: The boldface type heading w111 call attention to the new requirement and set i t o f f as a separate subject from the items which precede and Follow i t . COMMITTEE ACTION: Reject. COMMITTEE COHMENIT: See action on Comment 101-378 on 16-4.2 (Log #578),

(Log #407) 101 - 380 - (17-2.7.3): Accept ~UBMITTER: Harry Bradley, Hyattsvi l le, MD COMMENT ON PROPOSAL NO.: 101--G14 RECOMMENDATION: Revise "250 f t " to "150 Ft (45.7 m)" and revise "200 f t " to "100 Ft (30.5 m)". SUBSTANTIATION: The present Code l imi ts travel distance in nonsprinklered buildings to tO0 f t and in sprinklered buildings to 150 f t . , therefore, no part of a lobby in a hotel can be further than this From a door and i t is unreasonable to allow people discharging from an ex i t to be more than this distance From the ex i t door on the lobby Floor. COMMITTEE ACTION: Accept.

(Log #166) I01 - 381 - (17-2.11): Accept $UBMITTER: John A. Sharry, Lawrence--Livermore Laboratories COMMENT ON PROPOSAL NO.: lOI-611

I RECOMMENDATION: Delete a l l current 17-2.11. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places a l l the acceptable means of egress components For this occupancy and the i r associated "special features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording for th is expanded 2.2 section comes From the 2.11 Special Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #167) 101 383 - (18-2.11.2): Accept yUBHITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-611 RECOHMENDATION: Delete al l of current 18-2.11 e~cept 18-2.11.2. SUBSTANTIATION: The Committee Proposal, on whlch this comment is being made, places al l the acceptable means of egress components For this occupancy and thelr associated "special Features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording For this expanded 2.2 section comes From the 2.11 Special Features portion of the current (1985 edit ion) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. ~OHHITTEE ACTION: Accept,

Editors Note: 18 2.11.2 no longer exists in the 1988 Code, therefore a l l of 18-2.11 w i l l be deleted.

(Log #579) I01 - 384 - (18-3.1.2 Exception No. 1): Accept in Principle SUBMITTER: Rolf Jensen, P.E., James Antel l , A.I.A.. Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-GG2. RECOMMENDATION: Retain Exception No. I. SUBSTANTIATION: The Exception should be retained. No loss record has shown that the lack of elevator lobbies in sprlnklered buildings has been a problem. COMMITTEE ACTION: Accept in Principle.

I Delete 18-3.1.2. COMMITTEE COMMENT: Since high rise buildings are required to be sprinklered the E~ceptlon would always apply and therefore this becomes a nonrequirement.

(Log #33) 101 - 385 - (18-3.4.3.3 Exception): Reject SUBHITTER: Joseph A. Drouin, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO.: 101-672 RECOMMENDATION: The proponents proposal to delete the Exception should be accepted. SUBSTANTIATION: A voice communlcation SyStem ~s an ef fect ive means of providing instructions to building occupants during a Fire situation. Although people may be Familiar w~th the building, they have a tendency to panic during a Fire situation and do not act in a rational manner. Voice instructions w i l l assist them during this panic situation. The BOCA National Building Code and the Uniform Building Code presently require a voice communication system for apartment houses 75 Feet and over. BCHC also recommends such a system. In the interest of l i f e safety and uniformity the Exception should be deleted. COMMITTEE ACTION: Reject. ~OHHITTEE COMMENT: The Committee stands on i ts comment to Proposal 101-672 (page 386 in the TCR). The Submitter has not provided suf f l c ien t j u s t i f i c a t i o n to change the Committee's opinion. The use, or proper use, of such systems in these buildings is questionable.

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(Log #601) 101 - 386 - (18-3.5.1): Accept in Principle SUBMITTER: Matthew I. Chibbaro, Montgomery CO. MD Fire Marshal's Office COMMENT ON PROPOSAL NO.: I01-674 RECOMMENDATION: Retain the requirement for residential l is ted sprinklers in new occupancies as per or ig inal recommendations. SUBSTANTIATION: Residential sprinklers, unlike others, are spec i f ica l ly tested to maintain the tenab i l i t y in a compartment at a level which w i l l allow a sleeping occupant to survive. The cost for additional sprinklers and pipe is small compared to the overall system cost and is more than of fset by the increased l i f e safety. qOMMITTEE ACTION: Accept in Principle.

Revise 18-3.5.1 by adding the following sentence: "Sprinklers in l i v ing units shall be approved

residential type Fast response sprinkers." Delete A-18-3.5.1.

COMMITTEE COMMENT: The Committee concurs with the Submitter, that in new construction, residential sprinklers w i l l provide a s igni f icant l i f e safety benefit.

(Log #408) 101 - 387 - (18-3.5.1 Exception and 19-3.5.1 Exception): Accept in Principle SUBMITTER: Harry Bradley, Hyat tswl le , MD COMMENT ON PROPOSAL NO~: I01-674 RECOMMENDATION: Revise 18-3.5.1 Exception to read:

Exception: Sprinkler ins ta l la t ion may be omitted in clothes closets not over 12 sq f t (1.1 sq m) and bathrooms not over 55 sq f t (5.I sq m).

Revise 19-3.5.1 to read: Exception: Sprinkler insta l la t ions may be omitted in

clothes closets not over 24 sq f t (2.2 sq m) and bathrooms not over 55 sq f t (5.1 sq m). SUBSTANTIATION: The Exception For new buildings has been revised by deleting "small compartmented areas such as." Many architects are start ing to expand this Exception into many areas that were not o r i g ina l l y intended by the Committee, including mechanical rooms, storage rooms and simi lar areas. This only fur ther exacerbates the conf l i c t with NFPA 13 and should not be endorsed by the Committee. The revision to Chapter 19 has been returned to the or iginal text of the 1985 edit ion of the Code, as the reduction ~n closet s~ze is not of su f f i c ien t j us t i f i ca t i on to warrant r e t r o f i t t l n g in exist ing buildings.

I t should be remembered that sprinkler ins ta l la t ion being rehabbed Into existing bulld~ngs must comply with the requirements for new construction and, therefore, the larger closet sizes would not prevall any fur ther but would be allowed to be maintained that way ~n exist ing buildings. qOMMITTEE ACTION: Accept in Principle.

Revise 18-3.5.1 Exception to read: Exception: In individual l i v ing units, spr inkler

ins ta l la t ion may be omitted in closets not over 12 sq f t ( I . I sq m) and bathrooms not over 55 sq f t (5.1 sq m).

Revise 19-3.5.I Exception to read: Exception: In individual l i v ing units, spr inkler

insta l la t ions may be omitted in closets not over 24 sq f t (2.2 sq m) and bathrooms not over 55 sq Ft (5.I sq m). COMMITTEE COMMENT: The Committee concurs with the general intent of the Submitter. The modlfications made should s t i l l meet the general intent of the Submitter.

(Log #602) 101 - 388 - (18-3.5.1 and 19-3.S.I): Accept ~n Principle SUBMITTER: Matthew I. Chibbaro, Montgomery CO. MD Fire Marshal's Office qOMMENT ON PROPOSAL NO.: 101-674 RECOMMENDATION: Under the Exceptions to these paragraphs add:

"Closets which contain mechanical or e lect r ica l equipment such as washers, dryers, furnaces, heat pumps, or hot water heaters shall be sprinklered regardless of size."

SUBSTANTIATION: The omission of sprinklers in closets is based on a small probabi l i ty of f i r e ign i t ion such as in the case of clothes closets. This reasoning is not val id for closets containing the equipment l is ted above. COMMITTEE ACTION: Accept in Principle.

Add the following sentence to 18-3.5.1 Exception No. I and 19-3.5.1 Exception No. I . :

"Closets which contain equipment such as washers, dryers, furnaces on water heaters shall be sprinklered regardless of size." COMMITTEE COMMENT: The Committee agrees in general with the Submitter but has made changes to make the provisions more generic.

(Log #603) 101 - 389 - (18-3.5.1 and 19-3.5.I): Accept SUBMITTER: Marshall Klein, Marshall A. Klein & Assoc., Inc. COMMENT ON PROPOSAL NO.: I01-674 RECOMMENDATION: Reinstate the Exception No. 2 and Appendix items in a l l the above noted proposal sections, which a l l relate to sprinklering these occupancies using the modified NFPA 13 c r i t e r i a outlined in these Exceptions. SUBSTANTIATION: The substantiation of the Main Committee on Safety to Life is that the sprinkler c r i t e r i a stated in this E~ception No. 2 is "outside the scope of this document". I agree with the Subcommittee on Residential Occupancies that providing reasonable c r i t e r i a as outllned in th~s Exception w i l l encourage the use of sprlnklers, and thereby increase the l i f e safety in these occupancies. Life safety is within the scope of the "Li fe Safety Code". This sprinkler Exception al ternat ive is For l i f e safety, not property protectlon, and therefore is within the Scope of the "Life Safety Code".

NFPA 13, A-4-1.1.1, states: "This standard contemplates Full sprlnkler protection for a l l areas. Other NFPA standards which mandate sprinkler ins ta l la t ion may not require sprinklers in a l l areas. The requirements of this standard should be used insofar as they are applicable. The authority havlng ju r i sd ic t ion should be consulted in each case." Th~s statement in NFPA 13 shows recognition of the fact that other NFPA standards ( i . e . , NFPA I01) may modify sprinkler c r i t e r i a i f the need arises.

Without this reasonable modified spr inkler c r i t e r i a incorporated into the "Li fe Safety Code", sprinklers w i l l not be encouraged in a positive manner to be ~nstalled in these residential occupancies. I f we real ly want to provide the best l i f e safety tool we have available today, Exception No. 2 and the Appendix items should be placed into the Code. COMMITTEE ACTION: Accept.

( L o g # 9 2 ) 101 - 390 - ( 1 8 - 3 . 5 . 4 E x c e p t i o n ) : R e j e c t SUBMITTER: Matthew I. Ch~bbaro, Montgomery CO. MD Fire Marshal's Office COMMENT ON PROPOSAL NO.: I01-675, 676 RECOMMENDATION: Retain the original recommendations in thei r ent i rety. (Deletlon of Exception.) SUBSTANTIATION: The Fact that no such Exception exists in NFPA 13 is adequate j u s t i f i c a t i o n for the proposal when coupled with the substantiation of the or ig inal Submitters. The col lect ive experience which produced NFPA 13 should serve as the Fire record desired by the Residential Subcommittee. Addit ionally, the conf l i c t between standards has created enforcement problems. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee is not aware of any problems with f~re f a t a l i t i e s involving these Exceptions. The Committee does not see th is as a conf l i c t with NFPA 13. See A-4-1.1.l of NFPA 13.

333

(Log #277) I01 - 391 (18-3.5.7) : Accept in Pr inc ip le SUBMITTER: Daniel H. McGee, American Iron and Steel I n s t i t u t e COMMENT ON PROPOSAL NO.: 101-678 RECOMMENDATION: Revise proposed new section to read as fol lows:

18 3 . 5 . 7 Open parking structures meeting the d e f i n i t i o n of an open parking structure as defined in NFPA 88A, Standard fo r Parking Structures need not be sprinklered under th is Code. SUBSTANTIATION: The proposed new Section 16-3.5.3 contained in the TCD is not in conformance with the current requirements of NFPA 88A, Standard fo r Parking Structures or the model codes. NFPA 88A contains a d e f i n i t i o n of an open parking structure and requirements fo r separation from other occupancies. Every e f f o r t should be made to avoid creating con f l i c t i ng requirements in d i f f e ren t standards. COMMITTEE ACTION: Accept in Pr inc ip le .

Revise 18-3.5.7 to read: Open a i r parking structures complying with NFPA 88A,

Standard fo r Parking Structures, need not be sprinklered under th is Code. COMMITTEE COMMENT: The Committee concurs, in general, with the Submitter but feels that i f the remaining c r i t e r i a is to be deleted From NFPA I01, f u l l compliance, with NFPA 88A should be mandated,

(Log #183) I01 392 - ( 1 8 - 4 . 2 ) : Reject SUBHITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: I01 686 RECOMMENDATION: Inser t , before the actual sentence with the requirement, a boldface type heading "High Rise Bui ld ings." SUBSTANTIATION: The boldface type heading w i l l ca l l a t tent ion to the new requirement and set i t o f f as a separate subject from the items which precede and fo l low i t . COMMITTEE ACTION: Reject. COMMITTEE COHMENT: See action taken on I01-393 on 18-4.2 (Log #580).

(Log #580) 101 393 - (18-4.2): Accept SUBHITTER: Rolf Jensen, P.E., James Ante l l , A . I .A . , Rol l Jansen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-686

I RECOMMENDATION: Reject proposal. SUBSTANTIATION: The h igh-r ise provisions were added by the Main Committee with no review by the Sub-committees. Th~s comment is being submitted to al low the Sub committee to review the proposal and make changes to coincide with the spec i f ic needs of the occupancy group. COMMITTEE ACTION: Accept.

(Log #168) I01 - 394 - (19 2.2): Accept SUBMZTTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01 688 RECOMMENDATION: Delete all of current 19-2.11 except 19-2.11.2. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places all the acceptable means of egress components for this occupancy and their associated "special features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording for this expanded 2.2 section comes from the 2.11 Special Features portion of the current (1985 edi t ion) chapter. Without the proposed delet ions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #410) 101 - 395 - (19-2.7.3) : Accept SUBMITTER: Harry Bradley, Hya t t sv i l l e , HD COMMENT ON PROPOSAL NO.: 101-692 RECOMMENDATION: In 19-2.7.3 change "250 f t " to be "150 f t (45.7 m)" and change "200 f t " to "lO0 f t (30.5 m)". SUBSTANTIATI~: The present Code l i m i t s travel distance to I00 f t and 150 f t in nonsprinklered and sprinklered bui ldings respect ive ly , therefore, no point in the lobby Floor can be more than that distance From an ex i t and to al low an e x i t which discharges on a lobby Floor to be fu r ther away From an e x i t than that is un jus t i f i ed . COMMITTEE ACTION: Accept.

(Log #34) 101 - 396 - (20-3.3.1 Exception No. 2): Reject SUBMITTER: Joseph A. Drouin, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO.: 101-709 RECOMMENDATION: The proposal by the proponent to delete Exception No. 2 should be accepted. SUBSTANTIATION: A spr ink le r system should not negate the requirement of a f i r e alarm system. Manual stations should be provided to al low lodgers to act ivate the Fire alarm system to warn other occupants of a f i r e s i tua t ion . The major l ty of f i r e s are detected by people, and the a b i l i t y to a le r t other occupants Is p a r t i c u l a r l y important in a smouldering Fire - the most common type of f l r e in a res ident ia l occupancy - where condit ions may be in to lerab le before the spr lnk ler act ivates. ~OHHITTEE ACTION: Reject. COMMITTEE COMMENT: See Proposal I01-707 on 20-3.3.] Exception No. 2 and 20-3,3.2 (New). The Committee does not see a need fo r a f u l l y spr inklered lodging and rooming house with every level smoke detection to have m a n u a l f i r e a l a r m s t a t i o n s .

(Log #411) I01 - 397 - (20-3.5): Accept in Pr inc ip le SUBHITTER: Harry Bradley, Hya t t sv i l l e , MD COMMENT ON PROPOSAL NO.: I01-712 RECOMMENDATION: Revise 20 3.5 to read as fo l lows:

20-3.5 Extinguishment Requirements. 20-3.5.1 When an automatic spr ink le r system is

required, or is used as an a l te rna t i ve method of protect ion, e i ther fo r to ta l or pa r t ia l bui ld ing coverage, the system shall be ins ta l led in accordance wlth Section 7 7 and shall act ivate the Fire alarm system in accordance with Section 7-6.

Exception No. l : Spr ink ler i ns ta l l a t i ons may be omitted in clothes closets not over 12 sq f t (1. I sq m) and bathrooms not over 55 sq Ft (5.1 sq m).

Exception No. 2: In ex is t ing lodging and rooming houses, spr ink le r i n s t a l l a t i o n may be omitted in clothes closets not over 24 sq gt (2,2 sq m) and bathrooms not over 55 sq Ft (5.1 sq m).

Exceptlon No. 3: In bui ld ings where character is t ics of the occupancy are comparable with res ident ia l f i r e potent ia ls , a spr ink le r system complying with NFPA 130, Standard For the I n s t a l l a t i o n of Spr inkler Systems in One- and Two Family Dwellings and Mobile Homes may be used. SUBSTANTIATION: The two proposals, I01 712 and I01 7|3 address the same subject but in a d i f f e r e n t manner and the f i na l determination of the Committee was not evident ~n the Committee Action. The intent of th is comment is to ( I ) bring the two actlons together, (2) d e l e t e t h e " s m a l l c o m p a r t m e n t e d a r e a s s u c h a s " as t h i s is being expanded unnecessarily and increases the c o n f l i c t with NFPA 13, (3) re ta in the Exception For small closets as in the present Code as there is i n s u f f i c i e n t j u s t i f i c a t i o n to make th is a re t roac t ive provision and (4) to restore a concept which has been used fo r many years of using 13D in these small res ident ia l occupancies. Restr ic t ing th is to eight people is not j u s t i f i e d as the nature of these f a c i l i t i e s is s im i la r to a one- and two-family dwell ing. The Committee may consider the n e e d to revise th is Exception by adding "provided a l l habitable areas and closets are spr ink lered" such as appeared fo r the small board and care f a c i l i t i e s which contain people impractical to evacuate.

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~OMMITTEE ACTION: Accept in Pr inc ip le . In proposed Exception Nos. 1 and 2 delete "c lothes".

Do not add Exception No. 3. COMMITTEE COMMENT: The Committee concurs with the Submitter but feels that the action taken on Comment 101-400 on 20-3.5 (Log #604) and Comment I01-570 on A-20-I.5.1 (Log #404) are more appropriate than the suggested Exception No. 3.

(Log #444) I01 - 398 - (20-3.5): Accept in Pr inc ip le SUBMITTER: Bob Bat t les, NeAPRFMR COMMENT ON PROPOSAL NO.: lOI-Tl3 RECOMMENDATION: Revised 20-3.5 Exception*:

ExceptionS: In bui ld ings where there are not more than 15 boarders, a sp r ink le r system complying with NFPA 13D, Standard For the I ns ta l l a t i on of Spr inkler Systems in One and Two Family Dwellings and Mobile Homes, may be used. SUBSTANTIATION: T h i s r e v i s i o n a l l o w s For " g r a n d f a t h e r i n g " homes s e r v i n g 9 to 15 persons t h a t have a l r e a d y i n s t a l l e d a 13D sys tem. COMMITTEE ACTION: Accep t i n P r i n c i p l e .

See Comment 101-400 on 2 0 - 3 . 5 (Log #604 ) . COMMITTEE COMMENT: The a c t i o n taken on Comment I 0 1 - 4 0 0 s h o u l d s a t i s f y the i n t e n t o f t he S u b m i t t e r .

(Log #547) lOl - 399 - (20-3.5): Accept in Pr lnc ip le SUBMITTER: Roll Jensen, P.E., James Ante l l , A . I .A . , Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-712 & 713 RECOMMENDATION: Proposals 712 and 713 were both approved but read d i f f e r e n t l y . This needs to be resolved. SUBSTANTIATION: None. COMMITTEE ACTION: Accept in Pr inc ip le .

See action on Comment I01-397 on 20-3.5 (Log #411). COMMITTEE COMMENT: The action taken on Comment lOl 397 (Log #411) should sa t i s f y the in tent of the Submltter.

(Log #604) I01 - 400 - ( 2 0 - 3 . 5 ) : Accep t SUBMITTER: M a r s h a l l K l e i n , M a r s h a l l A. K l e i n & A s s o c . , I n c . COMMENT ON PROPOSAL NO.: 101-712

I " RECOMMENDATION: Reinstate the Exception No. 2 and

in a l l the above noted proposal sections, which a l l re la te to spr ink ler ing these occupancies using the modified NFPA 13 c r i t e r i a out l ined in these Exceptions. SUBSTANTIATION: The substant iat ion of the Main Committee on Safety to L i fe is that the spr ink le r c r i t e r i a stated in th is Exception No. 2 ~s "outside the scope of th is document". I agree w~th the Subcommittee on Residential Occupancies that providing reasonable c r i t e r i a as out l ined in th is Exception w~ll encourage the use of spr ink lers , and thereby increase the l~fe safety in these occupancies. L i fe safety is wi th in the scope of the "L i fe Safety Code". This spr ink le r Exception a l te rna t i ve is fo r l i f e safety, not property protect ion, and therefore is wi th in the scope of the "L i fe Safety Code".

NFPA 13, A-4-1.1.1, states: "This standard contemplates Full sp r ink le r protect ion fo r a l l areas. Other NFPA standards which mandate spr ink ler i n s t a l l a t i o n may not require spr ink lers in a l l areas. The requirements of th is standard should be used insofar as they are appl icable. The author i ty having j u r i s d i c t i o n should be consulted in each case." This statement in NFPA 13 shows recognit ion of the Fact that other NFPA standards ( i . e . , NFPA lOl) may modify spr ink le r c r i t e r i a i f the need arises.

Without th is reasonable modified spr ink ler c r i t e r i a incorporated into the "L i fe Safety Code", spr ink lers w i l l not be encouraged in a posi t ive manner to be ins ta l led in these res ident ia l occupancies. I f we rea l l y want to provide the best l i f e safety tool we have avai lable today, Exception No. 2 and the Appendix items should be placed in to the Code. qOMMITTEE ACTION: Accept.

(Log #463) I01 - 401 - (21-2 of p repr in t ) : Accept in Pr inc ip le SUBMITTER: William E. KoFFel, American Health Care Assn. COMMENT ON PROPOSAL NO.: I01 721 RECOMMENDATION: Replace the t e r m "bed room" w i t h " s l e e p i n g room" and t he te rm " d w e l l i n g u n i t " w i t h " F a c i l i t y " . SUBSTANTIATION: E d i t o r i a l r e v i s i o n . Bedroom appears i n 2 1 - 2 . 2 . 1 , E x c e p t i o n No. 1 and 2 1 - 2 . 2 . 1 , E x c e p t i o n No. 2, ( d ) . The use o f "bedroom' i n 21 2 . 3 . 6 . 1 , E x c e p t i o n No. 4 shou ld be r e t a i n e d For c l a r i t y . Dwelling uni t appears in 21-2.2.1, Exception NO. 3. COMMITTEE ACTION: Accept ~n Pr inc ip le .

Do as proposed by the Submitter but do not change "bedroom" in 21-3.6.1 Exception 4. COMMITTEE COMMENT: The Committee concurs with the Submitter and as indicated in the substant iat ion the change should not be made in 21-2.3.6.1 Exception No. 4.

(Log #415) 101 - 402 (21 2 . 2 ) : Accept i n P r i n c i p l e SUBMITTER: H a r r y B r a d l e y , H y a t t s v l l l e , HD COMMENT ON PROPOSAL NO.: 101-721 RECOMMENDATION: Rev ise 2 1 - 2 . 2 to read as f o l l o w s

21 2 .2 Means o f Escape. 2 1 - 2 . 2 . 1 P r i m a r y Means o£ Escape. Eve ry s leepTng

room and l i v i n g a rea s h a l l have access t o a p r i m a r y means o f escape so l o c a t e d as to p r o v i d e a s a f e pa th o f t r a v e l to the o u t s i d e o f t he b u i l d i n g w i t h o u t t r a v e r s i n g any c o r r i d o r , o r o t h e r Space, exposed to u n p r o t e c t e d v e r t i c a l o p e n i n g s . A l s o In s l ow and i m p r a c t i c a l F a c i l i t i e s , t h i s p r l m a r y means o f escape s h a l l no t be exposed to common l i v i n g spaces such as l i v i n g rooms and k i t c h e n s . When s l e e p i n g rooms or- l i v i n g areas a re above o r be low the l e v e l o f e x i t d i s c h a r g e , the p r i m a r y means o f escape s h a l l be an enc losed i n t e r i o r s t a i r , e < t e r i o r s t a i r , h o r i z o n t a l e x i t , o r an e x i s t i n g F i r e escape s t a i r .

2 1 - 2 . 2 . 2 Secondary Means o f Escape. In a d d i t i o n to t he p r i m a r y r o u t e , each s l e e p i n g room and l l v i n g a rea s h a l l have a second means o f escape o r a l t e r n a t e p r o t e c t i o n wh ich c o n s i s t s o f one o f t he f o l l o w i n g '

(a ) A door , s t a i r w a y , passage o r h a l l p r o v i d i n g a way, i ndependen t o f and remote From the p r i m a r y means o f escape, o f u n o b s t r u c t e d t r a v e l to the o u t s l d e o f t he d w e l l i n g a t s : r e e t o r g round l e v e l .

(b ) A passage t h r o u g h a d j a c e n t n o n l o c k a b l e spaces i n d e p e n d e n t 07 , and remote f r om, the p r i m a r y means o f escape to any approved means of escape.

(c) An outside window or door operable From the inside without the use of tools and providing a clear opening of no~ less than 20 in. (50.8 cm) in width, 24 in. (61 cm) in height and 5,7 sq ft (.53 sq m) in area. The bottom of the opening shall not be more than 44 in. (112 cm) off the Floor. Such means of escape shall be acceptable if:

(I) the window is wlthin 20 ft (6.1 m) of grade or, (2) the window is directly accessible to Fire

department rescue apparatus as approved by the authority havlng jurisdiction, or

(3) the window or door opens onto an exterior balcony.

(d) The bedroom or living areas shall be separated from all othe ~ parts of the living unit by construction having a fire resistance rating of least 20 minutes and shall be equipped with a door that will resist passage of fire For at least twenty minutes and is designed and installed to minimize smoke leakage. A means of providing smoke venting and fresh air to the occupants shall be provided.

Exception No. I: IF the bedroom or living area has a door leading directly outside of the building with access to g rade , o r to a s t a i r w a y t h a t meets t he requirements For exterior stairs ~n 21-2.3.1.2, that means of escape shall be considered as meeting all the escape requirements For the sleeping room or living area.

Exception No. 2: A second means of escape or alternate protection from each sleeping room or living area is not required where the dwelling unit is protected throughout by an approved automatic sprlnkler system complying with 21-2.3.5.

Exception NO. 3: Exist ing approved means of escape may be continued in service.

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21-2.2.3 Number of Hearts of Escape, Every slow and every impractical Facility shall have at least two r e m o t e l y l o c a t e d means o f escape t h a t do no t i n v o l v e w indows. At l e a s t one o f t h e s e means o f escape s h a l l comp ly w i t h 2 1 - 2 . 2 . 1 .

2 1 - 2 . 2 . 4 Enc losed I n t e r i o r S t a i r s . I n t e r i o r s t a i r w a y s s h a l l be e n c l o s e d w i t h t w e n t y m i n u t e F i r e b a r r i e r s w i t h a l l o p e n i n g s p r o t e c t e d w i t h smoke actuated automatic or se l f - c los ing doors having a Fire resistance comparable to that required fo r the enclosure. Stairways shal l comply with 5-2.2.3.4.

Exception No. l : Sta i rs connecting two levels only may be open to other than the s t reet Floor.

Exception No. 2: In prompt and slow F a c i l i t i e s , stairways may be unprotected in accordance with the Exception to 21-2.3 .1 . I .

21-2.2.5 Doors. Following th i s , renumber 21-2.2.3.1 and a l l subsequent paragraphs up to and including 21-2.2.5 as printed in the prepr in t . SUBSTANTIATION: This comment is to clean up the prepr in t regarding Section 21-2.2. The prepr in t did not bring in a l l the material From the ex is t ing Chapter 20 nor from the ex is t ing escape provis ion of 21-2 as indicated in Proposal 101=721. Some minor ed i t o r i a l provisions are also included in order to c l a r i f y the mix of provisions. No technical changes are intended by th is comment. ~OMMITTEE ACTION: Accept in Pr inc ip le .

Revise 21-2.2 to read as fo l lows: 21-2.2 Means of Escape. 21-2.2.1 Number of Means of Escape. Every f a c i l i t y

shal l have at least two remotely located means of escape t h a t do no t i n v o l v e windows f r o m each n o r m a l l y occupied story. At least one of these means of escape shall comply with 21 2.2.2.

Exception NO. l : In prompt Fac i l i t es , one means of escape may involve windows complying with 21-2.2.3(c).

E x c e p t i o n No. 2: A second means o f escape f r o m each s t o r y i s no t r e q u i r e d where the e n t i r e b u i l d i n g i s p r o t e c t e d t h r o u g h o u t by an app roved a u t o m a t i c s p r i n k l e r System c o m p l y i n g w i t h 21 2 . 2 . 3 . 5 and the f a c l l i t y has two means of escape.

21-2.2.2 Primary Means of Escape. Every sleeping room and l i v i n g area shal l have access to a primary means of escape so located as to provide a safe path of t ravel to the outside of the bu i ld ing without traversing any cor r idor , or other space, exposed to unprotected ver t i ca l openings. When sleeping rooms or l i v i n g areas are above or below the level of e x i t discharge, the primary means of escape shall be an enclosed i n t e r i o r s t a i r , ex te r i o r s t a i r , hor izontal e x i t , or an ex is t ing Fire escape s t a i r . AIso in slow and impractical f a c i l i t i e s , the primary means of escape fo r each sleeping room shal l not be exposed to common l i v i n g spaces such as l i v i n g rooms and kitchens.

21 2.2.3 Secondary Means of Escape. In addi t ion to the primary route, each sleeping room shall have a second means of escape or a l ternate protect ion which consists of one of the fo l lowing:

(a) A door, stairway, passage or hal l providing a way, independent of and remote from the primary means of escape, of unobstructed t ravel to the outside of the dwell ing at street or ground leve l .

(b) A passage through an adjacent nonlockable space independent of, and remote From, the primary means of escape to any approved means of escape.

(c) An outside window or door operable from the inside without the use of tools and providing a clear opening of not less than 20 in. (50.8 cm) in width, 24 in. (61 cm) in height and 5.7 sq f t (.53 sq m) in area. The bottom of the opening shal l not be more than 44 in. (I12 cm) o f f the Floor. Such means of escape shall be acceptable i f :

(1) the window is w i th ln 20 Ft (6. I m) of grade or, (2) the window is d i r e c t l y accessible to f i r e

department rescue apparatus as approved by the author i ty having j u r i s d i c t i o n , or

(3) the window or door opens onto an ex te r i o r balcony.

(d) The sleeping room shal l be separated From a l l other parts of the f a c i l i t y by construct ion having a f i r e resistance ra t ing of least 20 minutes and shal l be equipped with a door that w i l l res i s t passage of f i r e fo r at least twenty minutes and is designed and ins ta l led to minimize smoke leakage. A means of providing smoke venting and Fresh a i r to the occupants shall be provided.

Exception No. I: I f the sleeping room has a door leading d i r e c t l y outside of the bui ld ing with access to grade, or to a stairway that meets the requirements For e ' , te r io r s ta i rs in 21-2.3.1.2, that means of escape shall be considered as meeting a l l the escape requirements For the sleeping room.

Exception No. 2: A second means of escape or a l ternate protect ion from each sleeping room is not required where the f a c i l i t y is protected throughout by an approved automatlc spr ink ler system complying with 21-2.3.5.

Exceptlon No. 3: Exist ing approved means of escape may be continued in service.

21-2.2.4 Enclosed I n t e r i o r Sta i rs . I n t e r i o r stairways shall be enclosed with twenty minute f i r e barr iers with a l l openings protected with smoke actuated automatic or se l f -c los ing doors having a f i r e resistance comparable to that required fo r the enclosure. Stairways shall comply with 5-2.2.3.4.

Exception No. l : Stairs connecting twO levels only may be open to other than the st reet f l oo r .

Exception No. 2: In prompt and slow fac111t~es, stairways may be unprotected in accordance with the Exception to 21-2.3.1.1.

21-2.2.5 Doors. Following th is , renumber 21-2.2.3.1 and a l l subsequent paragraphs up to and including 21-2.2.5 as printed in the prepr~nt. COMMITTEE COMMENT: The Committee agrees with the intent of the Submitter but discovered a problem requi r ing every l i v i n g space to have two means of escape, revisions have been made to provide adequate l~Fe safety while easing th is burden (see new 21 2.2.1). lln addition several editorial changes have been made to make the section easier to use.

(Log #464) 101 403 - (21 2 .2 o f p r e p r i n t ) : Accep t i n P r i n c i p l e SUBMITTER: W i l l i a m E. K o f F e l , Amer i can H e a l t h Care Assn. COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: Revise section 21-2.2 as fol lows:

21-2.2.1 should read as 20-2.1.I cur ren t ly reads. 21-2.2.2 should read as 20-2.1.2 cur ren t ly reads

except the Exceptions should be pr inted as shown in the TCR For 21-2.2.1.

21-2.2.3 should read as 21-2.2.3.3 cur rent ly reads in the 1985 Code. SUBSTANTIATION: In the revisions to 21-2, some of the c u r r e n t r e q u i r e m e n t s i n Chap te r 20 were i n a d v e r t e n t l y d e l e t e d . S ince t he p r o p o s a l i n d i c a t e s t h a t no t e c h n i c a l changes were t o have been made, the comment s h o u l d be c o n s i d e r e d as an e d i t o r i a l c l a r i f l c a t i o n . COMMITTEE ACTION: Accept i n P r l n c i p l e .

See A c t i o n on Comment 101-402 on 2 1 - 2 . 2 (Log #415 ) . COMMITTEE COMMENT: A c t i o n taken on Comment I 01 -402 s h o u l d s a t i s f y the i n t e n t o f t he S u b m i t t e r .

(Log #24) 101 - 404 - ( 2 1 - 2 . 2 o f p r e p r i n t ) : Accep t i n P r i n c i p l e SUBMITTER: Thomas Jun9, New York State 0FFlce of Mental Retardation and Developmental D i s a b i l i t i e s COMMENT ON PROPOSAL NO.: I01-72l RECOMMENDATION: Revise section 21-2.2 to read as Follows:

21-2.2 Means o£ Escape. 21-2.2.1 Primary Means of Escape. Every sleeping

room and l i v i n g a rea s h a l l have access t o a p r i m a r y means o f escape so l o c a t e d as to p r o v i d e a s a f e pa th o f t r a v e l t o t he o u t s i d e o f t he b u i l d i n g w i t h o u t t r a v e r s i n g any c o r r i d o r , o r o t h e r space , exposed to unprotected ver t i ca l openings. Also in slow and impractical F a c i l i t i e s , th is primary means of escape shall not be exposed to common l i v i n g spaces such as l i v i n g rooms and kitchens. Where the sleeping room and l i v i n g area is above or below the level of e x i t discharge, the primary means of escape shall be an enclosed i n t e r i o r s t a i r , ex te r io r s t a i r , hor izontal e x i t , or an ex is t ing Fire escape s t a i r .

21-2.2.2 Secondary Means of Escape. In addi t ion to the primary route, each sleeping room and l i v i n g area shal l have a second means of escape or a l ternate protect ion which consists of one of the Following:

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(a) A door, stairway, passage or hall providing a way independent o f and remote From the p r imary means o f escape, o f unobs t ruc ted t r a v e l to the o u t s i d e o f the d w e l l i n g at s t r e e t o r ground l e v e l .

(b) A passage through ad jacen t non lockab le spaces independent o f and remote From the p r imary means o f escape to any approved means of escape.

(c) An outside window or door operable From the inside without the use of tools and providing a clear opening of not less than 20 in. (50.8 cm) in width, 24 in. (61 cm) in height and 5.7 sq f t (.53 sq m) in area. The bottom of the opening shall not be more than 44 in. (I12 cm) o f f the f loor . Such means of escape shall be acceptable i f :

(1) The window is within 20 f t (6.1 m) of grade or, (2) The window is d i rect ly accessible to Fire

department rescue apparatus as approved by the authority having jur isd ic t ion, or

(3) The window or door opens onto an exter ior balcony.

(d) The bedroom or l iv ing area shall be separated from al l other parts of the l iv ing unit by construction having a f i r e resistance rating of at least 20 minutes and shall be equipped with a door that w i l l resist passage of f i r e For at least 20 minutes, and is designed and installed to minimize smoke leakage. A means of providing smoke venting and Fresh a i r to the occupants shall be provided.

Exception No. l : I f the bedrooms or l iv ing area has a door leading d i rect ly outside of the building with access to grade or to a stairway that meets the requirements for exterior stairs in 21-2.3.1.2, that means of escape shall be considered as meeting a l l the escape requirements For the sleeping room or l~ving area.

Exception No. 2: In prompt Fac i l i t ies a second means of escape or alternate protection From each sleeping room or l iv ing area is not requlred where the dwelling unit is protected throughout by an approved automatic sprinkler system complying with 21 2.3.5.

Exception No. 3: Existing approved means of escape may be continued in service.

21-2.2.3 Number of Means of Escape. Every slow and every impractical Fac i l i ty shall have at least two remotely located means of escape that do not involve windows. SUBSTANTIATION: This proposal accomplishes two (2) major goals. First, i t corrects the language to consistently reference "means of escape" versus the terms "exi t" and "egress" which may imply compliance required with Chapter 5 of NFPA lOl. Second, the rewrite more accurately achieves the goal of incorporating applicable sections of Chapters 20 and 22 and their intent. The qual i f icat ions via Exceptions to Section 21-2.2 ref lect the current requirements of Chapter 21 by prohibiting open l iv ing Spaces along the path of the primary means of escape, and define requirements For a second means of escape. ~QHHITTEE ACTION: Accept in Principle.

See Comment I01-402 on 21-2.2 (Log #415). COMMITTEE COMMENT: The action taken on Comment I01-402 should satisfy the intent of the Submitter.

(Log #413) I01 - 405 - (21-2,2.2.1 Exception [21-2.1.3.1 Exception No. 2 in preprint]): Accept SUBHITTER: Harry Bradley, Hyattsvi l le, HD COMMENT ON PROPOSAL NO.: 101-723 RECOMMENDATION: Revise the Exception to 21-2.2.1 (this is 21-2.1.3.1 Exception No. 2 in the preprint) to read as follows:

Exception: Faci l i t ies which were previously approved as complying with the requirements for a large f a c i l i t y with the same evacuation capabi l i ty. SUBSTANTIATION: Proposal numbers I01-723 and 101-736 deleted this Exception whereas, Proposal I01-745 revised the Exception. The preprint indicated that the Exception would apply to a l l three categories of small f a c i l i t i e s , whereas, the actual proposals implied that this would only apply to impractical. The purpose of this comment is to c l a r i f y what I believe was the intent of the Committee and allow this to apply to any small f a c i l i t y where i t was previously approved but not be allowed in any new small f a c i l i t y . OC~QM_MITTEE ACTION: Accept.

(Log #263) lOl - 406 - (21-2.2.2.1 Exception [21-2.1.3.1 Exception No. 2 in prepr int ] ) : Accept in Principle $UBHITTER: Bernard Levin, Gaithersburg, MD COMMENT ON PROPOSAL NO.: 101-723 RECOMMENDATION: Retain Exception in 1985 Code For ewisting Fac i l i t ies . New wording:

Exception: Existing Faci l i t ies with a prompt evacuation capabil i ty complying with 21-3.2.2. SUBSTANTIATION: "Prompt" board and care homes that decrease the number of authorized cl ients to 16 or" fewer should not be required to be reevaluated under a new set o f r equ i remen ts . COMMITTEE ACTION: Accept in P r i n c i p l e .

See a c t i o n taken on Comment 101-405 on 2 1 - 2 . 2 . 2 . 1 Excep t ion [ 2 1 - 2 . 1 . 3 . 1 Except ion No. 2 in p r e p r i n t ] (Log #413). COMMITTEE COMMENT: The a c t i o n taken on Comment on 101-405 (Log #413) should s a t i s f y the i n t e n t o f the S u b m i t t e r .

(Log #359) I01 - 407 - (21-2.2.2.4 [21-2.3.4 in preprint]) : Reject SUBMITTER: James G. Nibert, Ohio Department of Mental Retardation and Developmental Disabi l i t ies COMMENT ON PROPOSAL NO.: I01-727 RECOMMENDATION: None. SUBSTANTIATION: We Support c la r i f i ca t ion of the proposed location of additlonal smoke detectors - however, the proposed wording does not c l a r i f y whether other common use rooms should be provided with smoke detectors, i . e . , dining rooms.

We are currently involved in a project to instal l Fire alarm and residential sprinkler equipment in mental retardation group homes. Authorities having jur isd ic t ion and Fire alarm designers are experiencing problems in determining how to comply with the standard's mandate. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Submitter provided no specific proposed revision.

(Log #36) lOl - 408 - (21-2.2.2.4.2 [21-2.3.4 Exception in preprint]) : Reject SUBMITTER: Joseph A. Drouln, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO.: I01 731 RECOMMENDATION: Reject proposal. SUBSTANTIATION: No substantiation is provided to show that a sprinkler system wi l l provide the same protection as a smoke detection system. Eighty percent of residential Fire deaths are From smoke inhalation. The detectlon system wi l l provide early warning for evacuation of the board and care resident. A smouldering Fife can create intolerable condltions before a sprinkler w111 activate. Smoke detection should be maintained in common areas as well as in sleeping areas. qOMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee believes that the insta l la t ion of a sprinkler system u t i l i z ing residential or quick response sprinklers provides the needed level of safety.

(Log #25) I01 - 409 - (21-2.2.2.4.2 Exception [21-2.3.4 of preprint]) : Reject SUBMITTER: Thomas Jung, New York State OFfice of Mental Retardation and Developmental Disabi l i t ies COMMENT ON PROPOSAL NO.: 101-731 RECOMMENDATION: Delete Exception to 21-2.2.2.4 allowing omission of smoke detectors in buildings protected by approved automatic sprinkler systems. SUBSTANTIATION: Consistent with Committee Action on I01-762 (21-3.2.2.5), early warning via smoke detection for occupant not i f icat ion is highly desirable. Sprinklers do not provide equivalent early warning, therefore some level of smoke detection should be provided.

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COMMITTEE ACTION: Re3ect. COMMITTEE COMMENT: See Comment I01-408 on 21-2.2.2.4.2 [21-2.3.4 Exception in prepr in t ] (Log #36), The Committee does not consider th is to be inconsistent, as in th is case the Committee is specifying res ident ia l spr ink lers or Quick response spr ink lers vs. a large f a c i l i t y with standard spr ink lers.

(Log #360) I01 - 410 - (21-2.2.2.5 [21-2.3.5.1 Exception No. 2 In p r e p r l n t ] ) : Accept SVBMITTER: James G. Nibert, Ohio Department of Mental Retardation and Developmental D i s a b i l i t i e s COMMENT ON PROPOSAL NO.: I01-733 RECOMMENDATION: We propose that 21 2.2.2.5, Exception No. 2 that the proposed change "Automatic Sprinklers may be omitted in small compartmented areas such as closets not over 12 sq f t . . . . " be dropped and that the wording in the current 101-1985 Edit ion "closets not over 24 sq gt . . . . " be maintained. SUBSTANTIATION: ( I ) Maintenance OF the ex is t ing wording w i l l assure coordination of provisions with NFPA 13D (1984 edi t ion) section 4-6, Exception No. 2 which states, "Sprinklers may be omitted from small closets where the least dimension does not exceed 3 f t (0.9 m) and the area does not exceed 24 sq f t (2.2 m 2) and the walls and ce i l ings are surfaced with noncombustible materials.

(2) The purpose of a res ident ia l sp r ink le r system is to assure the safety to l i f e in an occupied room - closets are not normally occupied. We, of course, note that larger closets are capable of being occupied - on an i r r egu la r basis.

(3) The wording of the proposed Exception No. 2 would appear to be in con f l i c t with the spec i f ic standards of i n s t a l l a t i o n in Exception, i f a res ident ia l spr ink le r system was ins ta l led per NFPA 13D, Section 4-6, Exception No. 2, which allows exemption of closets under 24 sq Ft.

We believe that a c o n f l i c t appears to ex is t i f a res ident ia l spr ink ler system may be ins ta l led per NFPA 13D and a closet less than 24 sq Ft is not spr inklered and a spr ink le r system ins ta l led per NFPA 13 is i ns ta l l ed , but allowed not to i n s t a l l heads per the ent i re f a c i l i t y per th is provision.

The Exception appears to create a standard of i n s t a l l a t i o n in variance with NFPA 13D and NFPA 13. COMMITTEE ACTION: Accept.

(Log #466) 101 - 411 - (21 2.2.2.5 Exception No. Z [21-2.3.5.1 Exception No. 2 in p rep r i n t ] ) : Accept SUBMITTER: William E. Kof fe l , American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-733 RECOMMENDATION: Reject the p roposa l . SUBSTANTIATION: The proponents f o r Proposal Nos. 101-733 and 101-732 r e f e r to c l o s e t s in h o t e l s . However, the o r ig in of the 24 sq f t is NFPA 13D. No documentation has been provided that the Fuel load in closets in dwellings is substant ia l ly less than that which is t yp i ca l l y found in board and care f a c i l i t i e s .

Whi le no documentat ion has been p rov ided f o r new f a c i l i t i e s , the proponent a l so has not p rov ided documentation to support a change to the requirements For ex is t ing f a c i l i t i e s . COMMITTEE ACTION: Accept.

(Log #445) lOl - 412 - (21-2.2.2.5 Exceptlon No. 2 [21 2.3.5.1 Exception NO. 2 in p rep r i n t ] ) : Accept SUBMITTER: Bob Bart les, Nebraska Assoc. of Pr ivate Residential Fac i l i t i es for the Mentally Retarded COMMENT ON PROPOSAL NOr: I01-733 RECOMMENDATION: Delete recodmmendation: Change "24 sq f t " to 12 sq f t " in 21-2.2.2.5 Exception No. 2. SUBSTANTIATION: I t is the co l l ec t i ve opinion of the NeAPRFMR membership that the present standard of 24 sq f t is adequate to provide safety For residents. COMMITTEE ACTION: Accept.

(Log #510) lOt - 413 - (21-2,2.2.5 Exception No. 2 [21-2.3.5.1 Exception No, 2 in p r e p r i n t ] ) : Accept in Pr inc ip le ~MITTER: Joni F r i t z , National Assn. of Private Residential F a c i l i t i e s For the Mentally Retarded COMMENT ON PROPOSAL NO.: I01-733 RECOMMENDATION: Change "24 sq f t " to "12 sq f t " in 21-2.2.2.5 Exception No. 2. SUBSTANTIATION: The proposed change is unnecessarily r e s t r i c t i v e . These are small homes which can be readily evacuated. We are unaware of any fires that have originated in a closet of a board and care home. The presence of an automatic extinguishing system in the room in which a closet is located and in adjoining rooms should adequately protect people in the home until they can evacuate the building. We therefore recommend retaining the language of the 1985 Code until and unless evidence is available that this is insufficient. If new language is adopted, at minimum, a provision should be included to "grandfather" compliance for homes that have already installed extinguishing systems. ~OMMITTEE ACTION: Accept in Principle.

See Comment I01-411 on 21-2.2.2.5 Exception No. 2 [21 2.3.5.1 Exception No. 2 in preprint]. COMMITTEE COMMENT: The action taken on 101-411 should satisfy the intent of the Submitter as indicated in her substantiation.

(Log #262) lot - 414 - (21-2.2.3.1 [21-2.1.3.1 Exception No. 2 in p rep r i n t ] ) : Accept in Pr inc ip le SUBMITTER: Bernard Levin, Galthersburg, MD COMMENT ON PROPOSAL NO.: 101-736 RECOMMENDATION: Retain Exception fo r ex is t ing f a c i l i t i e s .

Exception: Exist ing board and care occupancies with a slow evacuation capab i l i t y complying wlth 21-3.2.2. SUBSTANTIATION: "Slow" F a c i l i t i e s that decrease the number of authorized c l ien ts to 16 or fewer should not be required to be reevaluated under a new set of requirements. COMMITTEE ACTION: Accept in Principle.

See Comment 101-415 on 21-2.2.2.1. Exception [21-2.1.3.1 Exception No. 2 in preprint] (Log #414). COMMITTEE COMMENT: The a c t i o n taken on Comment 101-415 should s a t i s f y the i n t e n t o f the Subm i t t e r .

(Log #414) I01 - 415 = (21-2.2.3.1 Exception [21-2.1.3.1 Exception No. 2 in p r e p r i n t ] ) : Accept SUBMITTER: Harry Bradley, Hya t t sv i l l e , MD COMMENT ON PROPOSAL NO.: lOt 736 RECOMMENDATION: Revise 21-2.2.3.1 Exception ( th is is 21-2.1.3.1 Exception NO. 2 in the prepr in t ) to read as fol lows:

Exception: F a c i l i t i e s which were previously approved as complying with the requirements For a large F a c i l i t y with the same evacuation capab i l i t y . SUBSTANTIATION: Proposal numbers 101-723 and I01-736 deleted th is Exception whereas, Proposal 101-74 revised the Exception. The prepr int indicated that the Exception would apply to a l l three categories of small f a c i l i t i e s , whereas, the actual proposals implied that th is would only apply to impract ical . The purpose of th is comment is to c l a r i f y what I believe was the intent of the Committee and al low th is to apply to any small f a c i l i t y where i t was previously approved but not be allowed in any new small f a c i l l t y . COMMITTEE ACTION: Accept.

(Log #361) I01 - 416 - (21-2.2.3.5 Exception NO. 2 [21-2.3.5.1 Exception No. 2 in p r e p r i n t ] ) : Accept SUBMITTER: James G. Nibert, Ohio Department of Mental Retardation and Developmental D i s a b i l i t i e s COMMENT ON PROPOSAL NO.: I01-741 RECOMMENDATION: We recommend keeping the ex is t ing wording "Automatic spr ink lers may be omitted in small compartmented areas such as closets not over 24 sq f t

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SUBSTANTIATION: (1) Maintenance of the existing wording w i l l assure coordination of provisions/requirements with NFPA 13D, " Insta l la t ion of Sprinkler Systems in One- and Two-Family Dwellings and Mobile Homes," Section 4-6, Exception No. 2.

(2) The purpose of a residential sprinkler system is to assure l i f e safety within an occupied room - closets are not regularly occupied. We, of course, note that larger closets are capable of being occupied on an i rregular basis. ~OMMITTEE ACTION: Accept.

(Log #467) 101 - 417 - (21-2.2.3.5 Exception No. 2 [21-2.3.5.I Exception No. 2 in prepr int ] ) : Accept SUBMITTER: William E. Koffel, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-741

I RECOMMENDATION: Reject the proposal. SVBSTANTIATION: The proponents for Proposal Nos. I01-741 and I01-740 refer to closets in hotels. However, the origin of the 24 sq f t is NFPA 13D. No documentation has been provided that the fuel load in closets in dwellings is substantially less than that which is typ ica l ly found in board and care f a c i l i t i e s .

While no documentation has been provided for new Fac i l i t ies , the proponent also has not provided documentation to support a change to the requirements For existing f a c i l i t i e s . COMMITTEE ACTION: Accept.

(Log #446) lOl - 418 - (21-2.2.3.5 Exception No. 2 [21-2.3.5.1 Exception No. 2 in preprint]) : Accept $UBMITTER: Bob Bartles, Nebraska Assoc. of Private Residential Fac i l i t ies for the Mentally Retarded COMMENT ON PROPOSAL NO~: I01-741

I RECOMMENDATION: Delete recommendation: Change "24 sq gt" to "12 sq f t " in 2]-2.2.3.5 Exception No. 2. SUBSTANTIATION: I t is the col lect ive opinion of the NeAPRFMR membership that the present standard of 24 sq f t is adequate to provide safety for residents. COMMITTEE ACTION: Accept.

(Log #511) lOl - 419 - (21-2.2.3.5 Exception NO. 2 [21-2.3.5.1 Exception No. 2. in preprint]) : Accept in Principle SUBMITTER: Joni Fri tz, National Assn. of Private Residential Fac i l i t ies for the Mentally Retarded COMMENT ON PROPOSAL NO.: I01-741 RECOMMENDATION: Change "24 sq f t " to "12 sq f t " in 21-2.2.3.5 Exception No. 2. SUBSTANTIATION: The proposed change is unnecessarily res t r i c t i ve . These are small homes which can be readily evacuated. We are unaware of any f i res that have originated in a closet of a board and care home. The presence of an automatic extinguishing system in the room in which a closet is located and in adjoining rooms should adequately protect people in the home unt i l they can evacuate the building. We therefore recommend retaining the language of the 1985 Code unti l and unless evidence is available that this is insuf f ic ient . I f new language is adopted, at minimum, a provision should be included to "grandfather" compliance for homes that have already installed extinguishing systems. COMMITTEE ACTION: Accept in Principle.

See action on Comment I01-417 on 21-2.2.3.5 Exception No. 2 [21-2.3.5.1 Exception No. 2 in preprint] (Log #467). COMMITTEE COMMENT: The action taken on Comment I01-417 should sat isfy the actual intent of the Submitter as indicated in the substantiation.

(Log #61) IOl - 420 - (21-2.2.3.6 Exception No. 2 [21-2.3.6.4 Exception in preprint]) : Accept in Principle SUBMITTER: Dale F. Lowe, Green Valley Arc. COMMENT ON PROPOSAL NO.: 101-744 RECOMMENDATION: Add to the last section of Exception No. 2 ". . . and door closing devices are not required."

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SUBSTANTIATION: Door closing devices should not be required on corridor doors in buildings protected througout by an approved automatic sprinkler system. COMMITTEE ACTION: Accept in Principle.

No action needed. COMMITTEE COMMENT: See 21-2.3.6.4 contained in proposal 101-721 (page 396 of the TCR). This allows door closers to be exempted in sprinklered buildings as was permitted in the 1985 Code through Chapter 20.

(Log #52) I01 - 421 -- (21-2.2.3.6 Exception No. 2 [21-2.3.6.4 Exception in preprint]) : Accept in Principle $UBMITTER: Margaret N. Dunlap, Green Valley Arc. COMMENT ON PROPOSAL NO.: I01-744 RECOMMENDATION: To Exception No. 2 ( last part) add:

". . . and door closing devices are not required." SUBSTANTIATION: In buildings that are sprinklered throughout by an approved automatic system, door closing devices should not be required on corridor doors. COMMITTEE ACTION: Accept in P r i n c i p l e .

No ac t ion needed, COMMITTEE COMMENT: See Comment 101-420 on 21-2.2.3.6 Exception No. 2 [21-2.3.6.4 Exception in preprint] (Log #6l).

(Log #57) I01 - 422 - (21-2.2.3.6 Exception No. 2 [21-2.3.6.4 Exception in preprint]) : Accept in Principle $UBMITTER: Rebecca P. Baltzer, Green Valley Arc. COMMENT ON PROPOSAL NO.: 101-744 RECOMMENDATION: Add to the last section of Exception No. 2:

". . . and door closing devices are not required." SUBSTANTIATION: Door closing devices should not be required on corridor doors in buildings protected throughout by an approved automatic sprinkler system. COMMITTEE ACTION: Accept in Principle.

No action needed. COMMITTEE COMMENT: See Comment 101-420 on 21-2.2.3.6 Exception No. 2 [21-2.3.6.4 Exception in preprint] (Log #61).

(Log #207) lOl - 423 - (21-2.2.3.6 Exception No. 2 [21-3.6.4 Exception in preprint]) : Accept in Principle SUBMITTER: Dale F. Lowe, Maine Assn. of Private Residential Fac i l i t ies for Persons with Developmental Disabi l i t ies COMMENT ON PROPOSAL NO.: I0]--744 RECOMMENDATION: Add to the last section of Exception No. 2:

". . . and door closing devlces are not required." SUBSTANTIATION: Door closing devices should not be required on corridor doors in buildings protected throughout by an approved automatic sprinkler system. COMMITTEE ACTION: Accept in Princ}ple.

No action needed. COMMITTEE COMMENT: See Comment I01-420 on 21-2.2.3.6 Exception No. 2 [21-2.3.6.4 Exception in preprint] (Log #61).

(Log #465) lOl - 424 - (21-2.2.4 of preprint): Accept in Principle SUBMITTER: William E. Koffel, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-721 RECOMMENDATION: Add a new section 21-2.2.4 to read as follows:

21-2.2.4 Inter ior stairways shall be enclosed with 20-minute Fire barriers with a l l openings protected with smoke-actuated automatic or self-closing doors having a f i r e resistance comparable to that required for the enclosure. The stairway shall comply wlth 5-2.2.3.4.

Exception No. l : Stairs connecting two levels only may be open to other than the street f loor .

Exception No. 2: Stairways in prompt and slow f a c i l i t i e s may be unprotected in accordance with the Exception to 21-2.3.1.1.

SUBSTANTIATION: AS indicated by the proponent, the proposal was not intended to make any technical changes. The above paragraph is the same as 20-2.2 as currently referenced by Chapter 21. qOMMITTEE ACTION: Accept in Principle.

See action on Comment I01-402 on 2l-2.2 (Log #415). COMMITTEE COMMENT: The action taken on Comment I01-402 should sat is fy the intent of the Submitter.

(Log #205) I01 - 425 - (21-2.2.4.1 Exception [21-2.1.3.1 Exception No. 2 in preprint]) : Reject SUBMITTER: Dale F. Lowe, Maine Assn. of Private Residential Fac i l i t ies for Persons with Developmental Disabi l i t ies C~O_MMENT ON PROPOSAL NO.: I01-745 RECOMMENDATION: Revise the Exception to 21-2.2.4.1 to read:

Exception: Fac i l i t ies which were previously approved as complying with the requirements for a large Fac i l i ty with the same evacuation capacity. SUBSTANTIATION: I feel that Chapters 12 and 13 should be permitted to be used for compliance For small homes that are "impractical" to evacuate or large f a c i l i t i e s that are "prompt" or "slow" as an option or alternative to Chapter 21 (with adequate training and staf f ing) . COMMITTEE ACTION: Reject. qOMMITTEE COMMENT: I t appears that i t is the intent of the Submitter to reject Proposal I01-745. The Committee does not Feel that the requirements of Chapters 12 or 13 are e q u i v a l e n t to the requ i rements o f Chapter 21 f o r smal l board and care F a c i l i t i e s . When the requ i rements For new F a c i l i t i e s are mandated the p roper occupancy c l a s s i f i c a t i o n need to be met. (See s u b s t a n t i a t i o n For Proposal 101-745 on page 399 o f the TCR.) The Committee recogn izes t h a t Board and Care F a c i l i t i e s were p r e v i o u s l y approved under the Excep t ion p rov ided in the 1985 Code and Proposal 101-745 in combina t ion w i t h Comment 101-405 on 21 -2 .2 .2 .1 Except ion [ 2 1 - 2 . 1 . 3 . 1 Excep t ion No. 2 in p r e p r i n t ] (Log #413) and 101-415 on 2 1 - 2 . 2 . 3 . 1 Except ion [21-2.1.3.1 Exception No. 2 in preprint] (Log #414) w i l l allow these to be continued in use.

(Log #58) I01 - 426 - (21-2.2.4.1 Exception [21-2.1.3.1 Exception NO. 2 in preprint]) : Reject SUBMITTER: Rebecca Baltzer, Green Valley Arc. qOMMENT ON PROPOSAL NO.: I01-745 RECOMMENDATION: Revise the Exception to 21-2.2.4.1 to read:

Exception: Fac i l i t ies which were previously approved as complying with the requirements For a large Fac i l i t y with the same evacuation capabi l i ty. SUBSTANTIATION: I Feel that Chapters 12 and 13 should be permitted to be used for compliance for small homes that are "impractical" to evacuate or large f a c i l i t i e s that are "prompt" or "slow" as an option or al ternative to Chapter 21 (with adequate training and staf f ing) . O~ITTEE ACTION: Reject. qOMMITTEE COMMENT: See Comment I01-425 on 21-2.2.4.1 Exception [21-2.1.3.1 Exception No. 2 in preprint] (Log #205).

(Log #SO) I01 - 427 - (21-2.2.4.1 Exception [21-2.1.3.1 Exception No. 2 in preprint]) : Reject $UBMITTER: Margaret N. Dunlap, Green Valley Arc. ~OMMENT ON PROPOSAL NO.: 101-745 RECOMMENDATION: Please revise the Exception to 21-2.2.4.1 to read as follows:

Exception: Fac i l i t ies which were previously approved as complying with the requirements for a large f a c i l i t y with the same evacuation capabil i ty. SUBSTANTIATION: Small homes that are "impractical" to evacuate or large f a c i l i t i e s that are "prompt" or "slow" should be permitted to use Chapters IZ and 13 as an option to Chapter 21 (with adequate s ta f f and training).

COMMITTEE ACT~: Reject. COMMITTEE COMMENT: See Comment 101-425 on 21-2.2.4.1 Exception [21-2.1.3.1 Exception No. 2 in preprint] (Log #205).

(Log #60) 101 - 428 - (21-2.2.4.1 Exception [21-2.1.3.1 Exception No. 2 in preprint]): Reject SUBMITTER: Dale F. Lowe, Green Valley Arc. COMMENT ON PROPOSAL NO.: I01-745 RECOMMENDATION: Revise the Exception to 21-2.2.4.1 to read:

Exception: Faci l i t ies which were previously approved as complying with the requirements for a large f a c i l i t y with the same evacuation capabil i ty. SUBSTANTIATION: I Feel that Chapters 12 and 13 should be permitted to be used for compliance for small homes that are "impractical" to evacuate or large f a c i l l t i e s that are "prompt" or "slow" as an option or alternative to Chapter 21 (with adequate training and staf f ing) . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Comment I01-425 on 21-2.2.4.1 Exception [21 2.1.3.1 Exception No. 2 in preprlnt] (Log #205).

(Log #512) 101 - 429 - (21-2.2.4.1 Exception [21-2.1.3.1 Exception No. 2 in preprint]): Accept in Part in Principle SUBMITTER: Joni Fr i tz, National Assn. of Private Residential Faci l i t ies for the Mentally Retarded COMMENT ON PROPOSAL NO.: 101-745 RECOMMENDATION: Revise the Exception to 21--I.I.4.! to read:

Exception: Faci l i t ies which were previously approved as complying with the requirements f o r a large f a c i l i t y with the same evacuation capabil i ty. SUBSTANTIATION: NAPRFMR recommends that board and care homes continue to be permitted to meet Chapters 12 and 13 to comply with Chapter 21. Many small homes, in part icular, have upgraded to meet the more stringent requirements of those chapters during the period prior to the time the Department of Health and Human Services adopted the 1985 Code. Sections 12-I.3(c) and 13-I.3(c) speci f ical ly incorporate homes for people with mental retardation. Language of the 1985 Code should be retained or, at minimum, a provision should be included to "grandfather" compliance for homes that have added Features to comply with Chapters 12 and 13. COMMITTEE ACTION: Accept in Part in Principle.

See Action on Comments I01-405 on 21-2.2.2.1 Exception [21-2.1.3.1 Exception No. 2 in preprint] (Log #413) and I01-415 on 21-2.2.3.1 Exception [21-2.1.3.1 Exception No. 2 in preprint] (Log #414). COMMITTEE COMMENT: See Comment I01-425 on 21-2.2.4.1 Exception [21-2.1.3.1 Exception No. 2 in preprint] (Log #205). The action taken on I01-405 and I01-415 should sat isfy the intent of the user with regard to a "grandfather" provision.

(Log #468) I01 430 - (21-2.2.5 of preprint): Accept in Principle SUBMITTER: William E. KofFel, American Health Care Assn. COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: Add a new sec t i on 21 -2 .2 .5 to read as Fo l lows and renumber a c c o r d i n g l y :

21 -2 .2 ,5 The w i d t h , r i s e r s and t reads o f every s t a i r s h a l l comply w i t h the minimum requ i rements f o r Clsss B s t a i r s , as descr ibed in 5 -2 .2 . SUBSTANTIATION: The proposed s e c t i o n is the same as 22 -2 .4 .1 which the proponent had in tended to be i nc luded in the p r e p r i n t . ~0HMITTEE ACTION: Accept in P r l n c i p l e .

Add 21 -2 .2 .5 as suggested by the S u b m i t t e r but add the f o l l o w i n g Excep t ion :

Excep t ion : E x i s t i n g noncomplying s t a i r s may be continued in use subject to the approval of the authority having jur isdict ion.

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~OMMITTEE COMMENT: The Committee agrees with the in tent of the Submitter but has added the E×cept~on from 5-2.2.1 to c l a r i f y th is f l e x a b i l i t y in eKisting bui ld ings.

(Log #77) lOl - 431 - (21-2.3.4 Exception of p repr in t ) : Reject ~UBMITTER: H. Brooke Stauf fer , National E lec t r ica l Manufacturers Assn. COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: In paragraph 21-2.3.4 delete the Exception. SUBSTANTIATION: A spr ink le r system does not negate the need of a smoke detection system fo r l i f e safety, pa r t i cu l a r l y in a res ident ia l occupancy where smoldering f i r es are common and the major i ty of people die from smoke inhalat ion. Quick response spr ink lers do not act ivate fas ter than ra te -o f r ise heat detectors, and such heat detectors have been shown to be inadequate in terms of l i f e safety protect ion. COMMITTEE ACTION: Reject. ~OHHITTEE COMMENT: See Comment I01-408 on 21-2.2.2.4.2 [21-2.3.4 Exception in p repr in t ] (Log #36). Also see Proposal 101-731 on 21-2.2.2.2.4.2 (Page 398 of TCR).

(Log #35) 101 - 432 - (21-2.3.4 Exception of p repr in t ) : Reject ~UBMITTER: Joseph A. Drouin, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO~: I01-721 RECOMMENDATION: In paragraph 21-2.3.4 delete the Exception. ~UBSTANTIATION: Proposal was submlt ted as a re fo rmat For c l a r i f i c a t i o n . The Except ion to paragraph 21-2.3.4 Is new mate r ia l w i t hou t j u s t i f i c a t l o n For i t s a d d i t i o n to the standard. A s p r i n k l e r system does not negate the need of a smoke d e t e c t i o n system For l i f e s a f e t j , p a r t i c u l a r l y in a r e s i d e n t i a l occupancy where smouldering f i r e s are common and the maJor l t y of people d ie From smoke i n h a l a t i o n . COMMITTEE ACTION: Re jec t . COMMITTEE COMMENT: J u s t i f i c a t i o n was provided in Proposal I01-731 (Page 398 o f the TCR).

(Log #517) I01 - 433 - (21-2.3.5.1 in p rep r in t ) : Accept in Pr inc ip le SUBMITTER: Joni F r i t z , National Assn. of Private Residential F a c i l i t i e s for the Mentally Retarded COMMENT ON PROPOSAL NO.: I01 721 RECOMMENDATION: Proposed rev is ion inadvertent ly omitted from TCR. Proposal would l i m i t use of 13D s p r i n k l e r systems to homes se rv ing no more than 8 persons. SUBSTANTIATION: NAPRFHR opposes reducing the size of board and care homes which would be permitted to use 13D spr ink ler systems to those serving only 8 or fewer. There is no evidence that 13D systems are not e f fec t i ve in protect ing people f l y i ng in homes that serve 9 to 16 people. Limited experience indicates that the protect ion provided is adequate to protect l i ves . In the absence Of informat ion to the contrary, we recommend that the use of 13D Systems in board and care and lodging and rooming homes fo r IG or fewer persons be continued. COMMITTEE ACTION: Accept in Pr inc ip le .

See action on Comment I01-442 on 21 2.3.5.1 Exception No. 2 of prepr int , (Log #358). COMMITTEE COMMENT: The action taken on Comment I01-442 (Log #358) should sa t i s fy the actual in tent of the Submitter as indicated in her substant iat ion.

(Log # I I ) I01 - 434 - (21-2.3.5.1 Exception of p repr in t ) : Accept in Pr inc ip le SUBMITTER: Mayer D. Zimmerman, Health Care Financing Admin. ~OMMENT ON PROPOSAL NO.: I01-721

RECOMMENDATION: Propose that the rev is ion to new 21-2.3.5.1, Exception to l i m i t an NFPA 13D spr ink le r system to f a c i l i t i e s with 8 residents or less be l im i ted to new f a c i l i t i e s only. Exist ing f a c i l i t i e s should be allowed to use both Exceptions For up to and including IG people.

This proposal is appl icable to a l l board and care f a c i l i t i e s as well as to lodging and rooming houses. SUBSTANTIATION: I. This proposal is a re t roac t ive imposit ion and proposes to change the Code to make the requirements fo r ex is t ing bui ldings already in compliance with the Code more s t r ingent than in the past.

2. I am not. convinced that a properly designed NFPA 130 system with an adequate water Supply is unsafe fo r F a c i l i t i e s of lO or 12 beds which have the charac ter is t i cs and Fuel load of a one- and two-family dwel l ing, so le ly because they have more than 8 beds.

We have permitted a 13D system in 12 or 14 bed f a c i l i t i e s with no problem. COMMITTEE ACTION: Accept in Pr inc ip le .

See Action on Comment 101 437 on 21-2.3.5. I (Log #469). COMHITTEE COMMENT: The action taken on Comment I01-437 (Log #469) should sa t is fy the in tent of the Submitter.

(Log #507) I01 435 - (21 2.3.5.1 Except lons NO. 1 and 2 o f p r e p r i n t ) : Accept SUBMITTER: Wi l l i am A. White, VOCA Corp. COMMENT ON PROPOSAL NO.: 101 721 RECOMMENDATION: Under the new proposal merging Chapters 20 and 21, paragraph 21 -2 .3 .5 .1 , Except ion NO. I and Except ion No. 2, de le te , "Not g r e a t e r than e igh t r e s i d e n t s " . SUBSTANTIATION: Under the e x i s t i n g 1985 LSC NFPA I01, Chapter 21, The Type o f Bu i l d ing Cons t ruc t i on , The Locat lon o f Smoke De tec t ion , Separate Means o f Egress, Audib le F i re Alarm, Flame Spread Rat ings, Is s u f f i c i e n t l y adequate to ma in ta in the e x i s t i n g occupancy For 16 and under to a l l o w the 13D system. COMMITTEE ACTION: Accept.

(Log #508) I01 436 - (21-2 .3 .5 .1 Except ions No. 1 and 2 o f p r e p r i n t ) : Accept SUBMITTER: Thomas E. Hemingway, VOCA Corp, COMMENT ON PROPOSAL NO.: 101-721 RECOMMENDATION: Under the new proposal merging Chapters 20 and 21, paragraph 21 -2 .3 .5 .1 , Except ion No. 1 and Except ion No. 2, de le te , "Not g r e a t e r than e igh t r e s i d e n t s " . SUBSTANTIATION: Under the e x i s t i n g 1985 LSC NFPA I01, Chapter 21, The Type of Bu i l d i ng Cons t ruc t i on , The Locat ion o f Smoke De tec t i on , Separate Means o f Egress, Audib le F i r e Alarm, Flame Spread Rat ings, i s s u f f i c i e n t l y adequate to ma in ta in the e x i s t i n g occupancy For 16 and under to a l l o w the 13D system.

F a c i l i t i e s b u i l t and opera t ing under the 1985 Chapter 21 w i l l be out o f compliance. The p ip ing s i z i n g and h y d r a u l i c c a l c u l a t i o n For 13D vs. 13 are t o t a l l y d i f f e r e n t . The r e t r o f i t o f such f a c i l i t i e s w i l l be proh lb i t i ve . COMMITTEE ACTION: Accept.

(Log #469) 10] - 437 - (21-2 .3 ,5 .1 Except ions NO. 1 and 2 o f p r e p r i n t ) : Accept SUBHITTER: W111iam E. Ko f fe l , Amerlcan Health Care Assn. COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: Delete the phrase "with not greater than eight residents" from both Exceptions No. l and Exception No. 2. SUBSTANTIATION: There is no technical j u s t i f i c a t i o n fo r the l i m i t a t i o n to not more than eight residents. There is no s im i la r l i m i t a t i o n on size or occupant load in NFPA 13D. Furthermore, there is no l i m i t a t i o n in NFPA 13D to r e s t r i c t the use of the system to rooms which require two or less spr ink le r heads.

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We recogn ize t h a t the o v e r a l l l e v e l o f p r o t e c t i o n ( l i f e s a f e t y and p r o p e r t y p r o t e c t i o n ) p rov ided by an NFPA 13 system is g r e a t e r than the l e v e l p rov ided by an NFPA 13D system. However, the NFPA 13D system meets and p rov ides the l eve l o f p r o t e c t i o n des i red which is to p reven t f l a s h o v e r in the room o f o r i g i n and p rov ide adequate t ime For escape.

No documentat ion has been p rov ided t h a t the Fuel load is g r e a t e r than I0 I b / sq f t which is the l i m t a t i o n o f NFPA 13D. The proposed change would a lso a f f e c t e x i s t i n g b u i l d i n g s which have i n s t a l l e d NFPA 13D systems in accordance w i t h the 1985 e d i t i o n . COMMITTEE ACTION: Accept.

(Log #418) I01 - 438 - (21-2.3.5.1 Exception NO. 1 and 2 of p rep r in t ) : Reject SUBMITTER: Harry Bradley, Hya t t sv i l l e , MD COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: Revise Exception No. l to read:

Exception No. l : In impractical F a c i l i t i e s , where sleeping accomodations are provided For not more than eight residents, where the charac ter is t i cs of the occupancy are comparable w~th res ident ia l £1re potent ia ls , NFPA 13D, Standard For the I ns ta l l a t i on of Spr inkler Systems in One and Two Family Dwellings, and Mobile Homes with a th i r ty -minute water supply may be used provided a l l habitable areas and closets are spr inklered, Automatic spr ink lers may be omitted in bathrooms not over 55 sq Ft (5.1 sq m) with noncombustible plumbing Fixtures provided such spaces are Finished with lathe and p laster or materials with a 15 minute Finish ra t ing.

Revise Exception No. 2 to read: Exception No. 2: In prompt and slow f a c i l l t i e s ,

where sleeping accommodatlons are provlded For not more than eight residents, and where the character is t ics of the occupancy are comparable w~th res ident ia l f l r e potent ia ls , a spr ink ler system complying with NFPA 13D, Standard fo r the I ns ta l l a t i on of Spr inkler Systems in One- and Two-Family Dwellings and Mobile Homes, may be used. Automatic spr inklers may be omitted in bathrooms not over 55 sq Ft (5.1 sq m) with noncombustible plumbing f i x tu res provided such spaces are Finished with lathe and plaster or material with a IS minute f i n i s h ra t ing . SUBSTANTIATION: The prepr in t obviously was incorporat ing portions of TIA 227 which were also included in Proposal #101 713 on 20 3.5. I t was not c lear by the speci f ic proposals to Section 21-2 that th is was being done. This comment is provided to Formalize the inclusion of the concept of TIA 227 into these two Exceptions. COMMITTEE ACTION: Re3ect. COMMITTEE COMMENT: The Committee concurs with the Submitter that i t was the in tent of the Committee to incorporate the provisions of the proposed TIA #227 into the rewri te of Section 21 2. However, the review of public comments on th is subject has convlnced the Committee that these res t r i c t i ons were un jus t i f i ed . See Comments lot 435 (Log #507), 101-436 (Log #508), I01-437 (Log #469), 101 433 (Log #517), I01 441 (Log #357), and I01-439 (Log #27).

(Log #27) I01 - 439 - (21 2 .3 .5 .1 Except ions No. l and 2 o f p r e p r i n t ) : Accept SUBMITTER: Thomas Jung, New York S ta te O f f i c e o f Mental Re ta rda t ion and Developmental D i s a b i l i t i e s COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: Delete f rom f l r s t l i n e o f both Excep t ion No. 1 and Except ion No. 2 to 21 2 .3 .5 .1 the q u a l i f y i n g phrase " . . . w i t h not g r e a t e r than e i g h t r e s i d e n t s . . . . " SUBSTANTIATION: There is no t e c h n i c a l j u s t i f i c a t i o n For l i m i t i n g the use o f an NFPA 13D system to e i g h t o r less bed f a c i l i t i e s . The e i g h t bed l i m i t is a r b i t r a r y , and does not properly serve technical concerns over the adequacy of the 130 system in cer ta in Residential Board

and Care conf igurat ions. Since many Board and Care F a c i l i t i e s that are res ident ia l in nature benef i t From the use of the 13D system when cost and avai lab le water supply are constraints, a more ra t iona le argument that d i r e c t l y addresses the Committee's concerns should be developed with proper consideration. COMMITTEE ACTION: Accept.

(Log #416) I01 - 440 (21-2.3.5.1 Exceptions No. 1 and 2 and 3): Accept in Pr inc ip le SUBMITTER: Harry Bradley, Hya t t sv i l l e , NO COMMENT ON PROPOSAL NO.: 101 721 RECOMMENDATION: Revise 21 2.3.5.1 by rev is ing the Exceptions as Follows:

Exception No. I: In impractical F a c i l i t i e s , a spr ink ler system complying with NFPA 13D, Standard For the I n s t a l l a t i o n of Spr inkler Systems in One- and Two Family Dwellings, with a th i r ty -minute water supply may be used provided a l l habitable areas and closets are spr inklered. Automatic spr ink lers may be omitted in bathrooms not over 55 sq Ft (5.I sq m) provided such Spaces are Finished with lathe and p laster or material with a Fi f teen minute Finish rat lng.

Exception No. 2: In prompt and slow f a c l l l t l e s , a s p r i n k l e r system comply ing w i th NFPA 13D, Standard For the I n s t a l l a t i o n of S p r i n k l e r Systems in One and Two-Fami ly Dwe l l i ngs and Mobi le Homes may be used.

Except ion No. 3: In prompt and slow F a c i l i t i e s , au tomat ic s p r i n k l e r s may be omi t ted in c l o t hes c l o s e t s not over 12 sq f t ( 1 . I sq m) and bathrooms not over 55 sq Ft (5.1 sq m) provided spaces are f in ished with lathe and p laster or materials wlth a Fi f teen minute F i n i s h r a t i n g . E x i s t l n g s p r i n k l e r Systems, which omi t ted s p r i n k l e r s in c l ose t s not over 24 sq f t (2 .2 sq m) may be con t inued in s e r v l e e . SUBSTANTIATION: The Conlnl t tee has not documented any technical j u s t i f i c a t i o n For reducing the accep tab l l i t y of NFPA 13D in these Fac l l l t l e s down From 16 people to 8 people. The only j u s t i f i c a t i o n has been a p o l i t i c a l one involv ing NFPA 13D and not a technical 3ust iF lcat ion. The Committee on Safety to L i fe has in the past, emphasized that the size of these F a c i l i t i e s resul ts in Fire condit ions, Fuel load and fuel conf igurat ion s lm i la r to a one and two-Family dwell ing and, t h e r e f o r e , a s p r i n k l e r system accep tab le in a one and t w o - f a m i l y d w e l l i n g should be accep tab le in these F a c i l i t i e s . In a d d i t i o n , the Except ion For 24 sq Ft c l o s e t s should be cont inued to be a l lowed For e< ls t~ng i n s t a l l a t i o n s . COMMITTEE ACTION: Accept in P r l n c l p l e .

See Committee Ac t i on on Comments 101 437 on 21 -2 .3 .5 .1 Excep t ions No. I and 2 (Log #469). 101 411 on 2 1 - 2 . 2 . 2 . 5 Excep t ion No. 2 [21 2 .3 .5 .1 Excep t ion No. 2 in p r e p r i n t ] (Log #466) and I01 417 on 21 21 2 . 2 . 3 . 5 Except ion No. 2 [ 2 1 - 2 . 3 . 5 . 1 Except ion No. 2 in p r e p r i n t ] (Log #467). COMMITTEE COMMENT: See Committee Comment For Comment 101-443 on 21 2 .3 .5 .1 Except ion No. 3 (Log #266).

(Log #357) I01 - 441 - (21 2.3.5.1E~cept ion No. 2 of p rep r in t ) : Accept SUBMITTER: James G. Nibert, Ohio Department of Mental Retardation COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: We propose that the prepr in t of Section 21-2.3.5. I Exception No. 2, delete the phrase "not greater than eight residents . . . . " SUBSTANTIATION: I. We support the reformating and incorporat ion of Chapter 20 "Lodging and Rooming Houses" For the purposes of use in Chapter 21.

2. We are not, however, able to i d e n t i f y a proposal fo r Chapter 21 which would s p e c i f i c a l l y change the present sectlon 21-2.2.3 (I01 1985 ed i t ion) and create the Exceptions proposed in the prepr in t , unless the prepr lnt incorporates the proposal I01-713 For Chapter 20 "Lodging and Rooming Houses".

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3. We believe that the use of a residential sprinkler system meeting the requirements of NFPA 13D is appropriate to protect f a c i l i t i e s which are rated prompt or slow and which provide accommodations for up to 16 individuals, depending upon the nature of physical f a c i l i t y . The proposed Exception's wording may fo rs ta l l sprinkler insta l la t ions where commercial sprinklers are not Financially or technically Feasible. COMMITTEE ACTION: Accept.

(Log #358) IOl - 442 (21-2.3.5.1 Exception NO. 2 of preprint) : Accept SUBMITTER: James G. Nibert, Ohio Department of Mental Retardation and Developmental D isab i l i t ies COMMENT ON PROPOSAL NO.: I01-721 RECOMMENDATION: We propose that section 21-2.3,5.1, Exception No. 2 that the proposed change "Automatic sprinklers may be omitted in small compartmented areas such as c l o s e t s no t ove r 12 sq f t . . . . " be dropped and t h a t t he word ing i n t he c u r r e n t I01 1985 e d i t i o n " c l o s e t s no t ove r 24 sq f t . . . . " be m a i n t a i n e d . SUBSTANTIATION: (1) Ma in tenance o f t he e x i s t i n g word ing w i l l assure c o o r d i n a t i o n o f p r o v i s i o n s w i t h NFPA 13D (1984 e d i t i o n ) s e c t i o n 4 -6 , E x c e p t i o n No. 2 wh ich s t a t e s , " S p r i n k l e r s may be o m i t t e d From smal l c l o s e t s where the l e a s t d imens ion does no t exceed 3 f t ( 0 . 9 m) and the area does no t exceed 24 sq f t ( 2 . 2 m 2) and the w a l l s and c e l l i n g s a re s u r f a c e d w i t h n o n c o m b u s t i b l e m a t e r i a l s ,

(2) The purpose o f a r e s i d e n t i a l s p r l n k l e r sys tem is t o assu re the s a f e t y to l i f e in an occup led room where c l o s e t s are no t n o r m a l l y o c c u p i e d . We, o f c o u r s e , no te that larger closets are capable of belng occupied, on an i r regular basis.

(3) The wording in Exception No. 2 would appear to be in con f l i c t with the specif ic standards of ins ta l la t ion in E~ception No. I, i f a residential s p r i n k l e r sys tem was i n s t a l l e d per NFPA 1,3D, S e c t i o n 4 - 6 , E x c e p t i o n No. 2. COMMITTEE ACTION: Accep t .

(Log #266) I01 443 - (21-2.3.5.1 Exception No. 3 of prepr int) : Accept in Principle SUBMITTER: Bernard Levin, Gaithersburg, MD COMMENT ON PROPOSAL NO.: 101-747 RECOMMENDATION: Add Exception No. 3 as Follows:

Exception No. 3: In exist ing prompt and slow Fac i l i t i es a sprinkler system complying wlth NFPA 13D, Standard for the Insta l la t ion of Sprinkler Systems in One and Two-Family Dwellings and Mobile Homes, may be used. Automatic sprinklers may be omitted in small compar tmented areas such as c l o s e t s no t over 24 sq f t ( 2 . 2 sq m) and bathrooms no t ove r 55 sq gt (5 .1 sq m), p r o v l d e d such spaces are F i n i s h e d w i t h l a t h e and p l a s t e r o r m a t e r l a l s w i t h a 15 m inu te F i n i s h r a t i n g . SUBSTANTIATION: Sprinkler systems have been recently ~nstalled in some board and care f a c i l i t i e s to meet the provisions of the current Life Safety Code. Such systems provide a high level of safety. The increased cost, disruption of services, and inconvenience of r e t r o f i t t i n g buildings to the new standard, is not warranted, especially i f the residents can be evacuated. COMMITTEE ACTION: Accept in Principle.

See Action taken on Comments I01-437 on 21-2.3.5.1 Exceptions l and 2 (Log #469), lOI-411 on 21-2.2.2.5 Exception NO. 2 [21-2.3.5.1 Exception No. 2 in preprint ] (Log #466) and I01-417 on 21-2.2.3.5 Exception No. 2 [21-2.3.5.1 Exception No. 2 in preprint] (Log #467). COMMITTEE COMMENT: The action taken on Comments lOl 437 and 101-411 and I01-417 should sat is fy the intent of the Submitter as they do what the Submitter wants but do i t for both new and exist ing.

(Log #264) I01 - 444 - (21-3.1. I ) : Accept SUBMITTER: Bernard Levin, Gaithersburg, MD COMMENT ON PROPOSAL NO.: I01-753 RECOMMENDATION: Retain First two sentences. Revise third sentence as Follows:

"However, exist ing f a c i l i t i e s meeting the requirements of this section are considered to meet the requirements of Section 21-2.2.2 For prompt evacuation capabil i ty and Section 21-2.2.3 for slow evacuation capabil i ty. SUBSTANTIATION: "Prompt" and "slow" f a c i l i t i e s that decrease the number of authorized cl ients to 16 or Fewer should not be required to be reevaluated under a new s e t o f r e q u i r e m e n t s . COMMITTEE ACTION: Accep t .

(Log #513) 101 - 445 - (21-3.1. I ) : Accept in Principle SUBMITTER: Joni Fr i tz, National Assn. of Private Residential Fac i l i t ies for the Mentally Retarded ~OMMENT ON PROPOSAL NO.: I01-753 RECOMMENDATION: Delete second and th i rd sentence of 21-3.1.1. SUBSTANTIATION: NAPRFMR recommends that these deletions not be made. Not only are Chapters 12 and 13 more stringent than standards met by board and care Faci l i t ies in the past, Sections 12-1.3(c) and 13-I.3(c) spec i f ica l ly incorporate many homes for people with mental retardation. People reside in board and care homes longer than in many health care Faci l i t ies and become Familiar with ex i t routes and are trained to evacuate. They are in less danger than are Short term residents who are not trained. Language of the 1985 Code should be retained or, at minimum, a provision should be included to "grandfather" Compliance for homes that have added features to comply with Chapters 12 and 13. ~OMMITTEE ACTION: Accept in Principle.

See Comment I01-444 on 21 3.1.1 (Log #264). COMMITTEE COMMENT: See Comment 101-444 on 21 3.1. (Log #2G4) and Comment 101 425 on 21-2.2.4.1 [21-2.1.3.1 Exception No. 2 in preprint] (Log ~205

(Log #26) 101 - 446 - (21-3.1.3.21: Accept in Prlnciple SUBMITTER: Thomas Oung, New York State Office of Mental Retardation and Developmental D isab i l i t ies COMMENT ON PROPOSAL NO.: I01-752 RECOMMENDATION: Revise Section 2l-3.1.3.2 to read

21-3.1.3.2 Impractical. Fac i l i t ies housing groups of persons classed as impractical to evacuate shall meet the requirements for custodial care f a c i l i t i e s , Chapter 12 or 13, as appropriate. SUBSTANTIATION: Replacing the term "supervisory care f a c i l i t i e s " , as proposed, with term "custodial care Fac i l i t ies" is consistent with the def in i t ion of custodial care f a c i l i t i e s as f a c i l i t i e s housing c l ients incapable of sel f preservation, as well as the current requirement of 21-3.2.3.1. COMMITTEE ACTION: Accept in Principle.

Change to " l imited care" rather than "custodlal care". COMMITTEE COMMENT: The Committee has revised Chapters 12 and 13 by eliminating both supervisory care and custodial care and substituting " l imited care".

(Log #278) lOl - 447 - (21-3.1.4): Reject SUBMITTER: Daniel M. McGee, American Iron and Steel Inst i tu te COMMENT ON PROPOSAL NO.: 101-752 RECOMMENDATION: Revise the proposed minimum construction requirements to read as shown below:

Exception*: Fac i l i t ies where the authority having ju r i sd ic t ion has determined equivalent Safety is provided in accordance with Section I-5.

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21-3.1.4 Minimum Construction Requirements. 21-3.1.4.1 Construction requirements For large

Facilities shall be as required by this section. Where noted as "fully sheathed," the interior shall be covered with lathe and plaster, or materials with a 15 minute f in ish rating.

21-3.1.4.2 For the purpose of construction requirements, stories shall be counted start ing at the primary level of ex i t discharge and ending at the highest occupied level. For the purposes of this section, the primary level of ex i t discharge of a building shall be that Floor which is level with or above Finished grade of the exter ior wall l ine For 50 percent or more of i ts perimeter. Building levels below the primary level shall not be counted as a story in determining the height of a building.

2 1 - 3 . 1 . 4 . 3 The minimum c o n s t r u c t i o n requ i remen ts , based on the h l ghes t s t o r y no rma l l y used by board and care r e s i d e n t s , are:

(a) One or Two-Story Facilities. Any construction type that meets the requirements For l-hour or greater f i r e resistance rat ing, or is Type IV (IHH), Type I I (000) or is f u l l y sheathed, or is protected throughout by an approved automatic sprinkler system in accordance with 21-3.3.5.

Exception to (a): One story Fac i l i t ies having 30 or Fewer residents, housing groups capable of prompt evacuation, may be of any construction.

(b) Three to Six-Story Fac i l i t ies . Type I, I I or I I I construction that meets the requirements For l-hour or greater Fire resistance rating, and Type IV construction that is protected throughout by an automatic sprinkler System in accordance with 21 3.3.5, or any other type of construction that is both sheathed and protected throughout by an approved automatic sprinkler system in accordance with 21 3,3.5, other than Type V (000).

(c) Fac i l i t ies More Than Six Stories High. Any Type I or Type I I (222) construction. Any Type I I (111), Type I I l (211) or Type IV (2HH) construction that is protected throughout by an approved automatic sprinkler System in accordance with 21 3.3.5.

Exception to (a), (b), and (c): Any building of Type I or Type I I (222 or I l l ) construction may include roofing systems involving combustible decking, or roofing provided: (1) the roof covering meets Class A requirements in accordance with NFPA 256, Fire Tests of Roof Coverings, and (2) the roof is separated From a l l occupied portions of the building by a noncombustible Floor assembly having at least a 2 hour Fire resistance rating which includes at least 2 I/2 in. (G.4 cm) of concrete or gypsum F i l l . To qual i fy For this Exception, the a t t i c or other space so developed shall either be unused or protected throughout by an approved automatic sprinkler system in accordance wlth 21-3.2.2.6.

21-3.1.5" Occupant Load. The occupant load ]n numbers of persons For whom exits are to be provided shall be determined on the basis of one person per 200 sq Ft (18.6 sq m) gross Floor area, or the maximum probable population of any room or section under consideration, whichever is greater. The occupant load of any open mezzanine or balcony shall be added to the occupant load of the Floor below For the purpose of determining ex i t capabi l i ty.

21-3.2 Means of Egress. 21-3.2.1 All means of egress shall be in accordance

with Chapter 5. 21-3.2.2 Types of Exits. Exlts, or exi t components

arranged in accordance with Chapter 5, shall be one or more of the following types:

(a) Doors, as per 5-2.1. (b) Revolving doors, in accordance with 5-2.1.I0. (c) Stairs, in accordance with 5-2.2.

SUBSTANTIATION: The proposed construction requirements are in conf l i c t with proposed Table 12-1.6.2 and the requirements of the model building codes. NFPA should t ry to avoid creating conf l ic ts between Fire o f f i c i a l s and building o f f i c i a l s . ~OMMITTEE ACTION: Reject. ~OMMITTEE COMMENT: The Committee is more interested in the protection of the members versus the combustibi l i ty. The Committee does not see the "conf l ic ts" the Submitter alludes to. Many of the buildings that are being u t i l i zed here are exist ing structures and are "sheathed" and therefore this is a useful provision.

(Log #420) lOl - 448 - (21-3.2): Accept in Principle SUBMITTER: Harry Bradley, Hyattsvi l le, MD COMMENT ON PROPOSAL NO.: I01-752 RECOMMENDATION: Revise 21-3.2 to read as Follows:

21-3.2 Means of Egress Components. 21-3.2.1 Components of means of egress shall be

l imited to the types described in 21-3.2.2 through 21 3.2.7.

21-3.2.2 Doors. 21-3.2.2.1 Doors shall comply with 5-2.1. 21-3.2.2.2" No door in any means of egress shall be

locked against egress when the building is occupied. Exception: Special locking requirements complying

with 5-2.1.6 are permitted. 21-3.2.2.3" Every stairwel l door shall allow reentry

From the stairwel l to the in te r io r of the building or an automatic release shall be provided to unlock a l l stairwell doors to allow reentry. Such automatic release shall be activated with the i n i t i a t i o n of the building f i r e alarm system. AIso, they shall unlock upon loss of power control l ing the lock or locking mechanism.

2 1 - 3 . 2 , 2 . 4 Revo lv ing doors comply ing w i t h 5 - 2 . 1 . 1 0 are p e r m i t t e d .

21-3.2.3 Stairs. Stairs shall comply with 5-2.2. 21 3.2.4 Smokeproof Enclosures. SmokeprooF

enclosures shall comply with 5 2.3. 21 3.2.5 Horizontal Exits. Horizontal exits shall

comply with 5-2.4. 21 3.2.6 Ramps. Ramps shall comply with 5-2.5. 21=3.2.7 Exit Passageways. Exit passageways shall

comply with 5-2.6. SUBSTANTIATION: Section 21-3 was revised based on Chapters IG and 17. Section 16-2.2 and 17-2.2 have been revised and this revision should be included with the rewrite of Section 21-3. COMMITTEE ACTION: Accept in Principle,

Do as proposed by the Submitter but revise the First three paragraphs to read as Follows:

21-3.2 Means o f Egress. 21-3 .2 .1 A l l means o f egress s h a l l be in accordance

w i t h Chapter 5. 21 -3 .2 .2 Means o f Egress Components. Components o f

means o f egress s h a l l be l i m i t e d to the types desc r ibed in 21 -3 .2 .3 th rough 21 3 .2 .8 .

21 3 .2 .3 Doors. Renumber as a p p r o p r i a t e .

COMMITTEE COMMENT: The Committee agrees w i t h the i n t e n t o f the Subm i t t e r but wishes to m a i n t a i n 21 -3 .2 .1 From the o r i g i n a l r e w r i t e .

(Log #514) 101 - 449 - ( 2 1 - 3 . 2 . 2 . 1 Except ion [ 21 -3 .1 .1 in rewrite]): Reject SUBMITTER: Joni Fritz, National Assn. of Private Residential Facilities For the Mentally Retarded COMMENT ON PROPOSAL NO.: 101-756 RECOMMENDATION: Revise the Exception to 21-3.2.2.1 to read:

Exception: Facilities which were previously accepted as comply ing w i t h 2 1 - 3 . 2 . 3 . SUBSTANTIATION: NAPRFMR asks the Committee to r e j e c t recommendations t h a t board and care homes not be pe rm i t t ed to comply w i t h Chapters 12 or 13. Requirements For new and e x i s t i n g h e a l t h care F a c i l i t i e s are more s t r i n g e n t than are those For Fami ly res idences and l odg ing and rooming houses p r e v i o u s l y app l i ed to board and care type F a c i l i t i e s . Sec t ions 1 2 - I . 3 ( c ) and 1 3 - I . 3 ( c ) s p e c i f i c a l l y i n c o r p o r a t e many homes For people w i t h mental r e t a r d a t i o n . The Code would be i n c o n s i s t e n t i f t h i s were not a l lowed to con t inue . In a d d i t i o n , people w i l l be t r a i n e d to evacuate p laces they use as t h e i r homes. At minimum, language should be inc luded to pe rmi t " g r a n d F a t h e r i n g " For homes t h a t a l r eady meet these chap te rs . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The apparent intent of the Submitter is to continue to allow the use of Chapters 12 and 13 For small "impractical" board and care Fac i l i t ies . The Committee does not Feel this should be permitted as the Committee does not feel that Chapters 12 and 13 provide an equivalent level of protection for a smal l F a c i l i t y .

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(Log #470) lOl - 450 - (21-3.2.2.5 Exception NO. l [21-3.3.4.8 Exception No. l (New) in rewr i te ] ) : Accept in Principle ~BMITTER: William E. Koffel , American Health Care Assn. C~MMENT ON PROPOSAL NO.: I01-762, 763 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: We are not aware of tests conducted as part of Operation San Francisco which relate to smoke detectors and sprinklers in common spaces. Furthermore, is the perceived problem so severe that the revision needs to impact existing buildings also? COMMITTEE ACTION: Accept in Principle.

Add a new 21-3.3.4.8 Exception No. l to read: Exception No. I: Detectors may be omitted From

common spaces in Fac i l i t ies protected throughout by an approved automatic sprinkler system in accordance with 21-3.3.5. COMMITTEE~OMMENT: The Committee concurs with the Submitter but has c la r i f i ed the intent of the Exception.

U~UB~_TANTIATION: The proposed change is unnecessarily res t r ic t i ve . We question whether the difference between a closet of 12 sq Ft and 24 sq f t is signif icant enough to make a substantial difference in a board and care home that has an automatic extinguishing system protecting rooms adjacent to a larger closet. We are unaware of any Fires that have originated in a closet of a board and care home. We therefore recommend retaining the language of the 1985 Code unti l evidence indicates that this is insuf f ic ient . IF new language is adopted, at minimum, a provision should be included to "grandfather" compliance for homes that have already installed automatic extinguishing systems. COMMITTEE ACTION: Accept in Principle.

See Comment 101-452 on 21-3.2.2.6 Exception [21-3.3.5.1 Exception in rewrite] (Log #472). COMMITTEE COMMENT: The action taken on Comment I01-452 should sat isfy the intent of the Submitter.

(Log #471) 101 - 451 - (21-3.2.2.5 Exception No. 2 [21-3.3.4.8 in rewri te]) : Reject ~UBMITTER: William E. Koffel, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-764 RECOMMENDATION: Reject the proposal, thereby retaining the Exception. ~VBSTANTIATION: The Committee admits in the substantiation that the Exception ~S theoret ical ly useable. While the Committee may not be able to ident i fy specific applications, i f the Exception has merit i t should be retained. I t is conceivable that section of a long term care Fac i l i ty may provide Personal care beds. The same level of staff ing may be retained. With respect to s ta f f training, the provisions in Chapter 31 For board and care f a c i l i t i e s are more specific and at least equivalent to the requirements for health care occupancies.

I f an existing building complies with the provisions of the Exception and has previously been considered to comply with the Code, why should the f a c i l i t y be considered not complying with the new edition without more adequate substantiation? COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee feels that corridor smoke detectors are needed for l i f e safety. I t should be noted that limited care f a c i l i t i e s i n Chapters 12 & 13 are required to have corridor detectors. The Committee Feels that the Exception in the 1985 Code is unrealistic and unwarranted.

(Log #472) I01 - 452 - (21-3.2.2.6 Exception [21-3.3.5.1 Exception in rewri te]) : Accept ~UBMITTER: William E. Koffel, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101 766

I RECOMMENDATION: Reject the proposal. ~TANTIATION: The proponent refers to closets in hotels. However, the origin of the 24 sq Ft is NFPA 13D. While we are dealing here with large f a c i l i t i e s , the specific issue should be the re lat ive hazard that the closet represents. No documentation has been provided that the Fuel load in closets in dwellings is substantially less than that which is typical ly found in board and care f a c i l i t i e s .

While no documentation has been provided for new Faci l i t ies , the proponent also has not provided documentation to support a change to the requirements For existing f a c i l i t i e s . ~OMMITTEE ACTION: Accept.

(Log #515) I01 - 453 - (21-3.2.2.6 Exception [21-3.3.5.1 Exception in rewr i te] ) : Accept in Principle ~UBMITTER: Joni Fri tz, National Assn. of Private Residential Fac i l i t ies for the Mentally Retarded COMHENT ON PROPOSAL NO.: I01-766 RECOMMENDATION: Change "24 sq f t " to "12 sq f t " in 21-3.2.2.6 Exception.

(Log #473) I01 - 454 - (21-3.2.2.8 [21-3.3.6.3 Exception No. I in rewr i te ] ) : Accept SUBMITTER: William E. KofFel, American Health Care Assn. COMMENT ON PROPOSAL NO,: I01-770 RECOMMENDATION: Revise Exception No. I to 21-3.3.6.3 to read as follows:

Exception No. l: In existing buildings and conversions, such f~re barriers shall have a Fire resistance rating of not less than 20 minutes. SUBSTANTIATION: AS proposed in the TCR, the conversion of a health care occupancy or a hotel to a board and care occupancy would require potent ia l ly upgrading the corridor wall to a Fire barrier having a f i r e resistance rating of at least one hour. No documentation has been provided to support the change. I t should be noted that the 1985 edition would permit a long term care f a c i l i t y to convert to a board and care f a c i l i t y without any alterations. COMMITTEE ACTION: Accept.

(Log #474) 101 - 455 (21-3.2.2.8 [21-3.3.6.3 Exception No. 3 in rewr i te ] ) : Accept in Principle SUBMITTER: William E. KoFfel, Amerlcan Health Care Assn. COMMENT ON PROPOSAL NO=: I01-770 RECOMMENDATI_ON: Revise Exception No. 3 to 21-3.3.6.3 by deleting "and not less than 20 minutes in existing buildings." ~BSTANTIATION: The proposed revision to the requirements For an existing building have not been substantiated. COMMITTEE ACTION: Accept in Principle.

Revise as follows: ". . . and in existing f a c i l i t i e s no Fire resistance

rating is required." COMHITTEE~_OHMENT: The Committee concurs with the intent of the Submitter but notes that deletion w i l l not accomplish the Submitter's intent. The revision proposed by the Committee should sat is fy the intent of the Submitter

( L o g # 4 2 1 ) 101 - 456 - ( 2 1 - 3 . 2 . 1 0 . 1 , 2 1 - 3 . 2 . 1 0 . 2 and 21-3.2.I0.3): Accept SUBMITTER: Harry Bradley, Hyattsvi l le, HO COMMENT ON PROPOSAL NO.: I01-752

I RECOMMENDATION: Delete Sections 21-3.2.10.I, I0.2 and 10.3. SUBSTANTIATION: A comment has been provided on 21-3.2 which w i l l incorporate this material in 21-3.2 and, therefore, i t can be deleted here. COMMITTEE A A~TION: Accept.

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(Log #476) lOl - 457 - (21-3.3.4.1): Accept in Principle SUBMITTER: William E. KoFfel, American Health Care Assn. COMMENT ON PROPOSAL NO.: I01-775 RECOMMENDATION: Retain the Exception from 17-3.4.1 For existing buildings only. SUBSTANTIATION: No substantiation has been provided indicating the need to no longer accept the Exception in existing buildings. COMMITTEE ACTION: Accept in Principle.

Add the Exception, to read as follows: Exception: Existing board and care f a c i l i t i e s where

each sleeping room has exterior ex i t access in accordance with 5-5.3 and the building is not greater than 3 stories in height. COMMITTEE COMMENT: The Committee agrees with the Submitter but has c la r i f i ed that i t does not apply to conversions.

(Log #477) 101 - 458 - (21-3.3.4.2(a)): Accept in Principle $UBMITTER: William E. Koffel, American Health Care Assn. COMMENT ON PROPOSAL NO.: I01-776 RECOMMENDATION: Retain the Exception from 17-3.4.2(a) For existing buildings, however, change the phrase "hotel desk" to "a constantly attended location". SUBSTANTIATION: No substantiation has been provided indicating the need to no longer accept the Exception in existing buildings. COMMITTEE ACTION: Accept in Principle.

Add the Exception to read: Exception to (a): In exlsting board and care

Faci l i t ies a manual means, as specified in 7-6.2, in excess of the alarm station at a constantly attended location per (b) below, may be waived where there are other effective means (such as complete automatic sprinkler or automatic detectlon systems) For not i f icat ion of f i r e as required. COMMITTEE COMMEN!: The Committee concurs with the Submitter but has c la r i f i ed the application of the Exception.

(Log #37) 101 - 459 - (21-3.3.4.5 Exception): Reject SUBMITTER: Joseph A. Drouin, Simplex Time Recorder Co. COMMENT ON PROPOSAL NO.: 101-778 RECOMMENDATION: Revise 21-3.3.4.5 Exception to read:

Exception: Buildings equipped with a public address system meeting the requirements of NFPA 72F, Instal lat ion, Maintenance and Use of Emergency Voice/Alarm Communication Systems. SUBSTANTIATION: The public address system is being used as part of a l i f e safety system and should meet the supervisory, aud ib i l i ty and standby power requirements of NFPA 72F. This requirement is in the BCMC recommended high rise code. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that a regularly used public address system has adequate r e l i a b i l i t y For the intended use.

(Log #78) I01 - 460 - (21-3.3.4.5 Exception): Reject SUBMITTER: H. Brooke Stauffer, National Electrical Manufacturers Assn. COMMENT ON PROPOSAL NO.: I01-778 RECOMMENDATION: Revise 21-3.3.4.5 Exception to read:

Exception: Buildings equipped with a public address system meeting the requirements of NFPA 72P, Instal lat ion, Maintenance and Use of Emergency Voice/Alarm Communication Systems. SUBSTANTIATION: The public address system is being used as part of a l i f e safety system and should meet the supervisory, aud ib i l i ty and standby power requirements of NFPA 72P. This requirement is in the BCMC recommended high rise code.

COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that a regularly used public address system has adequate r e l i a b i l i t y For the intended use.

(Log #478) 101 - 461 - (21-3.3.4.5 Exception (New)): Accept in Principle SUBMITTER: William E. Koffel, American Health Care Assn. COMMENT ON PROPOSAL NO,: 101-778 RECOMMENDATION: Identi fy the proposed Exception as Exception NO. 1 and add a new Exception to read as follows:

Exception No. 2: Existing buildings. SUBSTANTIATION: The requirement For a voice communication system or public address system did not appear in the 1985 edition. Adequate substantiation has not been provided to require such a system in existing buildings. Proposed Section 30-8 does not apply to existing buildings. COMMITTEE ACTION: Accept in Principle.

Add a new Exception to read: Exception: Existing board and care Fac i l i t ies .

COMMITTEE COMMENT: The Committee agrees with the Submitter but wants to c l a r i f y that i t does not apply to conversions.

(Log #265) I01 - 462 - (21-3.3.4.7): Accept in Principle SUBMITTER: Bernard Levin, National Bureau of Standards COMMENT ON PROPOSAL NO.: I01-779 RECOMMENDATION: Retain, with modification, the Exception to 17-3.4.4 referenced in 21-3.2.2.1, 21-3.3.4.7.

Exception N o . 2: Existing buildings having a corridor detection system, in accordance with 7-6, connected to the building Fire alarm system. SUBSTANTIATION: Existing board and care homes that provide a high level of Fire safety may Find i t very d i f f i c u l t to meet the new requirement i f they are using the Fire Safety Evaluation System to evaluate the safety and i f they also have single station detectors in bedrooms. Investigations of Fires in board and care homes indicate that major f i res tend not to star t in bedroom areas. COMMITTEE ACTION: Accept in Principle.

Revise the Exception to read: Exception No. 2: Existing board and care Fac i l i t ies

having an existing corridor smoke detection system, in accordance with Section 7-6, connected to the building f i r e alarm system. COMMITTEE COMMENT: The Committee concurs with the intent of the Submitter but has made revisions consistent with proposed revisions to Chapter 17 to c l a r i f y the intent of the Committee.

(Log #479) I01 - 463 - (21-3.3.4.7): Reject SUBMITTER: William E. Koffel, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-779 RECOMMENDATION: Revise the Except ion to read as f o l l o w s :

Exception: In existing buildings, battery powered detectors . . . . (remainder unchanged). SUBSTANTIATION: The above language meets the intent of the proponent according to the substantiation. Due to the licensing and inspection procedure For board and care f a c i l i t i e s , the r e l i a b i l i t y of battery powered detectors can be greater than those Found in dwellings. I t should also be noted that a requirement For room detectors was not in the 1985 edition. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The intent of the Committee is to only allow existing detectors to be battery operated. The issue regarding re t roac t i v i t y was addrssed by Comment 101-462 on 21-3.3.4.7 (Log #265).

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(Log #422) I01 ~ ~64 ~ (2l-3.3.5,1): Accept in Principle ~BMITTE~: Harry Bradley, Hyat tsv i l le , HD ~_O_~_H_E_~T__O__N PROPO~S_ALLLL~_Q~_.: 101 - 7 S 2 R__~COHHENDA~I~J~: In 21-3.3.5.1 delete the asterisk.

B SJ~3_TANTIAT~N: This asterisk is not included in the text taken from Chapters 16 and 17 and i t is therefore not clear as to what the intent is as no Appendix note is printed in the preprint. The Appendix note that went with former 21-3.2.2,6 was recommended For removal by T.I.A. 227 and, therefore, the asterisk should be removed. ~ ~ : Accept in Principle.

Retain the asterisk and add the appendix note to read the same as A~21-3,2.2.6. C_Q_MM~TTEECQMHENT: The Committee Feels that rather than deleting the asterisk, retaining the old appendix note would be better.

(Log #299) lO] ~ 4G5 - (2l-3,3.6.2 Exception No. 2): Reject ~t~ITTER: Harry L, Bradley, Hyat tsv i l le , HD C.~UENT_ON PRQ_OPOSAL_N~, : lOl-~70 R E _ ~ . _ O _ H ~ : Change the Fire resistance rating to 20 minutes in new construction. ~LBSTTTTANTIATII0~N: The change would allow For existing health care occupancies converting to a new board and care occupancy. ~TTET~F~A~T~N: Reject. C0~M~TTEEC_QMMENT: The Committee Feels that in a new construction l hr is appropriate. The subject of conversions has been covered by Comment 101-454 on 21-3,2,2.8 [21-3.3.6.3 Exception No. l in rewrite] (Log #473).

(Log #22) 101 - 466 - (21-3.3.G~3 Exceptions NO, l , Z and 3): Reject 5~BMZTT~R: Paul S. Quigg, USG Corp. ~ _ _ _ Q N PROPOSAL N Q~.: 101-752 R ~ A T ~ : Disallow Exceptions No. l , Z and 3, Section 2l-3.3,6.3 which state:

"Exception No. I : In existing buildings such barriers shall have a Fire resistance rating of not less than 20 minutes.

Exception No. 2: In buildings protected throughout by an approved automatic sprinkler system in accordance with 21-3.3.5, Such barriers shall have a f i re resistance rating not less than 30 minutes in new construction and in existing buildings no Fire resistance rating is required.

Exception No. 3: In buildings housing groups capable of prompt evacuation, not greater than two stories in height, with a maximum o f 30 residents, such barriers shall have a f i re resistance rating of not less than 30 minutes in new construction, and not less than 20 minutes in existing buildings." SUB~TAN~IA_T~N: Exceptions No. l , 2 and 3 should be disallowed because residents of existing buildings have no less need for l i f e safety than residents of new buildings. The proposed provision would require one to believe that a 20-minute f i re rated wall would provide the same protection as a l-hour rated wall, and the needs o f residents o f existing buildings are less than the needs of residents of new buildings.

MM TTEE ACTI N: Reject. COMMITTEE COMHENT: See Comment 101-467 on 21-3.3.6.3 Exception NOS. l , 2 and 3 (Log #83).

(Log #B3) 101 - 467 - (21-3.3.6.3 Exceptions No. I , 2 and 3): Reject ~ : Robert A. Wessel, Gypsum Assoc. GOHH~NT_~ PR(ZEQ~_N~O~: I01-752 R E C O M M ~ : Delete Exceptions No. I , 2 and 3 in Paragraph 2 1 4 3 . 3 , 6 , 3 .

SUBSTANTIATIO_~ ~__~ N: These Exceptions permit a reduction in the Fire resistance of Fire barriers in an unfair way. The reduction to Z0 minutes in existing buildings is discriminatory to the occupants of these buildings. I t makes no sense to allow these f i re barriers to be less in existing buildings than in new buildingS. This implies that the occupants of existing buildings do not need the same protection as the occupants of new buildings. Exception No. 1 creates a dispari ty of 40 minutes solely on the grounds that i t is an existing building, I t has not been demonstrated that there is jus t i f icat ion For this action. Exception No. 2 reduces the Fire resistance rating when sprinklers are installed in new construction and to ta l ly eliminates the f i re resistance rating in sprinklered exist ing buildings. Again a disparity between new and exist ing buildings. ~_HMIITTEL_ACS_IQN: Re j e c t . CQ@MITTEE CQMMENT: The Committee intended this d i f ferent iat ion between new and existing buildings since many tradit ional existing walls fa l l into th is category and have performed well, I t is easy to ver i f y construction quality and condition in an existing building, The Code generally Provides a corridor rating reduction in Fully sprinklered buildings and f i re history jus t i f ies this.

(Log #475) 10] - 468 - (21~5.3.6.6): Accept in Part ~_~MITTj~R: William E. Kogfel, American Health Care Assn, MM~_0N PR~O~_NO~: I01-770 RE R_E~0MHHj~NDATIQ~: Revise Exception No. 2 by adding the following at the end of the sentence:

". . , or automatic closing." Add a new Exception to read as Follows: Exception NO. 3: In buildings where the corridors

involved are under continual direct supervision by s ta f f during al l times residents are in the Fac i l i ty . ~JJ~_$_TANT~J!gN: The revision to Exception No. 2 is necessary to c la r i f y the ~ntent of the Commlttee, Otherwise, the requirement for automatic closing doors would s t i l l apply,

Proposed Exception NO. 3 is currently in the Code. AS mentioned in the Committee's substantiation to TCR Proposal 101-764, the Committee admits that a similar exception is theoret ical ly useable. While the Committee may not be able to ident i fy specific applications, i f the Exception has merit i t should be retained. I t is conceivable that a section of a long term care Faci l i ty may provide personal care beds. The same level of staff ing may be retained. With respect to staf f training, the provisions in Chapter 31 For board and care f ac i l i t i e s are more specific and at least equivalent to the requirements For health care occupancies.

I f an existing building complies with the provisions of the Exception and has previously been considered to comply with the Code, why should the Fac i l i ty be considered not complying with the new edition without more adequate substantiation? COMMITTEE A~JIP~N: Accept in Part.

Revise Exception No. 2 as requested but do not add Exception No. 3. C OOMMITTEE COMMEN~: The Committee agrees with the c la r i f i ca t ion of Exception No. 2 but does not feel t l Exception No. 3 is warranted nor jus t i f i ed For a boa and care Fac i l i ty .

(Log #318) lot - 469 - ( 2 1 ~ 3 . 3 , G . 6 ) : Re jec t ~Jd_BMITTER: B i l l Pa rke r , P r o f e s s i o n a l Community Services, Inc. C~M~M_E_~!_~0N PR~'0 P QOSA L NO ~ : I 01 - 770 R~COMMEN PAT I~0.N : Add :

Exception No. 3: In prompt and slow f a c i l i t i e s serving persons who are mentally retarded with a maximum of 8 residents and with at least one sta person on duty and awake at al l times, 24 hours day, doors, other than doors tO hazardous areas not required to be self-closing,

Alternative: "With at least a one-to-Five staff ing ra t io" .

347

SUBSTANTIATION: In small f a c i l i t i e s serving persons who are mentally retarded, s ta f f are Frequently awake and on duty Fcr the purpose of evacuation. Self-closing doors would tend to impede this process. This could be an especially signif icant problem with residents who would tend to become confused in an emergency.

Furthermore, these Faci l i t ies are an attempt to foster a norma|izing, homelike environment. Every new revision of the Life Safety Code seems to be a new obstacle to the goal. Professional Community Services, Inc., operates small, community-based Fac i l i t ies (most are 5 bed home~,) for people who are mentally retarded. In a l l cases, v,e have 24 hour staf f ing. The primary reason For having s ta f f awake at night is for evacuation. OLr Fac i l i t ies are also Fully alarmed with systems monitored by the local f i r e service or a monitoring service.

Self-closing doors would impede independent movement by residents at a l l times. This is especially true with individuals who ~re physically handicapped.

As a trained ~ire Fighter, I recognize the importance OF protection. I am acutely aware of the need For smoke barriers ~ts well . As a professional who has worked for I$ years in services to people who are mentally retarded, however, I also recognize that self-closing doE,rs in these Faci l i t ies w i l l be an unreasonable hirderance.

Small f a c i l i t i e s can be evacuated quickly when s ta f f are awake. This is true even i f residents are slow to respond. Self-closing doors could slow evacuation Signif icant ly.

Sprinkler systems, even those installed under NFPA 130, are of l i t l ~ assistance in such a setting. In fact, I would predict that an activated sprinkler System would Frlqhten many of our cl ients to the point that panic and chaos would prevail.

In l a r g e r f a c i ' i t i e s , the on ly means to ensure Protection is through the use of sprinkler systems and automatic smoke harriers. In small f a c i l i t i e s , however the disadvantage~ - and dangers -- def in i te ly outweigh the benefits. COMMITTEE ACTION: Reject. COMMITTEE COMMENT~ Section 21-3 covers large f a c i l i t i e s (over 16 people).

(Log #261) I01 - 470 - (21-3 4.2): Accept in Principle SUBMITTER: Bernard Levin, Gaithersburg, MD COMMENT ON PROPOS/,L NO.: I01-782 RECOMMENDATION: ~lodify 21-3.4.2 as Follows:

21-3.4.2 New high rise buildings shall comply with Section 30-8. SUBSTANTIATION: This would permit Board and Care Occupancies to be established in or remain in existing buildings without the building being re t ro f i t ted to meet the requirements of Section 30-8. ~OMMITTEE ACTION: Accept in Principle.

See Comment lOl-.171 on 21-3.4.2 (Log #480), COMMITTEE COMMENT: The action taken on I01-471 should sat is fy the intent of the Submitter.

(Log #480) lOl - 471 - (21-3.4.2): Accept SUBMITTER: William E. KofFel, American Health Care Assn. O M i T ON PROPOSAL NO.: I01-782

I RECOMMENDATION: Reject the proposal. SUBSTANTIATION: Th,~ Subcommittee reviewed the BCMC recommendations and developed proposals as necessary. Furthermore, the impact of the proposal would also apply to existing buildings. No other occupancy is required to comply ~ith the provisions of 30-8 for existing buildings.

Adoption of the proposal would create confl icts with other sections of CYapter 21. ~_QMMITTEE AqTION: Accept.

(Log #481) I01 - 472 - (21-4,2.3): Accept ~BMITTER: William E. KoFFel, American Health Care Assn. ~_OMMENT ON PROPOSAL NO,: I01-787 RE_ECQMMENBATION: Revise 21-4.2.3 by revising the last sentence to read as f o l l o w s :

" I n app l y i ng the c o n s t r u c t i o n requ i remen ts , the h e i g h t s h a l l be determined by the he igh t o f the residential board and care Fac i l i ty above the primary level of exi t discharge." ~/IBSTANTIATION: All other building heights in the Chapter are measured from the primary level of exi t discharge. ~MMITTEE ACTION: Accept.

(Log #260) I01 - 473 - (24-1.4.2,1, 25-I.4.2.1): Accept ~UBMITTER: John Behrens, Huntington Beach, CA ~Q_MMENT ON PROPOSAL NO.: lOl-B01 RE~MMENDATION: Change the second part of the Committee Action So as to delete the parenthetical information Following subpart (c) rather than revising i t . ~BSTANTIATION: The proposed wording of subpart (c) per Proposal 101--800 For Chapter 24 and per proposal I01-828 For Chapter 25 adequately explains that a Class C m e r c a n t i l e occupancy may ha~e a sa les area on a mezzanine and s t i l l be a Class C mercantile occupancy i f no more than 3000 sq f t ~n aggregate (main f loor plus mezzanine) is used For sales purposes. ~OMMITTEE ACTION: Accept.

(Log #259) I01 - 474 - (24-1.4.2.3): Accept SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO=: lOl B02 RECOMMENDATION: Retain the same Accept in Principle Committee Action but rather than rewording 24-1.4.2.3 as stated in the Committee Action reference the Committee Action on Proposal 101-800 as meeting the same intent. ~UBSTANTIATIQN: The Committee Action on Proposal 100-800 adequately revises the wording of 24-1.4.2.3. This proposed revision should sat isfy the original proposer's (Proposal I01-802) intent. COMMITTEE ACTION: Accept.

(Log #581) lOl - 475 - (24-1,4.2,3): Reject S_UBMITTER: Roll Oensen, P.E., James Antell, A.I.A., Roll Jensen& Associates, Inc. ~_QMMENT ON PROPOSAL_N_O=: 101-802 R__ECOMMENOATIQN: Delete "but i f there are two mezzanine f loors, one shall be counted". ~9_BSTANTIATION: The revised deFinitlon of mezzanine l imits the aggregate area of multiple mezzanines to I/3 of the Floor area. This l imi tat ion on area should be suf f ic ient to address mezzanines without requiring a second mezzanine to be counted as a Floor level. ~MMITTEE ACTION: Reject. COMMITTEE COMMENT: The wording change proposed by the Commenter is not applicable given the Committee Action on Comment 101-474 on 24-1.4.2,3 (Log #259) which w i l l then address the subject using wording From TCR Proposal No. lOI-800 in place of the wording of TCR Proposal No. 101-802.

(Log #519) I01 - 476 - (24 2.4): Accept in Principle S_~BMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO~: 101-811 RECOMMENOATIQN: Retain requirements For minimum number of exits as well as minimum number of means of egress.

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SUBSTANTIATION: The text as proposed by the Subcommittee w i l l no longer establish minimum number o f exits. This could potent ia l ly le t a two or three story building exist with no exits on the upper f loor , only ex i t access which in the past has not been allowed. ~OMMITTEE ACTION: Accept in Principle.

Revise current 24-2.4 in ent irety as follows: 24-2.4 Number of Exits. 24-2.4.1 At least two separate exits shall be

accessible Fro~ every part of every f loor, including f loors below the street f loor .

Exception: In a Class C mercantile occupancy where travel distance is not more than 75 f t (22.9 m) or lO0 f t (30.5 m) when the story on which i t is located is protected throughout by an approved automatic sprinkler system in accordance with Section 7-7, to the exit or covered mall, ~hen i t is considered as a pedestrian way, a single e'<it shall be permitted. COMMITTEE COMMENT: The above Committee Action should sat isfy the Co~menter's intent. The proposed wording of the basic requirement, i . e . , 24-2.4.1, draws from wording of the current (1985) edition because any reference to proposed Section 5-4 would lose the concept of numker of "exits" and only result in a minimum number of "means of egress".

(Log #582) I01 - 477 - (24-2.4): Reject SUBMITTER: RolF Jensen, P.E., James Antell, A.I.A., Roll Jensen & #ssociates, Inc. COMMENT ON PROFOSAL NO.: lOI-al l RECOMMENDATION: Revise proposed 24-3.4 Exception as follows:

Exception: In Class C mercantile occupancies, a single means of egress shall be permitted i f travel distance to the exi t (or covered mall i f i t is considered to ~e a pedestrian way) is less than 75 f t in unsprinklerEd buildings or lO0 gt in buildings protected throughout by an approved automatic sprinkler system in accordance with Section 7-7. SUBSTANTIATION: Clar i f ies intent. COMMITTEE ACTICN: Reject. COMMITTEE COMMENT: The wording proposed by the Commenter woulc lose the concept of having to sprinkler only the story involved, rather than the entire building, in order to tolerate a longer travel distance in the single ( x i t case. The Committee's intent is to retain the current concept of having to sprinkler only the story involved.

(Log #169) I01 - 478 - (2(-2.11): Accept SUBMITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-808

I RECOMMENDATION: Delete a l l of current 24-2.11. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places a l l the acceptable means of egress comp(,nents For this occupancy and their associated "special features" together in the 2.2 section of thi~. occupancy chapter. Some of the proposed wording For this expanded 2.2 section comes from the 2.11 Special Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTI(~: Accept.

(Log #140) lOl - 479 - (2~-2.11.7): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROf~AL NO.: I01-816 RECOMMENDATION: In the revised 2.2 section of the occupancy chapter, which addresses acceptable means of egress components, reword the item dealing with alternating tread devices so as to change the parenthetical reference "(see 5 -2 . l i ) " to the sentence "Alternating tread devices complying with 5-2.11 are permitted."

SUBSTANTIATION: Coordination with the Format of the other 2.2 section l~sts of acceptable components of the means of egress. COMMITTEE ACTION: Accept.

(Log #583) I01 - 480 - (24-3.1): Accept SUBMITTER: Roll Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-817 RECOMMENDATION: Revise proposed 24-3.1 Exception l (a) and (b) as Follows:

(a) Between any two f loors. (b) Between the street f loor and the First adjacent

Floor below and the First adjacent Floor (or mezzanines) above. SUBSTANTIATION: Clar i f ies intent. COMMITTEE ACTION: Accept.

(Log #184) lOl - 481 - (24-4.2): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: lOI-821 RECOMMENDATION: Insert, before the actual sentence with the requirement, a boldface type heading "High-Rise Buildings." SUBSTANTIATION: The boldface type heading w i l l call attention to the new requirement and set i t o f f as a separate subject From the items which precede and Follow i t . COMMITTEE ACTION: Accept.

(Log #584) lOl - 482 (24-4.2): Accept in Principle SUBMITTER: Roll Jensen, P.E., James Antell, A.I.A., RoIF Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-821 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The high-rise provisions were added by the Main Committee with no review by the Sub-committees. This comment is being submitted to allow the Sub-committee to review the proposal and make changes to coincide with the specific needs of the occupancy group. COMMITTEE ACTION: Accept in Principle.

Create a 24-4.2 to read: 24-4.2 Nigh Rise Buildings. No requirements.

COMMITTEE COMMENT: The Fire record with respect to mercantile occupancies is such that the high rise package of requirements is not needed. Current 24-3.5.1 would already require high rise mercantile occupancies to be sprinklered. Current 24-3.4.1 would, s imi lar ly , require an alarm system.

(Log #520) 101 - 483 - (25 2 . 4 ) : Accept i n P r i n c i p l e SUBMITTER: F r e d e r i c k Maynard, New London, CT COHHENT ON PROPOSAL NO.: 101-831 RECOMMENDATION: R e t a i n r e q u i r e m e n t s For min imum number of exits as well as minimum number of means of egress. SUBSTANTIATION: The text as proposed by the Subcommittee w i l l no longer establish minimum number of exits. This could potential ly le t a two or three story building exist with no exits on the upper f loor , only exi t access which in the past has not been allowed. COMMITTEE ACTION: Accept in Principle.

In the text recommended by Proposal I01-831, change the term "means of egress" to "exits" in the 25-2.4 heading and in paragraphs 25-2.4.1, 25-2.4.2, and the 25-2.4.3 base requirement. Change "means of egress" to "ex i t " in 25-2.4.3 Exception Nos. l and 2. COMMITTEE COMMENT: The Committee Action should sat is fy the Commenter's intent.

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(Log #170) 101 484 (25-2.11): Accept SUBMITTER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO,: I01-830 RECOMMENDATION: Delete a l l of current 25-2.11. SVBSTANTIATION; The Committee Proposal, on which th is comment is being made, places a l l the acceptable means of egress components fo r th is occupancy and t he i r associated "special Features" together in the 2.2 section of th is occupancy chapter. Some of the proposed wording fo r th is expanded 2.2 section comes From the 2.11 Special Features port ion of the current (1985 edi t ion) chapter. Without the proposed delet ions the requirements would appear twice and serve to confuse the user COMMITTEE ACTION Accept.

(Log #141) I01 - 485 - (25-2 11.9): Accept SUBHITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-834 RECOMMENDATION: In the revised 2.2 section of the occupancy chapter, which addresses acceptable means of egress components, reword the ~tem dealing with a l te rnat ing tread devices so as to change the parenthetical reference "(see S 2.11)" to the sentence "Al ternat ing tread devices complying with 5-2.11 are permit ted." SUBSTANTIATION: Coordination with the Format of the other 2.2 section l i s t s of acceptable components of the means o f egress. COMMITTEE ACTION: Accept.

(Log #521) 101 - 486 - (26-2.4): Accept in Pr inc ip le SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: 101 846 RECOMMENDATION: Retain requirements fo r minimum number o f e x i t s as we l l as minimum number of means o f egress. SUBSTANTIATION: The t e x t as proposed by the Subcommittee w i l l no l onge r e s t a b l i s h minimum number o f e x i t s . Th is could p o t e n t i a l l y l e t a two or th ree s t o r y b u i l d i n g e x i s t w i t h no e x i t s on the upper F l oo r , on ly e x i t access which in the past has not been a l l owed . COMMITTEE ACTION: Accept in P r i n c i p l e .

Revise 26-2.4 SO as to: I . Use wording of current (1985 edi t ion) base

paragraph 26-2.4. 2. Use wording of the new replacement Exception No.

l per TCR Proposal No. I01-847 but change "means of egress" to "ex i t s " .

3. Use wording of current (1985 ed i t ion) Exception No. 2. COMMITTEE COMMENT: The Committee Action should sa t i s fy the Commenter's i n t e n t . A lso see Committee Comment on Comment I01-47G on 24-2 .4 (Log #519) w i t h respec t to not r e f e r e n c i n g Sec t ion 5-4.

(Log #171) I01 - 487 - ( 2 6 - 2 . 1 1 ) : Accept SUBHITTER: John A. Shar ry , Lawrence L ivermore L a b o r a t o r i e s COMMENT ON PROPOSAL NO.: 101-843

I RECOMMENDATION: Dele te a l l o f c u r r e n t 26 -2 .11 . SUBSTANTIATION: The Committee Proposa l , on which t h i s comment i s being made, p laces a l l the accep tab le means o f egress components f o r t h i s occupancy and t h e i r assoc ia ted " spec ia l f e a t u r e s " t o g e t h e r in the 2.2 s e c t i o n o f t h i s occupancy chap te r . Some o f the proposed wording For t h i s expanded 2.2 s e c t i o n comes From the 2.11 Specia l Features p o r t i o n o f the c u r r e n t (1985 e d i t i o n ) chap te r . Wi thout the proposed d e l e t i o n s the requ i rements would appear tw i ce and serve to confuse the user . COMMITTEE ACTION: Accept.

(Log #142) I01 - 488 - (26-2.11.6): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-851 RECOMMENDATION: In the revised 2.2 section of the occupancy chapter, which addresses acceptable means of egress components, reword the item dealing with a l te rnat ing tread devices so as to change the parenthetical reference "(see 5-2.11)" to the sentence "Al ternat ing tread devices complying with 5-2.11 are permit ted." SUBSTANTIATION: Coordination with the Format of the other 2.2 section l i s t s of acceptable components of the means of egress. COMMITTEE ACTION: Accept.

(Log #185) I01 - 489 ( 2 6 - 4 . 2 ) : Accept SUBHITTER: John A. Sharry , Lawrence-L ivermore L a b o r a t o r i e s COMMENT ON PROPOSAL NO.: 101-856 RECOMMENDATION: I n s e r t , be fo re the ac tua l sentence w ; th the requ i remen t , a bo ld face type heading "H igh -R ise B u i l d i n g s . " SUBSTANTIATION: The bo ld face type heading w i l l c a l l a t t e n t i o n to the new requ i rement and set i t o f f as a separa te s u b j e c t From the items which precede and Fo l low i t . COMMITTEE ACTION: Accept.

(Log #585) 101 - 490 (26 4.2): Accept in Pr inc ip le SUBMITTER: Roll Jensen, P.E., James Ante l l , A . I .A . , RoIF Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-856 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The h igh-r ise provisions were added by the Main Committee with no review by the Sub committees. Thls comment is being submitted to al low the Sub-committee to review the proposal and make changes to colncide with the spec i f ic needs of the OCCUpancy group. COMMITTEE ACTION: Accept in Principle.

Revise c u r r e n t 26-4.2 as Fo l lows : 26 4 .2" High Rise B u i l d i n g s . A 26-4 .2 (pe r c u r r e n t 1985 e d i t i o n appendix w o r d i n g ) . 26 4.2.1 Genera l . In a d d i t i o n to the requ i rements

o f t h i s s e c t i o n , a l l h igh r i s e b u i l d i n g s s h a l l comply w i t h a l l o t h e r a p p l i c a b l e p r o v i s i o n s o f t h i s Code.

2 6 - 4 . 2 . 2 Ex t ingu ishment Requirements. High r i s e b u i l d i n g s s h a l l be p ro tec ted th roughou t by an e l e c t r l c a l l y superv i sed , approved, au tomat i c s p r i n k l e r system i n s t a l l e d in accordance w i t h Sec t ion 7-7. A s p r i n k l e r c o n t r o l va l ve and a water Flow dev ice s h a l l be p rov ided f o r each F loo r .

2 6 - 4 . 2 . 3 De tec t i on , Alarm and Communication Systems, 26 4 .2 .3 .1 Genera l . De tec t i on , a la rm and

communicat ion systems as s p e c i f i e d by 2 6 - 4 . 2 . 3 . 2 and 26 4 . 2 . 3 . 3 s h a l l be prov lded in a l l b u i l d i n g s w i t h an occupied s t o r y 150 f t or more in h e i g h t measured From the lowest l e v e l o f f i r e department v e h i c l e access.

26 4.2.3.2 A f i r e alarm system u t i l i z i n g voice communication shall be ins ta l led in accordance with Section 7-6.

26-4.2.3.3 Two-way telephone communication service shall be provided For Fire department use. This system shall be in accordance with NFPA 72F, Standard For the I n s t a l l a t i o n , Maintenance and Use of Emergency Voice/Alarm Communication Systems. The communication system s h a l l opera te between the c e n t r a l c o n t r o l s t a t i o n and every e l e v a t o r car , every e l e v a t o r lobby , and each F loo r l e v e l o f e x i t s t a i r s .

Excep t i on : When the F i re department r a d i o system is approved as an e q u i v a l e n t system.

2 6 - 4 . 2 . 4 Standby Power. Standby power in accordance w i t h NFPA 70, Na t i ona l E l e c t r i c a l Code, A r t i c l e 701 s h a l l be p rov i ded . The standby power system s h a l l have a c a p a c i t y and r a t i n g s u f f i c i e n t to supp ly a l l r e q u i r e d equipment. S e l e c t i v e load p i ck -up and load shedding s h a l l be p e r m i t t e d in accordance w i t h NFPA 70, Na t i ona l E l e c t r ~ c a l Code. The standby power system s h a l l be connected to the Fo l l ow ing :

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(a) Emergency lighting system (b) Fire alarm system (c) Electric f i r e pump (d) Central Control Station equipment and l ighting (el At least one elevator serving a l l f loors and be

transferable to any elevator ( f ) Mechanical equipment for smokeproof enclosures, 26-4.2.5 ~ Central Control Station. A central

control station slball be provided in a location approved by the f i r e department. The control station shall contain:

(a) Voice f i r e alarm system panels and controls (b) Fire department two-way telephone communications

service panels and controls (c) Fire detection and f i r e alarm system

annunciation panels (d) Elevator f loor location and operation

annunciators (el Sprinkler valve and water Flow annunciators ( f ) Emergen¢y generator status indicators (g) Control~ for any automatic stairway door

unlocking syst(m (h) Fire pump status indicators ( i ) A telephone for Fire department use with

controlled access to the public telephone system. A-26-4.2.5 ] t is not the intent of the paragraph to

require any of the equipment in the l i s t , other than the telephone f'or f i r e department use, but only to provide the controls, panels, annunciators, and similar equipment at this location when the equipment is provided or required by another section of the Code. COMMITTEE COMMENT: The Committee agrees that high rise business occup~ncies should be sprinklered and current 26-4.2.1 does require this. The proposed Section 30-8 wording with respect to sprinkler systems is an improvement and should apply. However, the Section 30-8 requirements w i l l not be referenced because other provisions of (.hat section need revision. Thus, rather than referencing part of proposed Section 30-8, a wholly self-contained section 26 4.2 has been drafted.

With respect to alarm systems, new high rise business occupancies would be required to have a Fire alarm system per current 26-3.4.1, The Committee has chosen to have the additional voice communication and two-way telephone communication service requirements apply at the 150 f t hei~lht rather than at 75 f t . The 150 f t c r i t e r i a transates to approximately a 12 story building. There is substantial data (From the National Research Counc l of Canada and the U.S. National Bureau of Standards) to show that general building evacuation can be accomplished in buildings 12 or Fewer stories in height.

With respect tc, two-way telephone communication requirements, the same 150 f t height c r i t e r i a has been specified because the technology of portable two-way communication units has improved greatly and, thus, equipment available to Fire departments should be adequate to serve buildings 12 or fewer stories in height.

The provisions on standby power do not address emergency ligh;ing because emergency l ighting is required For new high rise buildings occupancies per current 26-2.9.1. See the above proposed 26-4.2.1 which reminds :he user that the other requirements of this Code appIK.

The standby lower requirement w i l l not reference NFPA llO because as the Committee reviewed NFPA 110 i t was obvious that, when used in con3unction with NFPA 70, al ternative ar-angements would be prohibited. A specif ic reference to NFPA 70 Ar t ic le 701 was developed for consistencK with other codes and because Ar t ic le 701 provides o~tions.

The Committee Action should sat is fy the Commenter's intent.

S~STANTIATION: The text as proposed by the Subcommittee w i l l no longer establish minimum number of exits. This could potent ial ly le t a two or three story building exist wlth no exits on the upper f loor , only ex i t access which in the past has not been allowed. COMMITTEE ACTION: Accept in Principle.

Revise the text proposed by TCR Proposal I01-862 so as to change "means of egress" to "exits" in a l l three places where i t appears. Also, in TCR Proposal 847, revise the text of the 27-2.4 Exception No. I so as to change "means of egress" to "ex i t " . COMMITTEE COMMENT: The Committee Action should sat is fy the Commenter's intent.

(Log #172) I01 - 492 - (27-2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-861 ~OMMENDATION: Delete a l l of current 27-2.11. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places a l l the acceptable means of egress components for this occupancy and thei r associated "special Features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording For this expanded 2.2 section comes From the 2.11 Special Features portion of the current (1985 edition) chapter, Without the proposed deletions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #143) I01 - 493 (27-2.11.7): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-864 RECOMMENDATION: In the revised 2.2 section of the occupancy chapter, which addresses acceptable means of egress components, reword the item dealing with alternating tread devices so as to change the parenthetical reference "(see S-2.11)" to the sentence "Alternating tread devlces complying with 5-2.11 are permitted." SUBSTANTIATION: Coordination with the Format of the other 2.2 section l i s t s of acceptable components of the means of egress. COMMITTEE ACTION: Accept.

(Log #363) I01 - 494 - (28-2.2.2.4): Accept SUBMITTER: Andrew P. Scitt lne, AT&T Technologies ~MMENT ON PROPOSAL NO=: 101-867 RECOMMENDATION: At the end of 28 2.2.2.4 add "See 28-2.2.5.2". SUBSTANTIATION: Sliding doors in horizontal exits have di f ferent closing requirements when a door is used on one side of the wall only compared to when a sliding door is used on one side of the wall and swinging doors used on the other side of the wall.

The former ins ta l la t ion requires self-closing or automatic closing by smoke detection and the la t te r insta l la t ion permits automatic sliding. COMMITTEE ACTION: Accept. COMMITTEE COMMENT: The Committee accepts the proposed addition of the cross reference as an aid to the Code user without agreeing f u l l y with the substantiation.

(Log #522) I01 - 491 - (27-2.4): Accept in Principle SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO,: I01-862 RECOMMENDATION: Retain requirements for minimum number of exits as well as minimum number of means of egress.

(Log #523) lOl - 495 - (28-2.4): Accept SUBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: lOI-86B

I RECOMMENDATION: Retain requirements For minimum number of exits as well as minimum number of means of egress.

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SUBSTANTIATION: The text as proposed by the Subcommittee w i l l no longer establish minimum number of exi ts. This could potent ia l ly let a two or three story building exist with no exits on the upper Floors, only ex i t access which, in the past, has not been allowed. COMMITTEE ACTION: Accept.

Therefore, text w i l l read: 28-2 .4 Number of E<I ts . 2 8 - 2 , 4 . I No less than two e x i t s s h a l l be p rov ided

Excep t ion to be worded per TCR Proposal No. I01 869. COMMITTEE COMMENT: The Committee Ac t i on o f "Accept" w i t h the reword ing shown above shows whlch words w i l l change. Th is should meet the Commenter's i n t e n t .

(Log #586) I01 - 496 (28-2.4.2): Accept SUBMITTER: Roll Jensen, P.E., James Antel l , A.I .A., Roll Jensen& Associates, Inc COMMENT ON PROPOSAL NO.: 101-870 RECOMMENDATION: Revise 28-2.4.2 to read as Follows:

28-2•4.2 Floors or portions thereof . . . . SUBSTANTIATE: The number of exits should be based on the Floor OCCUpant load, not the building occupant load. COMMITTEE ACTION: Accept.

(Log #432) I01 497 - (28 2.6.2(b) and (c)): Reject SUBMITTER: Peter Lamb, East Lyme Fire Marshal's OFfice, CT COMMENT ON PROPOSAL NO.: lOt 871 RECOMMENDATION: Add the Following to 28 2.6.2:

(b) Shall l im i t i n te r io r Finish to Class A or Class B.

(c) Shall provide emergency l lght ing. ~UBSTANTIATION: The Committee provided absolutely no substantiation For deleting these provisions From the present 28-2.6.2. Seeing that the Code allows Class C under the general i n te r io r provisions of 28-3.3.1 i t seems appropriate to retain this l im i ta t ion under 28-2•6.2 when such large travel distances are permitted. In addition, emergency l ight ing is exempted under certain conditions in 28-2•9.1 and under the extended travel distance should not be permitted. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: With respect to i n te r io r f in ish , Class A, B or C in te r io r wall and cei l ing Finish is adequate for this sprinklered buildlng with i ts means of smoke control in this non sleeping occupancy. With respect to emergency l ight ing, current 28 2.9.1 already requires emergency l ight ing under almost a l l conditions and needs not be repeated here as a condition For an increase in travel distance•

(Log #230) 101 - 498 - (28 2.6.3 and A 28-2.6.3): Reject SUBMITTER: Leonard R. Hathaway, Chicago, IL COMMENT ON PROPOSAL NO.: 101-872 RECOMMENDATION: Add a new paragraph in the Appendix, as follows:

A-28-2.G.3 Power generating plant turbine buildings and boi ler buildings having f i r e suppression systems in accordance with the NFPA recommended practice applicable to that Fac i l i ty , meet the intent of Section 28-2.6.3 for travel distances up to 400 f t . SUBSTANTIATION: I t iS recognized that the proposed revision to section 28-2.6.3 w i l l increase the travel distance For unsprinklered, ordinary hazard, special purpose industrial occupancies to 300 f t . We wish to compliment the L i fe Safety Committee For the i r action in making this progressive change. However, our Committee is s t i l l concerned that the turbine and boi ler buildings in power plants are of such unique construction that they deserve Special consideration. Of part icular concern are the areas with high bay ceil ings (50 to tOO f t high) where automatic sprinklers would be to ta l l y inef fect ive.

NFPA 850 and the proposed NFPA 851 p r o w d e recommendations f o r au tomat ic F i r e suppress ion systems For most areas o f the b u i l d i n g s . See note below For summary o f recommendat ions. IF p r o t e c t i o n is p rov ided f o r the t u r b i n e and b o i l e r b u i l d i n g s in accordance w i t h these recommended p r a c t i c e documents, i t is f e l t to be e q u i v a l e n t to p r o v i d i n g au tomat ic s p r i n k l e r s t h roughou t an ordinary hazard special purpose industr ial occupancy• This is due to the Fact that the areas of concern w i l l be protected in a structure consistlng of s tee l and conc re te .

Fu l l sca le f ~ r e t e s t i n g For r o l l paper s to rage performed by Factory Mutual Research (see Fire Journal, September 1980, page 43) demonstrated that as the distance between the top of a storage area and the cei l ing sprinklers increases, the more d i f f i c u l t ~t becomes to control the f i r e . Th~s effect also applies to other combustible materials, The hazards ~n the turbine and boi ler buildings consist primari ly of combustible l iquids enclosed within operating equipment and located 50 to lOO f t below the building roof, so cei l ing level sprinklers in accordance with section 28-2.6.3 would be an inef fect ive Form of protection.

The Committee Comment made in the TCR, Proposal lot 872, is that during periods of maintenance and rebuilding, combustibles get spread over larger areas outside the area of Fixed protection. We Feel that this concern is addressed by the Following:

I. NFPA 850 and 851 recommend that a Fire prevention program be established For the control of transient combustibles or other conditions that may increase Fire hazards•

2. The major combus t i b les ( t u r b i n e genera to r l u b r i c a t i n g o i l , hydrogen and b o i l e r Fuels) are min imized du r i ng pe r iods of maintenance or r e b u i l d i n g because the u n i t w i l l be shut down.

3. Smoke From most F i res w i l l r i s e away f rom egress paths and w i l l not cause a l i f e s a f e t y problem due to the na tu re o f c o n s t r u c t i o n in the b o i l e r and t u r b i n e b u i l d i n g s ( i . e . , h igh bay c e i l i n g s , l a rge openlngs in F loors , and use o f g ra ted f l o o r s ) .

NOTE: Summary o f recommendations in NFPA 880 " F i r e P r o t e c t i o n For Foss i l Fueled Steam E l e c t r i c Genera t ing P lan t s " and 851 " F i r e P r o t e c t i o n For H y d r o e l e c t r l c Generat ing P l a n t s " ( t o be re leased in 1987) f o r F i re suppress ion in the t u r b i n e and b o i l e r b u i l d i n g s :

a. NFPA 850 recommends t h a t an au tomat lc s p r i n k l e r system be p rov ided in the t u r b i n e b u i l d i n g f o r the Floors beneath the turbine--generator operating f loor . Also a sprinkler System should be provided for the turbine-generator bearings and the tube o i l l~nes above the operating Floor. Fire suppression systems are also recommended f o r o the r hazards w l t h i n the t u r b i n e b u i l d i n g .

b. NFPA 850 recommends t h a t the bo~ le r b u i l d i n g be prov ided w i t h an au tomat ic F i re suppress ion system For the b o i l e r Front o i l hazard areas (bu rne rs , p i p i n g , o i l c o l l e c t i o n areas, and s t r u c t u r a l members and walkways on burner l e v e l s ) .

c. NFPA 851 recommends t h a t a f i r e suppress ion system be p rov ided in the t u r b i n e b u i l d i n g For a l l lube o i l hazards areas (reservoirs, pumps, piping, o i l collection areas, and distances within 20 f t of o l l l ines). COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee believes that local application extinguishing systems are not the equivalent of automatic sprinkler protection throughout a building as previously explained in the Committee Comment on TCR Proposal No. I01 872. AIso, interpretations of equivalency should be l e f t to the authority having ju r i sd ic t ion and thus wording, as proposed by the Commenter, ~s inappropriate For inclusion in the Code.

(Log 4173) 101 - 499 - ( 2 8 - 2 . 1 1 ) : Accept SUBMITTER: John A. Shar ry , Lawrence-L ivermore Laboratories qOMMENT ON PROPOSAL NO.: I01-867

I RECOMMENDATION: Delete a l l of current 28-2.11.

352

SUBSTANTIATION: The Committee Proposal, on which this comment is beirg made, places a l l the acceptable means of egress components for this occupancy and their associated "spEcial Features" together in the 2.2 section of thi~ occupancy chapter. Some of the proposed wordirg For this expanded 2.2 section comes from the 2.11 Epecial Features portion of the current (1985 edition) chapter. Without the proposed deletions the requirements would appear twice and serve to confuse the user . COMMITTEE ACTICN: Accept .

(Log #144) 101 - SO0 - (2E-2.11.4): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROFOSAL NO.: I01-877 RECOMMENDATION: In the revised 2.2 section of the occupancy chapter, which addresses acceptable means of egress componerts, reword the item dealing with alternating tread devices so as to change the parenthetical reference "(see 5-2.11)" to the sentence "Alternating tread devices complying with 5-2.11 are permitted." SUBSTANTIATION: Coordination with the format of the other 2.2 section l i s t s of acceptable components of the means o f egress. COMMITTEE ACTICN: Accept .

(Log #433) 101 - 501 - (2~-3.6): Reject SUBMITTER: Peter Lamb, East Lyme Fire Marshal's OFFice, CT COMMENT ON PROFOSAL NO.: I01-880 RECOMMENDATION: Revise 28-3.6 to read:

"Corridors. The provisions of 5-I.3.4 shall apply. Exception: Existing buildings."

SUBSTANTIATION: The provisions of 5-1.3.4 have applied to al l occupancies unless speci f ica l ly exempted. Chapter 28 has not spec i f ica l ly exempted this in the past and absoILtely no substantiation has been provided for this blanket exemption. This is a Far sweeping signif lcant l i f e safety change with no documentation provided. COMMITTEE ACTICN: Reject. COMMITTEE COMMENT: The Subcommittee on Industrial and Storage Occuparcies never intended that the corridor provisions of Chapter 5 should apply. The occupancy in question is not a sleeping occupancy and occupants are usually Familiar with their surroundings as opposed to occupants of residential and assembly occupancies, for example. There is precedence For exempting occupancies from the ChaptEr 5 requirements. For example, slngle tenant areas within business occupancies are exempt. Even health care occupancies exempt corridor walls in sprinklered buildings.

(Log #186) I01 - 502 - (2E-4.2): Accept SUBMITTER: JoFn A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROFOSAL NO.: I01-881 RECOMMENDATION: Insert, before the actual sentence with the requirement, a boldface type heading "High Rise Buildings." SUBSTANTIATION: The boldface type heading w i l l cal l attention to t fe new requirement and set i t o f f as a separate subject from the items which precede and fol low i t . COMMITTEE ACTICN: Accept. COMMITTEE COMMENTT: Also see the Committee Action on Comment 101-502 on 28-4.2 (Log #209).

(Log #209) I0l - 503 - (2E-4.2): Accept in Principle SUBMITTER: Gregory Thomas, Liberty Mutual Insurance COMMENT ON PROFOSAL NO.: 101-881 RECOMMENDATION: Delete the requirement that high-rise buildings must comply with Section 30-8.

SUBSTANTIATION: Many occupancies which f a l l in the industrial chapter would not e f fec t i ve ly benefit from the provisions of 30-8. Some have limited routine human occupancy, others such as special purpose industrial occupancies do not Fit the general concept of a high-rise building. AIso, the occupants may be better equipped For self-preservation than those of other occupancies. COMMITTEE ACTION: Accept in Principle.

Create a 28-4.2 to read: 28-4.2 High Rise Buildings. No requirements.

COMMITTEE COMMENT: The Committee Action should meet the Commenter's intent.

(Log #587) lOl - 504 - (28-4.2): Accept in Principle SUBMITTER: Role Jensen, P.E., James Antell, A.I.A., Role Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-881 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The high-rise provisions were added by the Main Committee with no review by the Sub-committees. This comment is being submitted to allow the Sub-committee to review the proposal and make changes to coincide with the specific needs of the occupancy group. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment I01-503 on 28-4.2 (Log #209). COMMITTEE COMMENT: The Committee Action on Comment I01-503 (Log #209) should meet the Commenter's intent.

(Log #279) 101 - 505 - (28-4.2 Exception): Reject SUBMITTER: Daniel M. McGee, American Iron and Steel Inst i tute COMMENT ON PROPOSAL NO.: I01-881 RECOMMENDATION: Revise proposed section 28-4.2 to include additional Exception.

Exception: Existing buildings. Special industrial uses including among others; e lec t r ic , gas or steam generating f a c i l i t i e s , ro l l ing mi l ls , structural metal fabricating shops and Foundries. Use Group H - High Hazard. SUBSTANTIATION: The BCMC recommendations on high rise building provisions speci f ica l ly omltted certain use groups From the special requirements because they were not suitable or not needed.

The above Exception should be included here or in Section 30-8. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The changes proposed by the Commenter are not applicable given that the Committee Action on Comment I01-503 on 28-4.2 (Log #209) w i l l result in no special requirements fOr high rise buildings.

(Log #366) I01 - 506 - (29-2.2.2.3): Reject SUBMITTER: Andrew P. Scitt ine, AT&T Technologies COMMENT ON PROPOSAL N O~: I01-883 RECOMMENDATION: Replace "occupant load" with "occupancy" and add "persons" a f ter "F i f t y " . SUBSTANTIATION: There are no requirements for an occupant load in storage occupancies. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: "Occupant load" is the correct term. See the Chapter 3 def ini t ions of "occupancy" and "occupant load".

(Log #362) I01 - 507 - (29-2.2.2.4): Accept SUBMITTER: Andrew P. Scitt ine, AT&T Technologies ~OMMENT ON PROPOSAL NO.: I01-883 I RECOMMENDATION: At the end of 29-2.2.2.4 add "See 29-2.2.5.2".

353

SUBSTANTIATION: Sliding doors in horizontal exits have d i f fe rent closing requirements when a door is used on one side of the wall only compared to when a sl id ing door is used on one side of the wall and swinging doors used on the other side of the wall.

The former ins ta l la t ion requires self-closing or automatic closing by smoke detection and the la t te r ins ta l la t ion permits automatic s l id ing. COMMITTEE ACTIOn: Accept. COMMITTEE ~OMHENT: AIso see Committee Comment on Comment 101-494 on 28-2.2.2.4 (Log #363).

(Log #524) 101 - 508 - (29-2.4): Reject $UBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: I01-884 RECOMMENDATION: Retain requirements for minimum number of exits as well as minimum number of means of egress. SUBSTANTIATION: The text as proposed by the Subcommittee w i l l no longer establish minimum number of exi ts. This could potent ia l ly let a two or three story building exist with no exi ts on the upper Floors, only ex i t access which, in the past, has not been allowed. COMMITTEE ACTIOn: Reject. COMMITTEE COMMENT: Current paragraph 29 2.4.1 already uses the term "means of egress" rather than "exits" and, therefore, the boldface heading of 29-2.4 should track the wording of 29-2.4.1 and read: Number oF Means of Egress.

(Log #355) 101 - 509 - (29-2.4.1 Exception NO. 1 and Exception No. 2 (New)): Accept in Principle $UBMITTER: Bruce W. Hisley, Fire Marshal's Assn. of North America COMMENT ON PROPOSAL NO.: I01 885 RECOMMENDATION: Revise the Exception to 29-2.4.1 and add additional new Exception to read as follows:

Exception No. l : In low hazard storage occupancies a single means of egress shall be permitted From any story or section when the structure is of noncombustible construction.

Exception No. 2: In low and ordinary hazard storage occupancies a single means of egress shall be permitted From any story or section provided that the ex i t can be reached within the distance allowed as common path of t ravel . SUBSTANTIATION: As i t stands now the Exception as submitted was rejected by the Main Committee which means that the or iginal Exception s t i l l stands. The Exception needs to be c la r i f i ed as to intent, and additional consideration For low hazard occupancies considered.

Exception No. I is wri t ten to allow For the use of a single means of egress in those occupancies used For the storage of low hazard contents that pose no danger from f i r e from within the occupancy i t s e l f . This Exception also notes that the structure be of noncombustible construction. Within Section 4-2.2 (c lass i f icat ion of hazard of contents) only the contents need to be considered in determining hazard c lass i f icat ion. In determining the total f i r e hazard r isk to the occupant the combustible construction characteristic of the structure must also be considered. I t would be t o t a l l y unreasonable to allow a single means of egress of unlimited travel distance in a structure of combustible construction.

Exception No. 2 is wri t ten to allow for the use of a single means of egress in those occupancies used For low hazard storage, but are not of noncombustible construction, and ordinary hazard storage occupancies. The single means of egress would be permitted i f the travel distance to reach an ex i t did not exceed the allowed common path of travel as noted in section 29-2.5.I (Exception). I believe that i t was the Subcommittee's intent to recognize the need to allow for a common path of travel when the or iginal Exception to 29-2.4.1 was changed in the 1981 edit ion of the Code and carried over into the 1985 edit ion of the Code.

COMMITTEE ACTION: Accept in Principle. I Replace the current Exception to 29-2.4.1 with the

Following two Exceptions: Exception No. 1: In low hazard storage OCCupancies a

i single means of egress shall be permitted From any I story or section.

Exception No. 2: In ordinary hazard storage i occupancies a single means of egress shall be permitted

From any story or section provided that the ex i t can be reached within the distance allowed as common path of travel (see 29-2.5.I Exception). COMMITTEE COMMENT: The Committee Action should sat isfy the Commenter's intent.

(Log #589) lOl - 510 - (29-2.4.2): Accept SUBMITTER: Rolf Jensen, P.E., James Antel l , A.I.A., Role Oensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-88G I RECOMMENDATION: Revise 29-2.4.2 to read as follows:

29-2.4.2 Floors or portions thereof . . . . SUBSTANTIATION: The number of exits should be based on f loo r occupant load, not building occupant load. COMMITTEE ACTION: Accept.

(Log #368) 101 - 511 - (29-2.4.2): Reject SUBMITTER: Andrew P. Scit t ine, AT&T Technologies COMMENT ON PROPOSAL NO.: I01-886 RECOMMENDATION: Replace "occupant load" with "occupancy" and add "persons" af ter "500". SUBSTANTIATION: There are no requirements For an occupant load in storage occupancies. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: "Occupant load" is the correct term. See the Chapter 3 def in i t ions of "occupancy" and "occupant load".

(Log #352) 101 - 512 - (29-2.4.2): Reject $UBMITTER: Bruce W. Hisley, Fire Marshal's Assn. of North America COMMENT_ON PROPOSAL NO.: I01-886 RECOMMENDATION: The proposed new 29-2.4.2 is F~ne as writ ten, however there is a need to establish an occupant load Factor in o rder to de termine compl iance. Prov ide an occupant load Factor o f 300 sq g t gross f l o o r area For sec t i on 29 -1 .7 , SUBSTANTIATION: This sec t i on r e f e r s to the minimum number of separate and remote means of egress as specified by 5-4.1.2, when a building or portion thereof has an occupant load of more than 500. Section 5-3.1.2 states that the occupant load permitted is determined by dividing the Floor area assigned to that use by an occupant load Factor as specified in Chapter 8 through 30. Section 29-1.7 has no occupant load factor noted. Without a stated occupant load Factor the A.H.J. would not be able to determine when the requirements of 29-2.4.2 applied. An occupant load factor must be established within section 29 1.7 in order to determine compliance with 29-2.4.2. Presently a l l three model building codes have an occupant load factor of one (1) person for each 300 gross sq f t of f loor area. COMMITTEE ACTION: Rejec t . COMMITTEE COHHENT: Establishing an occupant load Factor in the 29 1.7 section during TCD preparation would not allow for the concept to receive public review and thus introduces new material. Occupant load in a storage occupancy can be determined without having to rely on an occupant load Factor by considering the maximum probable number of persons who might be present under anticipated conditions. See Chapter 3 for the def in i t ion of "occupant load". The Subcommittee on Industr ial and Storage Occupancies has established a Task Group to address the subject of occupant load factors for the 1991 edition of the Code.

354

(Log #588) lOl - 513 - (2~-2.4.2): Reject SUBMITTER: Roll Jensen, P.E., James Antel l , A.I .A., Roll Jensen & Associates, Inc. ~OMMENT ON PROPOSAL NO.: 101-886 RECOMMENDATION: Reject proposal. SUBSTANTIATION: Storage occupancies do not have a requirement For occupant load (29-1.7). The number of separate and remote means of egress is determined by travel distances. Proposed section is meaningless For this occupancy chapter. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Paragraph 5-3.1.I requires that the capacity of the means of egress be su f f i c ien t for the occupant load thereof. A storage occupancy, even though an occupant load factor is not specified, has an occupant load. The occupant load can be determined by considering the maximum probable number of persons who might be preser,t under anticipated conditions. See Chapter 3 For the def in i t ion of "occupant load". Also see the Committee Action and Committee Comment on Comment 101-512 on 29-2.4.2 (Log #352).

COMMITTEE ACTION: Accept in Principle. Revise 29-2.5.1 to read as follows: 29 2.5.1 Where two or more means of egress are

required, they shall be arranged so as to be reached by d i f fe rent paths of travel in d i f fe rent directions.

Exception No. l : Existing buildings. Exception No. 2: Low hazard storage occupancies. Exception No. 3: Common paths of travel and dead

ends shall be allowed in ordinary hazard storage occupancies provided that they do not exceed 50 f t (15.2 m) in an unsprinklered building and lO0 Ft (30.5 m) in a building protected throughout by an approved automatic sprinkler system in accordance with Section 7-7.

Renumber current 29-2.5.1 and 29-2.5.2 as 29-2.5.2 and 29-2.5.3. COMMITTEE COMMENT: Excessive common paths of travel and dead ends cannot be tolerated. Given the recent f i r e experience in ordinary hazard storage occupancies, the Committee agrees with the values proposed by the Commenter. The revised wording should sat isfy the Commenter's intent.

(Log #364) I0] - 514 - (2~-2.5.I): Accept in Principle SUBMITTER: Anorew P. Scit t ine, AT&T Technologies ~OMMENT ON PROPOSAL NO.: I01-887 RECOMMENDATION: Delete 29-2.5.1 (New). SUBSTANTIATION: The proposal would allow one means of egress ( I ) with a 200 f t travel distance in an ordinary hazard storage occupancy and (2) with a 400 f t travel distance in a sprinklered ordinary hazard storage occupancy. Exception of 29-3.4.1 only permits 50 f t and I00 f t respectively. I t would also permit one means of egres~ with unlimited travel distance in a low hazard storage occupancy. COMMITTEE ACTIC~: Accept in Principle.

See the Committee Action on Comment I01-515 on 29-2.5.1 (Log ~356). COMMITTEE COMMENT: The Committee Action on Comment I01-515 (Log #556) should sat is fy the Commenter's concerns.

(Log #356) I01 - 515 - (2!,-2.5.1 and Exception (New)): Accept in Principle SUBMITTER: Bruce W. Hisley, Fire Marshal's Assn. of North America COMMENT ON PROF~AL NO.: 101-887 RECOMMENDATION: Change section 29-2.5.1 to read as fol lows:

29-2.5.1 Wh~.re two or more exi ts are required, they shall be arranged as to be reached by d i f ferent paths of travel in d i f ferent directions.

Exception: Common paths of travel and dead ends shall be allowed in low and ordinary hazard storage occupancies provided that they do not exceed a travel distance of 50 f t in an unsprinklered building and I00 f t in a building protected throughout by an approved automatic sprinkler system. Renumber current 29-2.5.1 and 29-2.5.2 a~. 29-2.5.2 and 29-2.5.3. SUBSTANTIATION: As section 29-2.5.1 is currently wri t ten a common path of travel or dead end can be either 200 f t or 400 f t in length i f protected by an automatic sprinkler system, per section 29-2.6.1 that states allowable travel distances. These new distances are not rea l i s t i c and w i l l pose a serious l i f e hazard exposure to personnel occupying a low or ordinary hazard storage occupancy i f they would have to ex i t a structure that could have storage arrangement that would allow con~on paths of travel and dead end conditions in the magnitude of 200 f t or 400 f t in length.

The intent of" past Subcommittees was to allow a common path of travel or dead end condition of 50 or I00 f t , i f the structure was protected by an automatic sprinkler system, which was stated in the Exception to section 29-2.4.1 of the '81 and '85 editions of the Code.

(Log #174) lOl - 516 - (29 2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: 101-883 RECOMMENDATION: Delete a l l of current 29-2.11. SUBSTANTIATION: The Committee Proposal, on which this comment is being made, places a l l the acceptable means of egress components for this occupancy and the i r associated "special Features" together in the 2.2 section of this occupancy chapter. Some of the proposed wording for this expanded 2.2 section comes from the 2.11 Special Features portion of the current (1985 edit ion) chapter. Without the proposed deletions the requirements would appear twice and serve to c o n f u s e the u s e r . COMMITTEE ACTION: Accep t .

(Log #145) lOl - 517 - (29-2.11.4): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: 101-892 RECOMMENDATION: In the revised 2.2 section of the occupancy chapter, which addresses acceptable means of egress components, reword the item dealing with alternating tread devices so as to change the parenthetical reference "(see S-2.11)" to the sentence "Alternating tread devices complying with 5-2.11 are permitted." SUBSTANTIATION: Coordlnation with the Format of the other 2.2 section l i s t s of acceptable components of the means of egress. COMMITTEE ACTION: Accept.

(Log #367) I01 - 518 - (29-2.11.4): Reject SVBMITTER: Andrew P. Scit t ine, AT&T Technologies COMMENT ON PROPOSAL NO.: I01-891 RECOMMENDATION: Replace "occupant load" with "occupancy" and add "persons" a f ter "F i f t y " . SUBSTANTIATION: There are no requirements for an occupant load in storage occupancies. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action on Comment lOl-Sl l on 29-2.4.2 (Log #368) which explains the Committee's thinking on the subject.

(Log #353) 101 - 519 - (29-2.11.4): Reject ~UBMITTER: Bruce W. Hisley, Fire Marshal's Assn. o f North America COMMENT ON PROPOSAL NO.: I01-891 RECOMMENDATION: The proposed new 29-2.11.4 is Fine as wri t ten, however there is a need to establish an occupant load Factor in order to determine compliance. Provide an occupant load factor of 300 sq f t gross f loor area For section 29-1.7.

355

SUBSTANTIATION: This section refers to the use of horizontal sl iding doors in a means of egress when the occupant load does not exceed 50 persons. Section 5-3.1.2 states that the occupant load permitted is determined by dividing the Floor area assigned to that use by an occupant load Factor specified in Chapter 8 through 30. Section 29-1.7 has no occupant load Factor noted. Without a stated occupant load Factor the A.H.J. would not be able to determine when the requirements of 29-2.11.4 applied. An occupant load factor must be established within section 29~I.7 in order to determine when the requirements of 29 2.11.4 would apply. Presently a l l three model bu11ding codes have an occupant load Factor of one ( I ) person for each 300 gross sq f t of Floor area. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action on Comment I01-512 on 29-2.4.2 (Log #352) which explains the Committee's thinking on the subject.

(Log #434) I01 - 520 ~ ( 2 9 - 3 . 6 and Exception ( N e w ) ) : Reject SUBHITTER: Peter Lamb, East Lyme Fire Marshal's OFfice COMMENT ON PROPOSAL NO.: I01-895 RECOMMENDATION: Revise 29-3.6 to read:

29-3.G Corridors. Corridors shall comply with 5 - I . 3 . 4 ,

Exception: Existing buildings. SUBSTANTIATION: Presently the Code requires corridors to comply with 5-1.3.4 unless the occupancy chapters make s p e c i f i c a l t e r n a t e p r o v i s i o n s . T h i s has no t been done in the past by storage occupancies and this is a major technical change recommended by the Subcommittee. I t has not been documented in the substantiation. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action on Comment lOl SOl on 28 3.G (Log #433) which explains the Committee's thinking on the subject.

(Log #187) 101 - 521 - (29-4.2): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories ~OMMENT ON PROPOSAL NO.: 101 89G RECOMMENDATION: Insert, before the actual sentence with the requirement, a boldface type heading "High Rise Buildings," SUBSTANTIATION: The boldface type heading w i l l cal l attention to the new requirement and set i t o f f as a separate subject from the items which precede and fol low i t . COMMITTEE ACTION: Accept. COMMITTEE COMMENT: Also see Committee Action on Comment I01-522 on 29 2.4.2 (Log #210).

(Log #210) 101 - 522 - (29-4.2): Accept in Principle SUBMITTER: Gregory Thomas, Liberty Mutual Insurance ~OMMENT ON PROPOSAL NO.: 101-896 RECOMMENDATION: Delete the requirement that high-rise buildings must comply with Section 30-8. SUBSTANTIATION: The provisions of 30-8 are overly res t r i c t i ve for storage occupancies. The requirements of Chapter 29 contemplate a low population density, see (A-29-2.G.I) whereas 30-8 is designed for large numbers of people above the level of exi t discharge. COMMITTEE ACTION: Accept in Principle.

Create a 29-4.2 to read: 29-4.2 High Rise Buildings. NO requirements.

COMMITTEE COMMENT: The Committee Action should sat isfy the Commenter's intent.

(Log #590) I01 - 523 (29-4.2): Accept in Principle SUBMITTER: Roll Jensen, P.E., James Antel l , A.I .A., RoIF Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 101-896 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The high-rise provisions were added by the Main Committee with no review by the Sub-committees. This comment is being submitted to allow the Sub-committee to review the proposal and make changes to coincide with the specif ic needs of the occupancy g r o u p . COMMITTEE ACTION: Accep t i n P r i n c i p l e ,

See Commi t tee A c t i o n on Comment 101-522 on 2 9 - 4 , 2 (Log # 2 1 0 ) . ~OMMITTEE COMMENT: The Committee Action on Comment I01-522 (Log #210) should sat isfy the Commenter's intent.

(Log #177) 101 - 524 - (29-4.2): Accept in Principle SUBMIITER: John A. Sharry, Lawrence Livermore Laboratories COMMENT ON PROPOSAL NO.: 101 896 RECOHMENDATION: Duplicate the same wording, as proposed For 29 4.2, as a new 29-8.4 so as to apply the high rise requirements of Section 30-8 to new high rise parking garages. SUBSTANTIATION: Although placing the high-rise provisions in 29-4.2 should make them apply to a l l new storage occupancies, including parking garages, the users of Section 29 8 generally believe that a l l the requirements applicable to parking garages are wholly self--contained in Section 29 8. Duplicating the wordlng in Section 29 8 w i l l stress that the high-rise requirements also apply to new high-rise parking garages. COMMITTEE ACTION: Accept in Principle.

Create a 29 8,4 to read: 29-8.4 High Rise Buildings. No requirements.

COMMITTEE COMMENT: The Commlttee Action should address the Commenter's concern with respect to completeness of the Section 29 8 requirements applicable to parking garages.

(Log #280) I01 - 525 - (29=4.2 E'~ception): Reject SUBMITTER: Daniel M. McGee, American Iron and Steel Inst i tu te COMMENT ON PROPOSAL NO.: I01-89G RECOMMENDATION: Revise proposed section 29-4.2 to include additional Exception:

Exception: Existing buildings. Open parking s t r u c t u r e s . SUBSTANTIATION: The BCMC recommenda t ions on h i g h - r i s e b u i l d i n g p r o v i s i o n s s p e c i f i c a l l y o m i t t e d c e r t a i n use groups From the special requirements because they were not suitable or not needed.

The above exception should be included here or in Section 30-8. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The changes proposed by the Commenter are not applicable given that the Committee Action on Comment lOl 522 on 29-4.2 (Log #210) w i l l result in no special requirements for high rise buildings.

(Log #526) I01 - 526 - (29 8 . 2 . 4 ) : Accep t SUBMITTER: F r e d e r i c k Maynard , New London, CT COMMENT ON PROPOSAL NO=: I01-899 I RECOMMENDATION: Retain requirements for minimum number ~ex i x iEsas~e l l as mlnimum number o£ means of egress. ~UBSTANTIATION: The text as proposed by the Subcommittee w i l l no longer establish minimum number of exi ts. This could potent ia l ly le t a two or three story building exist with no exits on the upper f loors, only exi t access which, in the past has not been allowed.

356

COMMITTEE ACTION: Accept. Therefore, tex t w i l l read: 29-8.2.4 Number of E~its. Every Floor of every

garage shal l have access to at least two separate ex i t s . COMMITTEE COMMENT: The Committee Action reinstates the wording of the current (1985) ed i t ion of the Code. This should meet the Commenter's in tent .

(Log #175) 101 - 527 - (~9 8.2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore L a b o r a t o r i e s COMMENT ON PROPOSAL NO.: 101-898

I RECOMMENDATION: Dele te a l l o f c u r r e n t 29 -8 .2 .11 . SUBSTANTIATION: The Committee Proposa l , on which t h i s comment is being made, p laces a l l the accep tab le means o f egress components f o r t h i s occupancy and t h e i r assoc ia ted " s p e c i a l f e a t u r e s " t o g e t h e r in the 2.2 s e c t i o n o f t h i s occupancy chap te r . Some o f the proposed word ing f o r t h i s expanded 2.2 s e c t i o n comes f rom the 2.11 Spec ia l Features p o r t i o n o f the c u r r e n t (1985 e d i t i o n ) chap te r . Wi thout the proposed d e l e t i o n s the requirements would appear twice and serve to confuse the u~er.

COMMITTEE ACTION: Accept.

(Log #354) I01 - 528 - (29-8.2.11.3): Reject SUBMITTER: Bruce W. H1sley, Fire Marshal's Assn. of Nor th America COMMENT ON PRCPOSAL NO.; 101-902 RECOMMENDATION: The proposed new 2 9 - 8 . 2 . 1 1 . 3 is Fine as w r i t t e n , hcwever, t he re is a need to e s t a b l i s h an occupant load Fac to r in o rder to de termine compl iance. P rov ide an occupant load f a c t o r o f 300 sq f t gross f l o o r area fo r s e c t i o n 29-1 .7 . SUBSTANTIATIOn: This sec t i on r e f e r s to the use o f h o r i z o n t a l s l i d i n g doors in a means o f egress when the occupant load does not exceed 50 persons. Section 5-3.1.2 states that the occupant load permitted is determined by d iv id ing the Floor area assigned to that use by an occLpant load factor specif ied in Chapter 8 through 30. Eection 29 1.7 has no occupant load Factor noted. WithoLt a stated occupant load fac tor the A.H.J. would ro t be able to determine when the requirements cf 29-8.2.11.3 applied. An occupant load fac to r must b~ established wi th in Section 29-I .7 in order to determine when the requirements of 29-8.2.11.3 would apply. Presently a l l three model bui ld ing codes have an occupant load fac tor of one ( I ) person fo r each 300 gross sq f t of Floor area. COMMITTEE ACTION: Reject. COMMITTEE COMNtENT: See Committee Action on Comment I01-512 on 29-2.4.2 (Log #352) which explains the Committee's th inking on the subject.

(Log #365) lOl - 529 - (29-8.2.11.3): Reject SUBMITTER: Ardrew P. Sc i t t i ne , AT&T Technologies COMMENT ON PRCPOSAL NO.: 101-902 RECOMMENDATION: Replace "occupant load" with "occupancy" ard add "persons" a f te r " f i f t y " . SUBSTANTIATION: There are no requirements For an occupant load in storage occupancies. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: See Committee Action on Comment IOI-Sl l on 29-2.4.2 (Log #368) which explains the Committee's th inking on the subject.

(Log #527) lOl - 530 - (J0-2.4): Accept in Pr inc ip le $UBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: I01-909 RECOMMENDATION: Retain requirements fo r minimum number of ex i t s as well as minimum number of means of egress.

SUBSTANTIATION: The tex t as proposed by the Subcommittee w i l l no longer establ ish minimum number of ex i t s . This could po ten t i a l l y l e t a two or three story bui ld ing ex is t with no ex i ts on the upper f l oo rs , only e x i t access which, in the past, has not been allowed. COMMITTEE ACTION: Accept in Pr inc ip le .

In TCR Proposal I01-909, change "means of egress" in f i r s t two appearances to "ex i t s " and in i t s t h i rd appearance to " e x i t " . COMMITTEE COMMENT: The change should sa t i s f y the Commenter's in tent .

(Log #591) I01 - 531 - (30-2.4.2) : Accept SUBMITTER; Roll Oensen, P.E., James Ante l l , A . I .A . , Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-910

I RECOMMENDATION: Revise 30-2.4.2 to read as Follows: 30-2.4.2 Floors or port ions thereof . . . .

SUBSTANTIATION: Buildings with an occupant load of 500 do not need 3 separate ex i ts unless the occupant load is concentrated on one f l o o r i COMMITTEE ACTION: Accept.

(Log #176) 101 - 532 - (30-2.11): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01 908

I RECOMMENDATION: Delete a l l of current 30-2 . ] I . SUBSTANTIATION: The Committee Proposal, on which th is comment is being made, places a l l the acceptable means of egress components For th is occupancy and t he i r assoclated "speclal Features" together in the 2.2 section of th is occupancy chapter. Some of the proposed wording fo r th is expanded 2.2 section comes From the 2.11 Special Features port ion of the current (1985 edi t ion) chapter. Without the proposed delet ions the requirements would appear twice and serve to confuse the user. COMMITTEE ACTION: Accept.

(Log #146) I01 - 533 - (30-2.11.3): Accept SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-914 RECOMMENDATION: In the revised 2.2 section of the occupancy chapter, which addresses acceptable means of egress components, reword the item dealing with a l ternat ing tread devices so as to change the parenthetical reference "(see 5-2.11)" to the sentence "Al ternat ing tread devices complying with 5-2.11 are permitted." SUBSTANTIATION: Coordination with the Format of the other 2.2 section l i s t s of acceptable components of the means of egress. COMMITTEE ACTION: Accept.

(Log #435) 101 - 534 - (30 3.6): Accept SUBMITTER: Peter Lamb, East Lyme Fire Marshals Of f ice , CT COMMENT ON PROPOSAL NO.: I01-917 RECOMMENDATION: Revise 30 3.6 to read:

30-3.6 Corridors. The cor r idor provisions fo r the occupancy involved wi th in the unusual st ructure shal l apply. SUBSTANTIATION: For Chapter 30 to a r b i t r a r i l y el iminate cor r idor requirements without any technical j u s t i f i c a t i o n is unfounded. COMMITTEE ACTION: Accept.

357

(Log #188) lOl - 535 - ( 3 0 - 4 . 2 ) : Accept SUBMITTER: John A. Shar ry , Lawrence L ivermore L a b o r a t o r i e s COMMENT ON PROPOSAL NO.: 101-918 RECOMMENDATION: I n s e r t , be fo re the ac tua l sentence w i t h the requ i r emen t , a bo ld face type heading "High Rise B u i l d i n g s . " SUBSTANTIATION: The b o l d f a c e type heading w i l l c a l l a t t e n t i o n to the new requ i remen t and set i t o f f as a separa te sub jec t f rom the i tems which precede and f o l l o w i t . COMMITTEE ACTION: Accept .

(Log ~592) lot - 536 - (30-4.2): Reject SUBMITTER: RolF Jensen, P.E., 'James Ante l l , A . I .A . , RolF Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-918 RECOMMENDATION: Reject proposal. SUBSTANTIATION: The h igh- r ise provls~ons were added by the Main Committee with no review by the Sub-committees. This comment is being submitted to al low the Sub-committee to review the proposal and make changes to coincide with the spec i f ic needs of the occupancy group, COMMITTEE ACTION: Re jec t , COMMITTEE COMMENT: High r ise bui ld ing provisions are needed i f the occupancy involved wi th in the unusual structure is required to meet high r ise bui ld ing provisions per the appl icable occupancy chapter. See the Committee Action on Comment I01-537 on 30-4.2 (Log #281).

(Log #281) lOt 537 - (30-4.2 Exception): Accept in Pr inc ip le SUBMITTER: Daniel M. McGee, American Iron and Steel I n s t i t u t e COMMENT ON PROPOSAL NO.: lOl 918 RECOMMENDATION: Revise proposed section 30-4.2 to include addi t ional Exception.

Exception: Exis t ing bui ldings. Airpor t t r a f f i c control towers. Other low occupancy towers when approved by the author i ty having j u r i s d i c t i o n . SUBSTANTIATION: The FAA Construction Standards do not require automatic spr ink lers in control towers. The BOCA Natlonal Bui lding Code also exempts a i rpo r t control towers from the high r ise provisions. COMMITTEE ACTION: Accept in Pr inc ip le .

Create a 30-4 .2 to read: 30-4.2 High Rise Bui ldings. The high r lse bui ld ing

provisions For the occupancy involved wi th in the unusual structure shall apply (see Chapters 8 through 29). COMMITTEE COMMENT: The Committee Actlon should meet the Commenter's in tent .

(Log #79) 101 - 538 - (30 8): Reject SUBMITTER: H. Brooke Stauf fer , National E lec t r i ca l Manufacturers Assn. COMMENT ON PROPOSAL NO.: I01-920 RECOMMENDATION: Reject. Send back to Committee for Further study. SUBSTANTIATION: The proposal does not conform to the current requirement of the three model bui ld ing codes in terms of automatic f i r e detection. There are no requirements fo r detectors in mechanical equipment, e l e c t r i c a l , transformer, telephone equipment, e levator machine or s im i la r rooms. There are no requirements For duct detect ion. Requirements fo r voice alarm systems, system supervision, and system ac t i va t ion are also less s t r ingent than current or proposed model code language. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: As explained in the Committee Comment to Comment 101-539 on 30-8.1.I (Log #282), Section 30-8 is a menu of possible high r ise bu i ld ing provisions that can be cal led into play by other

sec t i ons of the Code. I t rep resen ts the best o v e r a l l package of p r o v i s i o n s as determined by the Subcommittee on F i re P r o t e c t i o n Features, a spec ia l Task Group o f the Committee on Sa fe t y to L i f e , and the paren t Committee on Sa fe ty to L i f e . As such, the Committee does not Feel t h a t the menu needs to agree comp le te l y w~th the model codes.

(Log #282) lOl 539 - (30-8.1.1 Exception No. 2 (New)): Reject SUBMITTER: Daniel M. McGee, American Iron and Steel I n s t i t u t e COMMENT ON PROPOSAL NO.: 101-920 RECOMMENDATION: Revise proposed section 30-8 to include addit ional Exception to section 30 8 . l . l :

Exception NO. 2: Open parking structures. Stadiums, sports arenas and outdoor assembly structures. Special indus t r ia l uses including among others; e l e c t r i c , gas or steam generating f a c i l i t i e s , r o l l i n g m i l l s , s t ructura l metal Fabricating shops and foundries. Use Group H-High Hazard. SUBSTANTIATION: The BCMC recommendation on h igh- r ise bui ld ing provisions spec i f i ca l l y omitted cer ta in use groups From the special requirements because they were not sui table or not needed. The proposed Section 30-8 omitted these Exceptions.

The Exceptions could also be placed in the occupancy chapters. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Section 30-8 provides a menu that can then be mandated by other sections of the Code. Any exceptions should be addressed and appear in the spec i f ic occupancy chapters.

(Log #338) 101 540 - (30-8.4): Reject SUBMITTER: John G. Degenkolb, Carson City, NV COMMENT ON PROPOSAL NO.: I01-920 RECOMMENDATION: Add a new 30-8.4 as fol lows:

30-8.4 Smoke Management. Every high r ise bui ld ing shal l be so arranged or equipped as to assure that smoke from a developing Fire w i l l be reasonably confined to the f l o o r of o r ig in . SUBSTANTIATION: I t has been well established that smoke is the real f i r e problem. For that reason NFPA has seen f i t to establ ish a new Subcommittee to develop Smoke Management c r i t e r i a . Section I-7 of the Committee report states: "Automatic suppression systems l i m i t the growth rate and the maximum size of a f i r e but do not necessari ly reduce or ¢l iminate the movement of smoke."

Al l the model bui ld ing codes have requirements concerning the handling of smoke. The L i fe Safety Code has p r o v i s i o n s in some chapters For smoke b a r r i e r s . I t seems a l i t t l e r i d i c u l o u s t h a t the L i f e Sa fe t y Code should be a b s o l u t e l y s i l e n t on the s u b j e c t o f smoke management. COMMITTEE ACTION: Re jec t . COMMITTEE COMMENT: The sub jec t o f p o s s i b l e menu i tems a p p l i c a b l e to h igh r i s e b u i l d i n g s was s tud ied in d e t a i l by the Subcommittee on Fire Protection Features, by a special Task Group of the Committee on Safety to L i fe , and by the parent Committee on Safety to L i fe . The Committee Feels that the proposed Section 30-8 provisions, as shown in the TCR, are adequate For l i f e safety in high r ise bui ldings without the need fo r addi t ional requirements fo r smoke contro l .

Ed i to r ia l Corrections

E d i t o r i a l l y , in the f i f t h l i n e o f c u r r e n t 28 3.2 d e l e t e the comma so as to read:

". . . or such protect ion as may be appropriate to the par t i cu la r hazard, such as explosion venting or suppression For any area subject to an explosion hazard, designed to minimize danger . . ."

358

(Log #594) I01 - 541 - (31-1.3.8): Reject SUBMITTER: Rolf Jensen, P.E., James Antell, A.I.A., Roll Jensen & Associates, Inc. COMMENT ON PROI~SAL NO.: I01-923 RECOMMENDATION: Reject Proposal I01-923. SUBSTANTIATION: See comments on Proposal 101 922. COMMITTEE ACTI(~: Reject. COMMITTEE COMMENIZ: See Committee Comment on Comment I01-542 on 31-I.3.8 (Log #593).

(Log #593) I01 - 542 - (31-1.3.8): Reject SUBHITTER: Roll Jensen, ~.E., James Antell, A.I.A., Roll Jensen & Associates, Inc COMMENT ON PROPOSAL NO.: I01-922 RECOMMENDATION: Reject Proposal I01-922. SUBSTANTIATION: No guidance on testing procedures, c r i t e r i a , or acceptance is provided. Semi-annual testing by an 'approved agency" is costly and an unneeded waste of' manpower For most Juridict ions. Testing of mechanical equipment is beyond the scope of this Code. COMMITTEE ACTION: Reject. COMMITTEE COMMENI': Other test requirements are addressed by the Code. See Committee Action on Comment I01-544 on 31-1.3.8 (Log #68) which w i l l use the term "approved pers,)nnel".

(Log #67) I01 - 543 (31 1.3.8): Accept in Principle SUBHITTER: Thomas D. Mattern, UCLA NeuFopsychiatric Hospital COMMENT ON PROI~OSAL NO.: 101 923 RECOMMENDATION: Delete wordxng "by an approved agency" and substitute wording "by trained personnel". SUBSTANTIATION: As wri t ten, this submittal indicates that "approved agencies" in Fact exist and that they are the on ly acceptab le " t e s t e r s , " when ~n Fact personnel withln the engineering department may exist who can perform this type of testing and maintain the required logs. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment I01-544 on 31-1.3.8 (Log #68). COMMITTEE COMMENI': The Committee Action on Comment I01-544 (Log #,58) w i l l change the term "approved agency" to "aporoved personnel". This action should sat isfy the Commenter's intent.

(Log #68) I01 - 544 - (31-1.3.8): Accept in Principle SUBMITTER: Th)mas D. Hattern, UCLA Neuropsychiatric Hospital COMMENT ON PRO=OSAL NO.: 101-921 RECOMMENDATION: To delete the words "by an approved agency" and change to read " t r a i n e d personne l " . SUBSTANTIATION: Where t r a i n e d on s i t e s t a f f are a v a i l a b l e to p~rForm t h i s tyPe o f t e s t i n g , I f ee l tha t the requirement o f using an "approved agency" leads to i n t e r p r e t a t i o n t ha t an ou ts ide agency is requ i red , when in Fact "on s i t e " personnel can per form these tasks and keep the a p p r o ) r i a t e logs For rev iew o f the a u t h o r i t y having ju r i sd ic t ion upon request. COMMITTEE ACTI,]N:: Accept in Principle.

Change "by al approved agency" to "by approved personnel". COMMITTEE COMMZNT: The Committee agrees that use of the word "agen=y" could cause confusion. The term "approved persJnnel" retains the control by the authority havilg ju r i sd ic t ion to determine which personnel are ~cceptable for the work. The Committee Action should satisfy the Commenter's intent.

(Log #69) 101 - 545 - (31-1.3.8): Accept in Principle SUBHITTER: Thomas D. Mattern, UCLA Neuropsychiatric Hospital COMMENT ON PROPOSAL NO,: 101-922 RECOMMENDATION: Delete wording "by an approved agency" and change to read "trained personnel". SUBSTANTIATION: Refer to substantiation From comment on TCR Proposal 101-921 by above Submitter. COMMITTEE ACTION: Accept in Principle.

See Committee Actlon on Comment I01-54q on 31-1.3.8 (Log #68). COHHITTEE COMMENT: The Committee Action on Comment I01 544 (Log #68) should sat isfy the Commenter's intent.

(Log #327) 101 - 546 - (31-2.6.4): Reject SUBMITTER: Charles J. Pierce, Chicago, IL COMMENT ON PROPOSAL NO.: I01-318 RECOMMENDATION: Would the Committee elaborate? For example, is i t acceptable to use a combustible and toxic foam which is covered with f i r e retardant material? I suggest that only noncombustible foams be permitted, whether they are exposed or not. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Commenter has not complied with Section l l -7 (d ) of the NFPA Regulations Governing Committee Projects which requires the Proposed text of comment, including the wording to be added, revised (and how revised), or deleted.

(Log #397) 101 - 547 - (31-4.5.5): Accept SUBMITTER: Kenneth Bush, Easton, MO COMMENT ON PROPOSAL NO.: I01-928 RECOHMENDATION: Revise the last l ine to read:

"And shall have a char length not exceeding 1.5 in. (3.8 cm)." SUBSTANTIATION: As presently printed, i t would require actual char length of 1.5 in. wherein the intent, I believe, is to not exceed 1.5 in. COMMITTEE ACTION: Accept.

(Log #595) 101 548 - (31-4.5.5): Reject SUBMITTER: Roll Jensen, P.E., James Antell A.I .A., Rol f Jensen & Assoc ia tes , Inc . COMMENT ON PROPOSAL NO.: 101-928 RECOMMENDATION: Delete Proposal 101-928. SUBSTANTIATION: Regula t ion o f b u i l d i n g Furn ish ings at the user l e v e l is nea r l y imposs ib le and should not be par t o f t h i s Code as s ta ted in I - 3 . 6 . COMMITTEE ACTION: Rejec t . COHHITTEE COMMENT: The Committee f e e l s t h a t t h i s is w i t h i n the scope o f the document as p reven t ing i g n i t i o n o f Furn ish ings c l e a r l y p rov ldes a l i f e s a f e t y b e n e f i t . This t e s t i n g is a v a i l a b l e and t h i s is a h i g h l y regu la ted occupancy in which t h i s p r o v i s i o n can be enforced.

(Log #506) 101 - 549 - (31-4 .5 .5 Except ion (New)): Accept in P r i n c i p l e SUBMITTER: Hike Thompson, American Heal th Care Assn. COMMENT ON PROPOSAL NO=: 101-928 RECOMMENDATION: Add a new Except ion as Fo l lows :

Exception: Health Care Occupancies Protected throughout with automatic sprinklers in accordance with 7-7. SUBSTANTIATION: Many health care regulations permit and in some cases encourage patients in nursing homes and hospices to bring in personal Furniture For the i r use. No documentation or evidence has been presented that this furn i ture is or has been a problem in a Fully-sprinklered f a c i l i t y .

359

COMMITTEE ACTION: Accept in Pr inc ip le . Add the Exception as requested by the Submitter but

also revise the f i r s t sentence of 31-4.5.5 as Follows: "Newly introduced upholstered Furniture wi th in . . ."

COMMITTEE COMMENT: Committee agrees with the in tent of the Submitter and at the same time wishes to c l a r i f y what was meant by new upholstered Furniture,

(Log #596) I01 - 550 - (31-4.7): Reject SUBMITTER: Roll Jensen, P.E., James Ante l l , A . I .A . , Rol l Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-929 RECOMMENDATION: Reject Proposal lOl 929. SUBSTANTIATION: This requirement is beyond the scope of the Code as out l ined in I -3 .6 . COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Feels that th is material is d e f i n i t e l y wi th in the scope of the L i fe Safety Code. I t should be noted that compliance with 31 1.I would be mandated even i f not specif ied wi th in Section 31-4. I t is being added here to complete the package fo r health care. Making sure that egress sys tems a re a v a i l a b l e i n an a rea o f c o n s t r u c t i o n i s c l e a r l y w i t h i n the scope o f t he L i f e S a f e t y Code.

(Log #376) !01 - 551 ( 3 1 - 6 . 4 ) : Accept SUBMITTER: T. D a l y / H . Moore, Commi t tee on S a f e t y and F i r e P r o t e c t i o n - Amer i can H o t e l and Mote l Assoc. COMMENT ON PROPOSAL NO.: 101-931 RECOMMENDATION: A f t e r t he words " p o s t e d on" add, " o r i m m e d i a t e l y a d j a c e n t t o " e v e r y g u e s t room door . . . . SUBSTANTIATION: Due t o the s i z e r e q u i r e m e n t s o f s i g n s i n many b u i l d i n g codes, the amount o f i n f o r m a t i o n to be on t he s i g n and the a r c h i t e c t u r a l s u r f a c e o f some d o o r s , i t may be i m p o s s i b l e t o i n s t a l l t he s i g n on t he doo r i t s e l f . COMMITTEE ACTION: Accep t .

(Log #373) 101 - 552 - (31-6.6.2): Reject SUBMITTER: T. Daly/H. Moore, Committee on Safety and Fire Protection - American Hotel and Motel Assoc. COMMENT ON PROPOSAL NO.: I01-934 RECOMMENDATION: Add the fo l lowing:

"Where new upholstered f u rn i t u re is purchased in small quant i t les, such Furniture which is manufactured From components passing tests out l ined in NFPA 260A, Standard Method of Test fo r Cigarette Ign i t i on Resistance of Upholstered Furniture Components shall be permitted." SUBSTANTIATION: Where purchase of f u rn i t u re in small quant i t ies is made i t is not l i k l e y that Full scale f~re "tests to destruct ion" of composites w i l l be done as required by NFPA 206B. Lacking such wi l l ingness on the part of purchasers, the a l ternate language suggested above would contr ibute to an improvement in the Furniture being purchased, The NFPA 260A standard is widely used by the Furniture industry. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee sees th~s as an appropriate recommendation as NFPA 260B is a more precise test. The Committee sees problems with determining what is a "small quant i ty" .

(Log #597) I01 - 553 - (31-6.6.2): Reject SUBMITTER: Roll Jensen, P.E., James Ante l l , A . I .A . , Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-934 RECOMMENDATION: Reject Proposal I01-934. SUBSTANTIATION: See comments on Proposal I01-928. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee Action on TCR Proposal 101-934 makes use of the appendix only to advise on the subject. NO mandatory requirements fo r Furniture mock-ups test ing per NFPA 260B w i l l appear in the Code.

(Log #598) 101 - 554 ( 3 1 - 7 . 5 ) : Accept SUBMITTER: R o l l Jensen , P . E . , James A n t e l l , A . I . A . , RolF Oensen & A s s o c i a t e s , I n c . COMMENT ON PROPOSAL NO.: 101 938 RECOMMENDATION: R e j e c t P roposa l 101-938 . SUBSTANTIATION: See comments on P r o p o s a l 101-928 . COMMITTEE ACTION: Accep t . COMMITTEE COMMENT: The Commi t tee does Feel t h a t t h i s wou ld be d i f f i c u l t t o e n f o r c e i n t h i s occupancy . I t i s d e s i r a b l e to a l l o w Lhese occupan ts t o b r i n g i n t h e i r own f u r n i s h i n g s . The Commi t tee does Feel i t i s d e s i r a b l e to c o n t r o l d r a p e r i e s , c u r t a l n s and s i m i l a r furnishings in these F a c i l i t i e s regardless of size, and Feels that a homelike atmosphere can be provided but does recognize enforcement problems in th is occupancy.

(Log #206) I01 - 555 (31 7 . 5 ) : Accept i n P r i n c i p l e SUBMITTER: Da le F. Lowe, Maine Assn. o f P r i v a t e R e s i d e n t i a l F a c i l i t i e s For Persons w i t h D e v e l o p m e n t a l D i s a b i l i t i e s COMMENT ON PROPOSAL NO.: 101-938 RECOMMENDATION: Rev ise as f o l l o w s :

3 1 - 7 . 5 New d r a p e r l e s , c u r t a i n s and o t h e r s i m i l a r f u r n i s h i n g s and d e c o r a t i o n s in board and ca re homes s h a l l be i n acco rdance w i t h the p r o v i s i o n s o f 31 1 .4 , SUBSTANTIATION: D e l e t e . Smal l s i x bed f a c i l i t i e s a re supposed to be h o m e l i k e in n a t u r e and t h i s r e q u i r e m e n t wou ld a l t e r t h a t e n v i r o n m e n t . The c o s t wou ld a l s o be p r o h i b i t i v e . Do no t Feel t h i s i s a p p r o p r i a t e f o r s m a l l homes such as a s i x bed. COMMITTEE ACTION: Accep t i n P r i n c i p l e ,

See Comment 101-554 on 3 1 - 7 . 5 (Log #598 ) . COMMITTEE COMMENT: See Comment 101-554 on 3 1 - 7 . 5 (Log #598 ) . T h i s s h o u l d s a t i s f y the a c t u a l i n t e n t o f t he S u b m i t t e r as i n d i c a t e d in the s u b s t a n t i a t i o n .

(Log #516) I01 - 556 ( 3 1 - 7 . 5 ) : Accept i n P r i n c i p l e SUBMITTER: Jon i F r i t z , N a t i o n a l Assn. o f P r i v a t e R e s i d e n t i a l F a c i l i t i e s For the M e n t a l l y Re ta rded COMMENT ON PROPOSAL NO.: 101 938 RECOMMENDATION: Add new s e c t i o n as f o l l o w s :

3 1 - 7 . 5 New d r a p e r i e s , c u r t a i n s and o t h e r s i m i l a r f u r n i s h i n g s and d e c o r a t i o n s i n board and c a r e homes s h a l l be i n acco rdance w i t h the p r o v i s i o n s o f 3 1 - 1 . 4 . SUBSTANTIATION: Requ i remen ts to use Flame r e s i s t a n t t e x t i l e s a re u n n e c e s s a r i l y r e s t r i c t i v e i n p l a c e s t h a t become home on a l ong te rm b a s i s f o r peop le i n need o f some s u p p o r t . Use o f donated F u r n i s h i n g s and i t e m s b r o u g h t From a f a m i l y home make the p roposed r e q u i r e m e n t i m p r a c t i c a l , and i n f r i n g e on the r i g h t s o f peop le t o d e c o r a t e the p l a c e t h a t t h e y l i v e as t h e y w i s h . COMMITTEE ACTION: Accept in P r i n c i p l e .

See Comment 101-554 on 3 1 - 7 . 5 (Log #598 ) . COMHITTEE COMMENT: See Comment 101-554 on 3 1 - 7 . 5 (Log #598 ) . T h i s s h o u l d s a t i s f y t h e a c t u a l i n t e n t o f t he S u b m i t t e r as i n d i c a t e d i n t he s u b s t a n t i a t i o n .

(Log #56) I01 - 557 - ( 3 1 - 7 . 5 ) : Accept i n P r i n c i p l e SUBMITTER: Rebecca P. B a l t z e r , Green V a l l e y P a t t e n Group House COMMENT ON PROPOSAL NO.: 101-938 RECOMMENDATION: Rev ise as f o l l o w s :

3 1 - 7 . 5 New c u r t a i n s , d r a p e r i e s and o t h e r s i m i l a r f u r n i s h i n g s and d e c o r a t i o n s i n board and c a r e homes s h a l l be i n acco rdance w i t h the p r o v i s i o n s o f 3 1 - 1 . 4 . SUBSTANTIATION: D e l e t e . Smal l s i x bed f a c i l i t i e s a re supposed t o be home l i k e i n n a t u r e and t h i s r e q u i r e m e n t wou ld d e f i n i t e l y a l t e r t h a t e n v i r o n m e n t ; a l s o , t h e c o s t wou ld a l s o be p r o h i b i t i v e . We do no t f e e l t h a t t h i s i s a p p r o p r i a t e f o r sma l l homes such as a 6 bed. ~OMMITTEE ACTION: Accep t i n P r i n c i p l e .

See Comment 101-554 on 3 1 - 7 . 5 (Log #598 ) . COMMITTEE COMMENT: See Comment 101-554 on 3 1 - 7 . 5 (Log #598 ) . T h i s s h o u l d s a t i s f y t h e a c t u a l i n t e n t o f t he S u b m i t t e r as i n d i c a t e d i n t he s u b s t a n t i a t i o n .

360

(Log #59) I O l - 558 - (31-7.5}: Accept in Principle SUBMITTER: Dale F. Lowe, Green Valley Arc. COMMENT ON PROPOSAL NO.: 1 0 1 - 9 3 8

RECOMMENDATION: Revise as follows: 31-7.5 New draperies, curtains and other s imi lar

furnishings and decorations in board and care homes shall be in accordance with the provisions of 3l-1.4. SUBSTANTIATION: Delete. Small six bed Fac i l i t ies are supposed to be homelike in nature and this requirement would a l te r th;~t environment; The cost would also be prohib i t ive. Do not Feel that this is appropriate for small homes such as a six bed. COMMITTEE ACTION: Accept in Principle.

See Comment I01-554 on 31-7.5 (Log #598). COMMITTEE COMMENT: See Comment I01-554 on 31-7.5 (Log #598). This should sat isfy the actual intent of the Submitter ~is indicated in the substantiation.

(Log #62) I O l - 559 - (3=-7.5): Accept in Principle SUBMITTER: Margaret N. Dunlap, Green Valley Arc. COMMENT ON PROPOSAL NO~: I01-938 RECOMMENDATION Revise as follows:

31-7.5 New draperies, curtains and other s imi lar furnishings and decorations in board and care homes shall be in ac(:oFdance with the provisions of 31-1.4. ~UBSTANTIATION Delete the above. Small six bed f a c i l i t i e s should not be required to do this. They are supposed to be homelike and not ins t i tu t iona l . This is also unnecessary considering the number of residents and the amount of s taf f ing to help evacuate. The cost would also be prohibi t ive. ~OMMITTEE ACTION: Accept in Principle.

See Comment "01-554 on 31-7.5 (Log #sq8). COMMITTEE COMM~!: See Comment lO1 554 on 31-7.5 (Log #598). This should sat isfy the actual ~ntent of the Submitter es indicated in the substantiatlon.

(Log #231) I 01 - 560 - (A-1-6.4): Accept in Principle SUBMITTER: Jo~n Behrens, Huntington Beach, CA COMMENT ON PROFOSAL NO.: I01-4 RECOMMENDATION: Revise the proposed A-I-6.4 to read as Follows:

A-I-6.4 Examples of changes From one occupancy subclassif ication to another subclassif ication of the same occupancy could include a change From a Class C to a Class B assembly occupancy or a change From a Class B to a Class A mercantile occupancy. Hospitals and nursing homes are both health care occupancies and are defined separately but are not established as separate suboccupancies and thus a change from one to the other does not constitute a change of occupancy subclassif ication.

Hotels and apartments, although both are residential occupancies, are treated separately and a change From one to the other ,does constitute a change of occupancy subclassif ication. SUBSTANTIATION: Ouring discussions by the Subcommittee on Administration an expanded Appendix note was discussed and, in fact, was included in the or iginal draf t of the Appendix to Chapter I. However, this expanded Appendix note was never contained in the TCR. The Appendix note helps c l a r i f y the difference between a change in suboceupancy c lass i f icat ion versus just a change of a def in i t ional type. COMMITTEE ACTION: Accept in Principle.

Revise A-I-6.4 as recommended by the Commenter, but revise the last t~o l ines as follows:

". . . one to the other constitutes a change OF occupancy." COMMITTEE COMMENT: The Committee agrees with the Submitter but believes that the ed i tor ia l change helps to c l a r i f y further the Commenter's intent.

(Log #lOt) lOt - 561 - (A-5-2.2.6.4 Exception No. 2 to (a) (New)): Accept in Principle SUBMITTER: Jake Pauls, Wheaton, MD COMMENT ON PROPOSAL NO.: 101-90 RECOMMENDATION: Add an Appendix note, as follows, to 5-2.2.6.4(a) (or more speci f ica l ly , to 5-2.2.6.4(a), Exception No. 2 regarding additional handrails):

A-5-2.2.6.4 Exception No. 2 to (a) On stairs that form part of the means of egress For, or that w i l l be used extensively by children 5 years or less in age, additional handrails should be instal led at approximately 24 in. (60 cm) helght.

(Suggested cross references, via Appendix notes, are also proposed For I0-2.2 and II-2.2 addressed in Proposals 101-331 and 101-380.) SUBSTANTIATION: The provision of chi ldren's height handrails was always desirable For stairs extensively used by young children and, with the move to more effect ive handrail heights for adults, there is a greater need to recommend (~F not requlre) the additional lower handrails. The choice of age 5 or under is somewhat arbi t rary but is s imi lar to age c r i t e r i a used in Chapters lO and I I in re lat ion to day-care centers. Between ages two and four, children's average shoulder height ranges from 26 in. to 32 in. Field studies in Canadian buildings suggest that children older than about 5 years of age w i l l use an adult-height handrail (up to 41 in. high) even when there is a lower handrail (about 12 in. lower). Where there was not an additional child-height handrail, young c h i l d r e n were obse rved u s i n g a h a n d r a i l l o c a t e d a t o r above t h e i r s h o u l d e r h e i g h t . COMMITTEE ACTION: Accept in P r i n c i p l e ,

Rev ise A - 5 - 2 . 2 . 6 , 4 ( a } E x c e p t i o n No. 2 t o read as F o l l o w s :

E x c e p t i o n No. 2: On s t a i r s t h a t w i l l be used e x t e n s i v e l y by c h i l d r e n 5 yea rs o f age o r y o u n g e r , a d d i t i o n a l h a n d r a i l s a t a h e i g h t o f a p p r o x i m a t e l y 24 i n . (GO cm) a re recommended. COMMITTEE COMMENT: E d i t o r i a l changes to make t h e n o t e more a p p r o p r i a t e For A p p e n d i x A.

(Log #238) lOl - 562 - (A-6-2.2.3.Q(d) (New)): Reject SUBMITTER: John Behrens, Huntington Beach, CA COMMENT ON PROPOSAL NO.: I01 165 RECOMMENDATION: Add an Appendix note to read:

A-6-2.2.3.4(d) This does allow the entire two or three Floors interconnected to be considered the communicating space, i f that is desired by the building designer or owner; but in that case, parts (c), (e) and (g) would apply to the entire communlcating stories, as the entire stories would be the communicating space. SUBSTANTIATION: Revisions to 6-2.2.3.4 help c l a r i f y the intent of the section. However, the proposed Appendix note would c l a r i f y that the communicating space can either be a portion of the interconnected f loors or may, in Fact, be the entire interconnected f loors as long as a l l portions of those Floors comply with the requirements of the paragraph. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Code text already permits th is. The proposed wording would not c l a r i f y but rather would confuse because an exist ing Formal Interpretation says that enclosures such as bathrooms within the communicating area do not meet condition (c) with respect to openness and unobstructedness. Therefore to address, by appendix note, whole f loors as part of the communicating area is misleading.

(Log #495) I01 - 563 - ( A - 6 - 3 . 2 ) : R e j e c t SUBMITTER: Mike Thompson, Amer lcan H e a l t h Care Assn. COMMENT ON PROPOSAL NO.: 101-178 RECOMMENDATION: Add a t h i r d p a r a g r a p h t o A - 6 - 3 . 2 t o read:

" I t is not the intent of the provisions of 6-3.2 to require that horizontal Fire-rated f l oo r / ce i l i ng assemblies serving as part of the smoke compartment meet the requirements of a smoke bar r ie r . "

361

SUBSTANTIATION: The substantiation did not indicate that removal of the words " f i r e barr ier" From the exist ing text was intended to require rated horizontal f l oo r / ce i l i ng assemblies to meet the requirements of a smoke barr ier . Therefore, the additional Appendi, note is proposed for c la r i f i ca t i on . ~_O_MMITTEE ACTIO~N: Reject. COMMITTEE COMMENT: I t is the Committee's intent, except as covered by c u r r e n t 6 - 3 . 4 . I Excep t lon No. 4, t h a t a l l f l o o r s serve as smoke b a r r i e r s ,

(Log #70) 101 - 564 - (A-8-2.5.5.6, A-9-2.5.5.6): Accept in Principle SUBMITTER: Thomas D. Mattern, UCLA Neuropsychiatric Ins t i tu te COMMENT ON PROPOSAL NO.: I01-979 RECOMMENDATION: To delete word "agency" ~n f i r s t paragraph f i f t h l ine to read: "person or agency". SUBSTANTIATION: While agency is usually construed to mean an "employer company", i t is my opinion that many larger inst i tu tes have persons on s ta f f who have the technical a b i l i t i e s to complete a "Li fe Safety Evaluation" and should not be required to use outside "agencies" i f this person exists and is accepted by the authority having Jur isc i t ion. COMMITTEE ACTION: Accept in Principle.

Change "by a competent technical agency and be acceptable" to "by an approved person acceptable". COMMITTEE COMMENT: The Committee Action should sat isfy the Commenter's i n t e n t .

(Log #I14) 101 - 565 (A lO 2.2.3 and A II 2.2.3 (New)): Accept SUBMITTER: Jake PauIs, Wheaton, MD COMMENT ON PROPOSAL NO:" I01-331 and 380 RECOMMENDATION: Add an Appendix note which refers to an Appendix note to 5-2.2.6.4(a) (suggested in another comnent) regarding addit ional, child height handrails:

"See Appendix A-5-2.2.6.4(a) regarding additional handrails on stairs that are used extensively by children 5 years or less in age."

(The suggested Appendix note, For 5 2.2.6.4, is as follows: "On sta~rs that form part of the means of egress for, or that w i l l be used extensively by children 5 years or less in age, additional handrails should be instal led at approximately 24 in. (60 cm) height.") SUBSTANTIATION: The provision of chi ldren's height handrails was always desirable For stairs extensively used by young children and, with the move to more ef fect ive handrail heights for adults there is a greater need to recommend ( i f not require) the additional lower handrails. The choice of age 5 or under is somewhat arbi t rary but is s imi lar to age c r i t e r i a used in Chapters lO and II in relat ion to day-care centers. Between ages two and four, children's average shoulder height ranges from 26 in. to 32 in, Field studies in Canadian buildings suggest that children older than about 5 years of age will use an adult-height handrail (up to 41 in. high) even when there is a lower handrail (about 12 in. lower). Where there was not an additional child-height handrail, young children were observed uslng a handrail located at or above their shoulder height. COMMITTEE ACTION: Accept.

(Log #153) I01 - 566 - (A-12-6.5.2.2): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: 101-1010 RECOMMENDATION: Expand the proposal SO as to include also the deletion of A-13-6.5.2.2. SUBSTANTIATION: There is no corresponding proposal For the deletion of A-13-6.5.2.2. This comment is intended to a l l o w the Committee to address the s u b j e c t i f the lack o f a proposa l was an o v e r s i g h t . COMMITTEE ACTION; Accept .

(Log #152) 101 - 567 - (A-13-3.6.1): Accept in Principle SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-504 RECOMMENDATION: Retain current A-13-3.6.1. SUBSTANTIATION: I t is unclear from the proposed wording whether or not the current Appendix note A-13-3.6.1 should be retained. COMMITTEE ACTION: Accept in Principle. COMMITTEE COMMENT: The Committee intends to retain the current appendix note except the f i r s t paragraph which was speci f ica l ly moved into the Code text by another proposal.

(Log #599) 101 - 568 - (A-14-3.8.I, A-15.3.8.1): Accept in Part SUBMITTER: Rolf Jensen, P.E., James Antel l , A.I.A., Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: I01-I016 & I017 RECOMMENDATION: Revise the last sentence to read:

"to run with I00 percent outside a i r supply and 100 percent exhaust would also be acceptable." SUBSTANTIATIOn: The current wording c la r i f i es the explanatory note. "Return" could imply recirculat ion. COMMITTEE ACTION: Accept in Part.

Revise the last sentence to read: " . . . to run with 100 percent supply and 100 percent

exhaust would be acceptable". COMMITTEE COMMENT: The Committee agrees that the word "exhaust" should be used. The use of the word "outside" was not accepted because the concept is one of looking only for makeup a i r , not necessarily a separate ducted system.

(Log #372) 101 - 569 - (A-16-3.5.I, A-17-3.5. l) : Accept in Principle SUBMITTER: T. Daly/H. Moore, Committee on Safety and Fire Protection - American Hotel and Motel Assoc. COMMENT ON PROPOSAL NO.: I01-I019 RECOMMENDATION: After the words, "sprinklers is (are) encouraged" add " for new insta l la t ions of sprinkler systems" . . . . SUBSTANTIATION: Ins ta l la t ion of sprinkler systems have been made both in response to building codes and on a voluntary basis pr ior to the widespread ava i l ab i l i t y of either residential or quick response standard sprinklers. Such insta l la t ions should not be made to appear less than adequate given that there is no record of a single f i r e death in a dwelling unit within a hotel SO equipped. COMMITTEE ACTION: Accept in Principle.

Add the terms as indicated to A-17-3.5.1 and A-19-3 .5 .1 . COMMITTEE COMMENT: A 18-3.5. I has been deleted (see Comment I01-386 on 18-3.5.1 [Log #601]). The change also needs to be made to A-19.3.5.1 for consistency.

(Log #404) 10l - 570 - (A-20-1.5.1): Reject $UBMITTER: Frederick Maynard, New London, CT COMMENT ON PROPOSAL NO.: 101-701 RECOMMENDATION: Delete A-20-I.5.1 in i ts ent i rety. SUBSTANTIATION: T.I.A. #227 has recommended the deletion of A-20-I.5.1. In addition, Proposal I01-713 is set out to spec i f ica l ly recognize NFPA 13D and, therefore, this Appendix note is inappropriate and should be removed. COMMITTEE ACTION: Reject. c=~O_MMITTEE COMMENT: See action taken on Comment I01-437 on 21-2.3.5.1 Exception Nos. l and 2 (Log #469).

(Log #219) lOl - 571 - (A-30-8.2.1): Reject SUBMITTER: T. Daly/H. Moore, Hilton Hotels Corp. COMMENT ON PROPOSAL NO.: 101-920 REqOMMENDATION: Change " s e c t i o n " to read " s t a n d a r d " . SUBSTANTIATION: Occupancies w i l l be judged to be in compl iance w i t h an NFPA s tandard r a t h e r than a s e c t i o n t h e r e o f .

362

~OMMITTEE ACTI{~: Reject. ~OMMITTEE COMMENT: The use of the word "section" in proposed A-30-8.2.1 refers only to the provisions of Section 30-8, r~ot to the provisions of the entire Code. The provisions of Section 30-8 can speak only for Section 30-8, not for the entire Code.

(Log #483) I01 - 572 - (Appendix C): Accept in Principle SUBMITTER: William E. Koffel, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO.j: 101-1039 RECOMMENDATION: Revise the Appendix to re f lec t the changes made to Chapters 12 and 13. SUBSTANTIATION: Substantial changes have been made to Chapters 12 and 13 which must be incorporated into the FSES. COMMITTEE ACTION: Accept in Principle.

Replace Table C--6 with the following two tables:

(Log #482) I 0 1 1 574 - (Appendices C, D, E, F, G and H): Reject $UBMITTER: William E. Koffel, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO~: 101-1038 RECOMMENDATIO~N: Revise the publishing cycle of NFPA IOIM to be 12 months behind NFPA 101. SUBSTANTIATION: The various FSES's must be revised in accordance with the changes to NFPA 101. I t is almost impossible, especially with respect to action taken at the Association meeting, to revise the FSES to re f lec t current Code text. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: The Committee believes that i t is not appropriate For a public comment to address publishing cycles.

TABLE C-6A Mandatory Safety Requirements (For Use In Any Hospital Or Nursing Home)

Zone Loca t ion Containment Ex t i ngu i shmen t People Movement Sa Sb Sc

New E x i s t . New E x i s t . New E x i s t .

Ist (Hosp) 9 5 4 4 4 1 Ist (N.HM) 9 5 5 4 6 I

Znd (Hosp) 14 9 G G 7 3 2nd (N.HM) 14 9 8 6 9 3

3rd (Hosp) 14 9 6 G 7 3 3rd (N.HM) 11 9 IG G 9 3

4th/Sth (Hosp) 14 g G 6 7 3 4th/5th (NH) 14 9 18 6 10 3

>5th (Hosp) 14 9 16 6 8 3 >Sth (N.HM) 14 9 18 G 10 3

Table C-6B Mandatory Safety Requirements (For Use Only in Sprinkler Protected Hospitals or Nursing Home)

Zone Location Containment Extinguishment People Movement Sa Sb Sc

New E x i s t . New E x i s t . New E x i s t .

Ist (N.HM) 7 - 14 7

2nd (Hosp) 11 7 2nd (N.HM) II 7

14 10 7 7 16 I0 9 7

3rd (Hosp) II 14 - 7

Hosp = Hospital N.HH or N.H. = Nursing Home

COMMITTEE COMMENT: The revision of existing Table C-6 into new Tables C-6A and C-6B fine tunes the mandatory requirements to re f lec t the changes made to the Code requirements for hospitals and nursing homes. The changes should meet the Commenter's intent.

(Log #154) 101 - 573 - (Appendix C): Accept SUBMITTER: John A. Sharry, Lawrence-Livermore Laboratories COMMENT ON PROPOSAL NO.: I01-1047 RECOMMENDATION: In the Fourth l ine of the TCR proposed revised wording, change "parameter valve" to "parameter value". SUBSTANTIATION: Substitution of intended wording. COMMITTEE ACTION: Accept.

(Log #484) 101 - 575 - (Appendix E): Accept in P r i n c i p l e ~BMITTER: W i l l i a m E. K o f f e l , K o f f e l Assoc. , Inc . COMMENT ON PROPOSAL NO=: 101-1054 RECOMMENDATION: Revise the Appendix to re f lec t the changes made to Chapters 14 and 15. SUBSTANTIATION: Substantial changes have been made to Chapters 14 and 15 which must be incorporated into the FSES. COMMITTEE ACTION: Accept in Principle.

Revise Appendix E Table E-3A as fol lows: 1. In the column headed "Height" add the

mathematical symbol "Z" (greater than or equal to) before "3 story" in three places so as to read "Z 3 story".

2. In the four columns headed "New", a f ter the numerical value associated with "> 3 story" (thus, in 12 places) add a parenthetical "(A)" notation.

3. Beneath the table add a Note A to read: (A) Use Table E-3B for f a c i l i t i e s in high-rise

buildings.

363

~MMITTEE COMMENT: The revisions to Table E-3A Fine tune the FSES mandatory values to track with a Code change which requires high-rise detention and correctional Fac i l i t ies to be sprinklered. The Committee Action should sat is fy the Commenter's intent.

(Log #6001 lOl - 576 - (Appendix E): Accept in Part SVBMITTER: Roll Jonson, P.E., James Antell, A.I.A,, Roll Jensen& Associates, Inc. ~OMMENT.ON PROPOSAL NO.: 10!-1056 & I057 RECOMMENDATION: Retain old text in Appendix E, Safety Parameter I, Paragraph 4 and Appendix E, Safety Parameter 12, Paragraph 6. ~UBSTANTIATION: These two proposals state that multit iered open cell blocks are permitted in existing f a c i l i t i e s only, however, Proposal I01-522 which was accepted by the subcommittee w i l l now permit multit iered open cell blocks in new detention and correctional f a c i l i t i e s . COMMITTEE A~TION: Accept in Part.

Change Parameter 12, only, as Follows: To the def ini t ion of smoketight add a second sentence

to read: "Unprotected vert ical openings in accordance with 14-3.1.I Exception No. 3 and 15-3.1.I Exception No. 3 are considered to be smoketight."

To the d e f i n i t i o n o f f i r e r e s i s t a n t add a second sentence to read: "At r iums in accordance w i th 6 - 2 . 2 . 3 , 5 are considered to be f i r e r e s i s t a n t . " COMMITTEE COMMENT: With respect to Parameter I , dea l ing w i t h bu i l d i ng c o n s t r u c t i o n type, the Committee be l i eves tha t a m u l t i l e v e l arrangement should be treated as a multistory building. With respect to Parameter 12, vert ical openings unless protected (e.g,, compliance with 14-3.1.1 Exception No. 3, 15-3.1.1 Exception No. 3, or 6-2.2.3.5) are a deficiency.

(Log #267) 101 - 577 - (Appendix G): Accept ~ I T T E R : Bernard Levin, Gaithersburg, MD COMMENT ON PROPOSAL NO.: 101- RECOMMENDATION: Changes in Chapter 21 may affect the values in the Mandatory Requirements, IF such values need to be changed, they should be. SUBSTANTIATION: None. COMMITTEE ACTION: Accept.

(Log #23) I01 - 579 - (Appendix H): Accept in Principle ~_UBHITTER: Paul S. Quigg, USG Corp. COMMENT ON PROPOSAl: 101-10G2 RECOMMENDATION: Delete entire third paragraph of Section 8 of newly proposed Appendix H, "Any in te r io r Finish having a flame spread of 200 or less that is protected by automatic sprinklers is evaluated as having a Flame spread of greater than or equal to 25. SUBSTANTIATION: This provision would permit the use of wall and cei l ing materials which, when ignited, may well allow a flame front to progress down a hallway spreading Fire as i t goes, because the low heat Flux of the in ter ior f in ish and/or the thermal lag of the sprinklers would not cause the sprinklers to be activated in a timely manner. Implementation of Section 8 could cause:

I. flames spreading Further and Faster- than would occur with an in ter ior Finish w~th a Flame spread of 25;

2, increased area of F~re involvement due to the Faster spread of flame of an in ter ior Finish with a Flame spread of 200. COMMITTEE ACTION: Accept in Prlnciple.

On TCR page 454, in the safety parameter number 8 discussion on in ter ior Finish, revise the ti~ird paragraph to read:

"Any in ter ior f inlsh having a Flame spread of 75 or less that is protected by automatic sprink]ers is evaluated as having a Flame spread not exceeding 25. Any in ter ior f in ish having a Flame spread of more than 75 but not more than 200 that is protected by automatic sprlnklers is evaluated as hav~ng a flame spread not e~ceeding 75."

Revise Table H ! Note B (TCR page 457) to read: "In any sprinkler protected spaces consider Flame

spread rating to be 25 or 75 i f the in ter ior f in lsh ma te r i a l f lame spread does not exceed 75 o r 200, r e s p e c t i v e l y . "

On TCR page 454, in the s a f e t y parameter number 8 d iscuss ion on i n t e r i o r F in i sh , r e v i s e the F i r s t sentence o f the second paragraph to read:

"No c o n s i d e r a t i o n is inc luded in the s a f e t y parameter va lue f o r any f i n i s h w i t h a f lame spread r a t l n g o f more than 200 or for any Finish not rat ional ly measured by the NFPA 255 test and, thus, this FSES should not be used when such condltions exist. (continue with remainder of paragraph per TCR).

In Table H-I on TCR page 457, in the parameter B First entry for exi t route in ter ior Finish, change the symbol preceeding the value of 75 From a "less than" symbol to a "greater than" symbol. COMMITTEE COMMENT: The Comrn]ttee Ac t ion should meet the Commenter's i n t e n t .

(Log #485) 101 - 578 -- (Appendix G): Accept in Principle SUBMITTER: William E. KoFfel, American Health Care Assn. COMMENT ON PROPOSAL NO.: 101-I060 RECOMMENDATION: Revise the Appendix to ref lect the changes made to Chapter 21. SUBSTANTIATION: Substantial changes have been made to Chapter 21 which must be incorporated into the FSES. ~OMMITTEE ACTION: Accept in Principle.

Replace current Appendix G Table G-2C with the Following two tables (shown on followlng page):

On NFPA I01-1985 page 264 (top l e f t column dealing with Part 2 Glossary for Worksheet for Evaluating a Large Faci l i ty , Safety Parameter G Separation of Sleeping Rooms From Exit Access, subpart (e) l-Hour Walls, 20-Minute Doors:

I. Change "Exception:" to "Exception No. I : " . 2. Insert a new Exception No. 2 to read: "Exception No. 2: Barriers in conversions complying

with Exception No. l of 21-3.3.6.3." COMMITTEE COMMENT: The above actions ref lect the fine tuning of the FSES made necessary by changes to Code requirements For board and care Fac i l i t ies .

(Log #81) 101 - 580 - (Appendi~ H): Accept in P r i n c i p l e ~UBMITTER: Robert A. Wessel, Gypsum Assoc. _COMMENT ON PROPOSAL NO.: 101-I062 RECOMMENDATION: Delete t h i r d paragraph o f Sect ion 8 " i n t e r i o r f i n i s h " whlch permits the use o f i n t e r i o r f i n i s h m a t e r i a l s w i th a Flame spread o f 200 where a maximum of 2S would normal ly be pe rm i t t ed . SUBSTANTIATION; The s u b s t i t u t i o n o f a 200 f lame spread i n t e r i o r F in i sh can e a s i l y r e s u l t in a rap id progression of a Fire which could conceivably overpower- a sprinkler system designed for the normal flnish m a t e r i a l . The purpose o f the s p r i n k l e r system is supposed to be to ex t i ngu i sh a f i r e be fo re i t can spread. This change w i l l make i t e a s i e r For the f i r e to spread to i n v o l v e g rea te r areas than is d e s i r a b l e . I t de fea ts the purpose o f having the s p r i n k l e r system in the F i r s t p lace. This change w i l l j e o p a r d i z e the s a f e t y o f the occupant by a l l ow ing a F i r e to spread r a p i d l y , p o s s i b l y out running the s p r i n k l e r system. COMMITTEE ACTION: Accept in P r i n c i p l e .

See Committee Action on Comment 101-579 (Log #23), ~_0MHITTEE COMMENT: The Committee Action on Comment 101-579 (Log #23) should sat isfy the Commenter's intent.

364

Table G-2C.I Mandatory Requirements - Large Fac i l i t i es (For Use In Any Large Fac i l i ty )

Level of Evacuation Control Egress Refuge D i f f i c u l t y and Requirement Requ i remen t Requirement Building Height Sa Sb Sc

New Exist. New Exist. New Exist.

Prompt -<30 residents l -story 2 l .5 8.5 7.5 2.5 2 2-story 2.5 l .5 9.5 7.5 3.5 2

Prompt or slow l -s tory 5 3.5 9.5 8 5.5 4 2-story 4.5 2.5 I0.5 8 5.5 3 3-story 6.5 4.5 I0.5 8 7.5 5 4-story 6.5 4.5 10.5 8 7.5 5 5/6-story 6.5 4.5 10.5 8 7.5 5 Over 6 - s t o r y (A) 8.5 6.5 10.5 8 9.5 7

(A) Use Table G-2C.2 for f a c i l i t i e s in new high rise buildings

General Firesafety Requirement

Sd New Exist.

7 6 8 6

I0 8 I0 7 12 9 12 9 12 9 14 I I

Table G-2C.2 Mandatory Requirements - Large Fac i l i t ies (For Use Only In Sprinkler Protected Large Fac i l i ty )

Level ¢,f Evacution Control Egress Refuge D i f f i c u l t y and Requirement Requ i remen t Requirement Building Height Sa Sb Sc

New Exist. New Exist. New Exist.

Prompt <30 residents l -story 6 5.5 6.5 5.5 8.5 8 2-stor)' 2.5 l .5 7.5 5.5 5.5 4

General Firesafety Requlrement

Sd New Exist.

8 7 5 3

Prompt or Slow l -story 9 5.5 8 5.5 l l .S 8 II 7 2-story 5.5 1.5 9 5.5 8.5 4 8 3 3-story 8.5 4.5 9 5.5 I I .5 7 11 6 4-story 7.5 3.5 9 5.5 I0.5 6 I0 5 5 / 6 - s t o r y 11.5 7.5 9 5.5 10.5 6 14 9 Over 6 - s t o r y 11.5 3.5 9 5.5 10.5 2 14 5

(Log #193) lOl - 58l - (Appendix H): Accept in Principle SUBMITTER: Jon&s L. Morehart, National Inst i tutes of Health COMMENT ON PROP[~L NO.: I01-I062 RECOMMENDATION: Provide ed i tor ia l support to provide lines and columns for Tables H-2, H-3, H-4 . Ident i fy figures on pages 459, 461. SUBSTANTIATION: Current lack of horizontal and vert ical lines LO construct the tables makes usage d i f f i c u l t . Tables and figures need to be properly ident i f ied to be readily usable. qOMMITTEE ACTION: Accept in Principle.

The necessary lines w i l l be added. The figures w i l l be appropriately numbered and given the t i t l e s , respectively:

l . Approximate Fire Severity, 2. Approximate Flashover Energy, and 3. Approximate Time to Smoke Impact.

qOMMITTEE COMME~: The Committee Action should sat isfy the Commenter's intent.

(Log #189) I01 - 582 - (Appendix H): Accept in Principle SUBMITTER: C l i f fo rd Harvey, FMANA COMMENT ON PROPOSAL NO.: I01-I062 RECOMMENDATION: Revise proposed new Appendix FSES For business occupancies to track more closely with the most current edition of the NBS Fire Safety Evaluation

System for NASA Office/Laboratory Buildings, Report #NBSIR 86-3404, by H.E. Nelson. (NOTE: A complete copy of the report, as submitted by Mr. Harvey, is available for review at NFPA Headquarters.) SUBSTANTIATION: The NBSIR 86-3404 report f ine tunes the proposed Appendix addressed by Proposal I01-I062 and presents an o v e r a l l b e t t e r document. COMMITTEE ACTION: Accept in P r i n c i p l e .

I . Make r e v i s i o n s , w i t h respec t to i n t e r i o r f i n i s h , as d i r e c t e d by the Committee Ac t i on on Comment 101-579 (Log #23).

2. On TCR page 452, in the second paragraph o f the FSES text , delete the words "new or exist ing" so as to read:

"This appendix describes a system for determining the re la t ive level of safety for business occupancies as compared to exp l i c i t conformance with . . ." .

3. On TCR page 453, in the parameter 2 discussion on segregation of hazards, revise the wording addressing the subject of "s t ructura l ly endangering" per the Committee Action on Comment I01-583 (Log #15).

4. In Table H-l, on TCR page 457, move words so as to correct an alignment problem so that the headings associated with safety parameter l on construction read as follows:

365

F i r e Heavy Wood R e s i s t i v e P r o t e c t e d U n p r o t e c t e d O r d i n a r y Timber Frame

Type I Type I I Type 11 Type I I I Type IV Type V 443 or 332 222 o r I l l 000 211 200 2HH 111 000

Additionally, in safety parameter lO dealing with exlt access, change the mathematical symbols under the heading of maximum dead end to show one grouping of values For "more than" 75 Ft but "less than or equal to" I00 ft and another grouping of values For "more than" 50 ft but "less than or equal to" 7~ ft.

5. In Table H-2, TCR page 458, shade or "X out" portions of the table, as applicable, to show which parameters are to be assigned values and whlch are not.

6. If NFPA I01M is created, move the new Appendix H FSES to that document so as to become a chapter of NFPA lO1H. COMMITTEE COMMENT: The Commlt tee has compared the most r e c e n t v e r s i o n o f the NBSIR 86-3404 r e p o r t a g a i n s t the TCR d r a f t . A p p r o p r i a t e changes are no ted above i n the Commit tee A c t i o n . Wi th r e s p e c t to a p p l i c a b i l i t y o f the FSES t o new c o n s t r u c t i o n , the above change w i l l s t a t e t h a t t h e FSES a p p l i e s to bus lness occupanc les w l t h o u t a d d r e s s i n g the a p p l i c a b i l i t y to "new" o r " e x m s t i n g " . TCR Proposa l I01 836 on 26 I . I . I and 2 7 - I . I . I w i l l address t h i s s u b j e c t v i a appendi , , n o t e s . The Commit tee A c t l o n shou ld meet the Commenter 's i n t e n t .

(Log #15) I01 - 583 (Appendi~ H): Accept i n P r i n c i p l e SUBMITTER: George M. Lanler, Rome Fire Department, GA COMMENT ON PROPOSAL NO.: lOl I062 RECOMMENDATION: The primary Concern is the wording of item 2, "Segregation of Hazards" on page 453 of the 1987 Fall Meeting Technical Committee Reports. Under Step 2, "Determine the Level of Hazard", paragraph a., "Structurally Endangering" the wording In the example may be too severe. Perhaps it could be reworded along the following lines.

a. Structurally Endao~. A hazardous area with an approximate potential fire severity that may exceed the tested fire resistance of the enclosure and which could defeat the basic structural integrity of the building framing as defined in Parameter l (See Figure 1 For determining approximate potential Fire severity).

Example: For a room 20 ft by 30 ft by 8 ft high with a (windowl openlng 3 ft wlde by 4 ft high, 3000 Ib of ordinary Fuel can produce a fire severity of approximately 95 minutes. If the Fire resistance of the hazardous area enclosure is less than 95 mlnutes, and the Fire is l~kely to continue to its estimated duration, the hazardous area may be classed as structurally endangerlng. SUBSTANTIATION: The recently ~ssued Technical Committee Reports deallng with proposals for the 1988 edition of the LSC contain some provisions that concern me. The proposed Appendi, H contains a Formula for evaluating the fire severity of a space. The results are given in mlnutes of fire duratlon. AIso given is an example of a 600 sq ft space having a 12 sq ft opening. The Fuel load is given as 3,000 Ib of normal c o m b u s t i b l e s . I f my math i s r i g h t t h i s i s a 5 Ib per sq f t f u e l l oad . I n the past us ing a c o n v e r s i o n c h a r t the hea t impact would be e q u i v a l e n t to a 30 m inu te F i r e . I n such a case a I hour e n c l o s u r e shou ld be more than adequate i f p r o p e r l y c o n s t r u c t e d and m a i n t a i n e d .

The example g i ven us ing the Formula r e s u l t s i n a 95 m inu te f i r e d u r a t i o n . The t e x t c l e a r l y s t a t e s t h a t a hazard e x i s t s i f the b a r r i e r s e n c l o s i n g t he space have a r a t i n g under 95 m i n u t e s . Th i s concerns me because the LSC and o t h e r codes e s t a b l i s h minimum b a r r i e r r a t i n g s . Most are For l - h o u r and room s i z e and f u e l loads are no t d e a l t w i t h .

I n a Commit tee Comment on Appendix H i t i s c l e a r t h a t t he new m a t e r i a l w i l l a p p l y to the e v a l u a t i o n o f e x i s t i n g c o n s t r u c t i o n . However, I have a prob lem w i t h t h i s because o f the v e r y g r e a t d i f f e r e n c e s between the r e s u l t s o b t a i n e d in d e t e r m i n i n g the d u r a t l o n o f a F i r e us ing the o ld and new methods. I t seems u n r e a l l s t i c t o a p p l y t he new method to e x i s t i n g c o n d i t i o n s and t o c o n t i n u e to accep t LSC minimums For new c o n s t r u c t l o n .

I f my u n d e r s t a n d i n g o f the proposed F i r e s e v e r i t y Formula i s c o r r e c t , i t seems to me t h e r e needs t o be a ve r y c a r e f u l e v a l u a t l o n o f a l l code r e q u l r e m e n t s d e a l i n g w i t h f i r e b a r r i e r r e q u i r e m e n t s . I f t h e r e i s a proven d l f f e r e n c e o f 65 m inu tes in the f l r e d u r a t i o n c a l c u l a t i o n s f o r the g i ven space us ing the two methods , then t h e r e seems to be a need to look ve r y c l o s e l y a t code r e q u i r e m e n t s . I f the mlnimum r e q u l r e m e n t s are i nadequa te the code shou ld be updated ~ c c o r d l n g l y . I f the new method is sound, then i t seems a p p r o p r l a t e to a t l e a s t i n c l u d e i t i n t he code in Appendi~ A as a means o f d e t e r m i n i n g i f minimum code r e q u i r e m e n t s are appropriate For 'various spaces in a new or e~istlng building. If the method is appropriate for use in Appendi< A, then there needs to be some supporting materlal on realistic methods of f~eld estimatlng of fuel loads.

This or similar wording should place a degree of flexibility in the provislon. For example, the evaluator may consider Fire department actlon and the impact on the flre's duration. Perhaps it is not intended for such interventlon to be consldered, however, this ms something that needs to be determlned. COMMITTEE ACTION: Accept In Prlnciple.

On TCR page 453, In the s a f e t y pa ramete r 2 d l s c u s s l o n on s e g r e g a t i o n o f haza rds , s tep 2, r e v i s e (a) to read :

(a) S t r u c t u r a l l y Endanger ing . A hazardous a rea w l t h a p o t e n t i a l F i r e s e v e r i t y t h a t may exceed the t e s t e d Fire reslstance of the enclosure and defeat the baslc structural integrity of the building Framing as deflned in Parameter 1 (See Figure I for determining a p p r o x i m a t e p o t e n t i a l F i r e s e v e r l t y ) .

Example: For a room 20 f t by 30 f t by 8 f t h~gh w~tn a (window) open ing 3 Ft wide by 4 f t h i g h , 3000 pounds of ordinary fuel can produce a fire severity of a p p r o x i m a t e l y 9S m l n u t e s . I f the f l r e r e s i s t a n c e o f the hazardous area enclosure is less than 95 minutes, and the hre is likely to continue to Its estimated d u r a t i o n , the hazardous area may be c l a s s e d as s t r u c t u r a l l y e n d a n g e r i n g . COMMITTEE COMMENT: The m ino r e d i t o r i a l changes made to the Commenter 's proposed word ing he lp t o c l a r i f y and shou ld meet t he Commenter 's i n t e n t .

(Log #529) 101 584 (Appendi~ H): Accept i n P r i n c i p l e SUBMITTER: George H. Lanier, Rome Fire Department, GA COMMENT ON PROPOSAL NO.: I01-I062 RECOMMENDATION; Revise points addressed in Followlng s u b s t a n t i a t i o n . SUBSTANTIATION: The r e c e n t l y i ssued T e c h n i c a l Committee Reports dealing wlth proposals for the 1988 edition of the LSC contain some provisions that concern me. The proposed Appendi~ H contalns a Formula for evaluating the flre severity of a space. The results are given in minutes of Fire duration. Also glven 1s an example of a 600 sq ft space having ~ 12 sq ft opening. The fuel load is given as 3,000 lb of normal c o m b u s t i b l e s . I f my math i s r i g h t t h i s i s a S Ib per sq f t Fuel l oad . I n the past us ing a c o n v e r s i o n c h a r t t he hea t impact would be e q u i v a l e n t t o a 30 m i n u t e F i r e . I n such a case a l - h o u r e n c l o s u r e Should be more than adequate i f p r o p e r l y c o n s t r u c t e d and m a l n t a l n e d .

366

The example given using the formula results in a 95 minute Fire duration. The text c lear ly states that a hazard exists i f the barriers enclosing the space have a rating under 95 minutes. This concerns me because the LSC and other codes establish minimum barrier ratings. Most are for l-hour and room size and fuel loads are not dealt with.

In a Committee Comment on Appendix H i t is clear that the new material w i l l apply to the evaluation of exist ing construction. However, I have a problem with this because of the very great differences between the results obtained in determining the duration of a f i r e using the old and new methods. I t seems unreal ist ic to apply the new method to exist ing conditions and to continue to accept LSC minimums for new construction.

I f my understanding of the proposed Fire severity formula is correct, i t seems to me there needs to be a very careful evaluation of a l l code requirements dealing with f i r e barr ier requirements. I f there is a proven difference of 65 minutes in the Fire duration calculations for the given space using the two methods, then there seems to be a need to look very closely at code requirements. I f the minimum requirements are inadequate the code should be updated accordingly. I f the new method is sound, then i t seems appropriate to at least includ(, i t in the code in Appendix A as a means of determining i f minimum code requirements are appropriate for various spaces in new or existing buildings. I f the method is appropriate for use in Appendix A, theft there needs to be some supporting material on rea l i s t i c methods of f i e l d estimating of fuel loads.

I f i r s t saw the Formulas in a s l i gh t l y d i f ferent Form in an NBS publi(at ion "FIREFORM" by Harold Nelson. I am seeking some additional information From him on the f i r e severity formula as well as of the other formulas presented in Appendix H and in "FIREFORM". Perhaps my lack of technical training is causing me to read more into this matter than is actually there, however, I can never know unt i l I ask. qOMMITTEE ACTIOn: Accept in Principle.

See Committee Action on Comment 101-583 (Log #15). COMMITTEE COMMEN!: Although the Commenter did not ask for a specific v~ording change or action, the Committee believes that the Commenter's concerns have been addressed by the Committee Action on Log #15.

(Log #378) lot - 585 - (Appendix H): Accept in Principle SVBMITTER: H. Nelson, Gaithersburg, MD qOMMENT ON PROPOSAL NO.: I01-I062 RECOMMENDATION: In Table H-l, Parameter l , Construction, change the heading of the third column under "Noncombu~.tible" From "Wood Unprotected, Type I I I " to "Unprotected, Type I I " .

AIso under "Combustible", in the second column change "Type V" to "Type I I I " and insert the words "Type V" in the last column. SUBSTANTIATION: Editor ial revisions to coordinate with the def in i t ion in NFPA 220. COMMITTEE ACTION: Accept in Principle.

See Committee Action on Comment I01-582 (Log #189). COMMITTEE COMMENT: The Committee Action on Comment I01-582 (Log #189) should sat is fy the Commenter's intent.

(Log #377) lot - 58G - (Appendix H): Accept SUBMITTER: H.E. Nelson, Gaithersburg, MD COMMENT ON PROPOSAL NO.: I01-I062 RECOMMENDATION: Revise Table H-2 to include the "x-ed" out blocks as shown on following page: SVBSTANTIATION: This is believed to be ed i to r ia l . The x-ed out elements are essential in proper scoring of an FSES. COMMITTEE ACTION: Accept.

(Log #283) I01 - 587 - (Appendix H): Reject SUBMITTER: Daniel M. McGee, American Iron and Steel Inst i tu te qOMMENT ON PROPOSAL NO.: 101-I062 RECOMMENDATION: Return to Subcommittee for further work as Table H-I Safety Parameters appears to have errors in i t . The values assigned to the types of construction are not consistant with the values in Table C-4 of Appendix C to NFPA lOt. SUBSTANTIATION: I t would be inappropriate to publish Appendix H with errors in i t . The values assigned as safety parameter values in Table H-l for the various types of construction should be consistant with other appendices. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Differences between the point values, assigned to the various building construction types, for business occupancies and health care occupancies should not be of concern. The occupancies and the i r operations are d i f fe ren t and thus the overall structure of one FSES may be d i f fe rent From another FSES as long as the instruments adequately measure equivalency. A direct comparison of values between d i f fe rent FSES methodologies is not applicable.

Although the Commenter's recommendation has been rejected, the Committee Action on Comment I01-582 (Log #189), which revises the TCR draf t of the FSES, should meet some of the Eommenter's concerns.

367

Table H-2 Individual Safety Evaluation

SAFETY PARAMETER

1. Construct ion

2. Hazardous areas

3. Ve r t i ca l openings

4. Spr ink lers

5. Manual l i re fight=ng equipment

6. Manual f ire alarm sys tem

7. Smoke detect ion and alarm

8. In ter ior f in ish

9. Smoke contro l

10. Exi t access

1 1. Exi t system

12. Corr idor separa t ion

FIRE CONTROL

(Sl)

-:2

- 2

,-2

÷2

":2

13. Emergency prepardness

Tota l S 1 =

EGRESS PROVIDED

(S2)

X

+2

+2

+2

$2=

GENERAL FIRE SAFETY

PROVIDED ( $ 3 )

$3--

368

NOTE: The fol~owing "preprint" is included only for the convenience of the reviewer. I t incorporates the Committee Actions on Comments which address this specific chapter.

CHAPTER 8 NEW ASSEMBLY OCCUPANCIES

(See also Chapter 31.)

SEC~'ION 8-I GENERAL REQUIREMENTS

8-1.1 Application. The requirements of this chapter apply to new a:;sembly occupancies. (See 8-I.3 for def in i t ion . )

8-1.2 Mixed Occupancies. (See also 1 -4 .7 . )

8-1.2.1" Any assembly occupancy and i ts access to exits in buildrngs of other occupancy, such as ballrooms in hotels, restaurants in stores, rooftop assembly occupancies, or assembly rooms in schools, shall be so located, separated, or protected as to avoid any undue clanger to the occupants of the assembly occupancy From a Fire originating in the other occupancy or smoke therefrom.

8-1 .2 .2 Occup,~ncy o f any room or space f o r assembly purposes by fewer than 50 persons in a building of other occupanc¢ and incidental to such other occupancy shall be classed as part of the other occupancy and subject to the provisions applicable thereto.

8-1.2.3 Assemoly occupancies in buildings of other occupancy may ~se exits common to the assembly occupancy and Lhe other occupancy provided that the assembly area ~nd the other occupancy considered separately eac,~ have exits suf f ic ient to meet the requirements of th~s Code.

8-1.2.4 Exits shall be suf f ic ient for simultaneous occupancy o f both the assembly occupancy and o ther par ts o f the bJ i ' Id ing .

Exception*: W~ere the authority having jur isd ic t ion determines that the conditions are such that simultaneous o:cupancy w i l l not occur.

8-1.3 ~ Special Definit ions.

Assembly Occupancies. Include, but are not limited to, a l l buildings or portions of buildings used for gathering together 50 or more persons for such purposes as deliberation, worship, entertainment, dining, amusement, or awaiting transportation.

Cyclorama. The name generally applied to a neutral background that, with suitable l ighting, can suggest the i n f i n i t e space of the sky. I t may be curved and may be painted to depict any required background.

Drop. A large piece of scenic canvas which hangs vert~cal ly, usually across the stage area.

Flow Time. Flow time is the time during which there is crowd flow past a point in the means of egress system, and i t is a component of total evacuation time.

Fly. The space over the stage of a theater where scenery and equipment can be hung out of view. Also called lo f t s and rigging lo f ts .

Fly Gallery. A narrow raised platform at the side of a legitimate stage from which the lines for f ly ing scenery are manipulated.

Gridiron. The arrangement of beams over a legitimate stage supporting the machinery for f ly ing scenery and hanging batters from which l ighting is hung.

Leg Drop. A long narrow s t r ip of fabric used for masking. Where used on either or both sides of the acting area, to provide entry to the stage by the actors, but also to mask. They may also be called "wings".

Life Safety Evaluation. A l i f e safety evaluation is a written review dealing with the adequacy of l i f e safety Features relat ive to Fire, storm, collapse, crowd behavior, and other related safety considerations.

Multi-Purpose Assembly Occupancy. An assembly room designed to accommodate temporarily any of several possible assembly uses.

Pinrai l . A beam at one side of a legitimate stage through which wooden or metal pins are driven, and to which lines from the f l i e s are fastened.

Platform." That raised area within a building used for the presentation of music, plays or other entertainment; the head tables for special guests; the raised area for lecturers and speakers; boxing and wrestling rings; theater-in-the-round; and similar purposes wherein there are no overhead drops, scenery or stage effects other than l ighting and a screening valance.

Platform, Temporary. A platform erected within an area for not more than 30 days.

P la t fo rm, Permanent. A p l a t f o r m erected w i t h i n an area For more than 30 days.

Proscenium Wall. The wall that separates the stage from the auditorium or house.

Smoke-Protected Assembly Seating.* Seating served by means of egress that is not subject to blockage by smoke accumulation within or under a structure.

Special Amusement Building. Any building, temporary, permanent or mobile, containing a device or system which conveys PaSSengers or provides a walkway along, around or over a course in any direction as a form of amusement so arranged that the egress Path is not readily apparent due to v~sual or audio distractions or intentionally confounded egress path, or is not readily available due to the mode of conveyance through the building or structure. Included are such amusements as a "haunted house," a " ro l l e r coaster" type ride within a building, a "merry-go-round" w i t h i n a building, a "submarine" ride and similar amusements where the occupants are not in the open a i r .

Stage. An area within a building used For the purpose of entertainment, and u t i l i z ing drops or scenery or other stage effects and shall be classif ied as one of the following:

(a) Stage, Legitimate. A stage wherein scenery is retractable mechanically, either horizontal ly or ve r t i ca l l y or suspended overhead.

(b) Stage, Regular. A stage wherein scenery is not retractable.

(c) Stage, Thrust. A platform extending beyond the proscenium arch and into the audience.

Stage Properties. Furniture, carpet and similar materials generally having an overall height of less than 5 f t (152 Cm) and used to provide an appearance simulating a room or area.

Stage Scenery. Decora t i ve m a t e r i a l s such as F l a t s , cycloramas, painted or photograph ic backings, and s i m i l a r ma te r i a l s to "d ress" the stage.

369

8-1.4 Classif ication of Occupancy. (See 4 1.2.)

8 -1 .4 .1 Subclassification of Assembly Occupancies, Each assembly occupancy shall be subclassified according to i ts occupant load as follows: Class A, occupant load greater than lO00 persons; Class B, occupant load greater than 300 but not greater than lOOO persons; Class C, occupant load of 50 or more but not greater than 300 persons.

8-1.5 Classif ication of Hazard of Contents. Contents of assembly occupancies shall be classif ied in accordance with the provisions of Section 4-2.

8-1.G Minimum Construction Requirements (see G-2.1). The location of an assembly occupancy shall be limited as follows:

Type o f

C o n s t r u c t i o n

I (443) 1 (332)

!1 (222)

ll (111)

III (211) IV (2HH)

V ( l i t )

11 (000)

I l l (200) v (oo0)

B e l o w

L E D

AfBfC~" Any N u m b e r

of Levels

A l B t C t O n e Level

Below L E D

AtBtCt O n e Level

Below L E D

B+C* Onc Level

Below L E D

BfCt One Lcvel

Below L E D

Number of Levels Above L E D

4 & L E D 1 2 3 Above

A B C A B C A B C A B C A~fBI"C

A B C A B C A f B C B t C t N.P ,

A B C A B C Ai 'B i 'C B t C t N .P .

A t B C C f N.P . N .P . N.P .

BC C1" N ,P . N.P . N.P .

t~rmit ted if all the ~llowmg are protected throughout by an approved, su~rvised automatic sprinkler system m acco~ance with S~tion 7-7:

(a) The level of the assembly ~cu~ncy, and (b) Any level ~low the level of the assembly ~cu~ncy, and (c) In the case of an assembly occupancy l~ated ~low the level of exit

discharge, any level inte~ening between that level and the level of exit discharge, including the level of exit discharge. N.P. - - Not ~rmitted LED - - Level of Exit Discharge

8-1.7 Occupant Load.

8-].7.1" The occupant load permitted in any assembly building, structure, or portion thereof, shall be determined on the basis of the following occupancy load factors:

(a) ~ An assembly area of concentrated use without fixed seats such as an auditorium, place of worship, dance f loor , discotheque or lodge hall - one person per 7 net Sq f t (0.65 sq m).

(b) An assembly area of less concentrated use such as a conference room, dining room, drinking establishment, exhibit room, gymnasium, or lounge - one person per 15 net sq ft (I.4 sq m).

(c) Bleachers, pews and similar bench-type seating - one person for 18 linear in. (45.7 linear cm).

(d) Fixed Seating. The occupant load of an area having fixed seats shall be determined by the number of fixed seats installed. Required aisle space serving the fixed seats shall not be used to increase the occupant load.

(e) Kitchens. One person per I00 gross sq ft (9.3 sq m).

( f ) Libraries. In stack areas one person per ]00 gross sq f t (9.3 sq m); in reading rooms - one person per 50 net sq f t (4.6 sq m).

8-I.7.2 The occupant load permitted in a building or portion thereof may be increased above that specified in 8-l.7.1 i f the necessary aisles and exits are provided. To increase the occupant load, a diagram indicating placement of equipment, aisles, exits, and seating shall be provided to and approved by the authority having jur isdict ion prior to any increase in occupant load. In areas not greater than lO,OOO sq f t (930 sq m) the occupant load shall not exceed one person in 5 sq f t (.46 sq m); in areas greater than I0,008 sq f t (930 sq m) the occupant load shall not exceed one person in 7 sq f t (.65 sq m).

8-].7.3 Waiting Spaces. In theaters and other assembly occupancies where persons are admitted to the building at times when seats are not available to them, or when the permitted occupant load has been reached based on 8-1.7.1 or 8-].7.2, and persons are allowed to wait in a lobby or similar space unt i l seats or space are available, such use of lobby or similar space shall not encroach upon the required clear width of exits. Such waiting shall be restricted to areas other than the required means of egress. Exits shall be provided for such waiting spaces on the basis of one person for each 3 sq f t (0.28 sq m) of waiting space area. Such exits shall be in addition to the exits specified for the main auditorium area and shall conform in Construction and arrangement to the general rules for exits given in this chapter.

SECTION 8-2 MEANS OF EGRESS REQUIREMENTS

8-2.1 General. All means of egress shall be in accordance with Chapter 5 and this chapter.

8-2.2 Means of Egress Components.

8-2.2.1 Components of means of egress shall be limited to the types described in 8-2.2.2 through 8-2.2.7.

8-2.2.2 Doors.

8-2.2.2.] Doors shall comply with 5-2.1.

8-2.2.2.2 Class C assembly occupancies in covered malls (see 24-4.3.1 Exception) may have horizontal or vert ical security g r i l l es or doors complying with 5-2.].4.1 Exception No. 3 on the main entrance/exits.

8-2.2.2.3 Panic Hardware or Fire Exit Hardware. Any door in a required means of egress from an area having an occupant load of 100 or more persons may be provided with a latch or lock only i f i t is panic hardware or f i r e exi t hardware complying with 5-2.1.7.

Exception No. I: In assembly occupancies having an occupant load not greater than 500, when the main exi t consists of a single door or single pair of doors, locking devices complying with 5-2.1.5.1 Exception No. 2 may be used on the main exi t . Any latching device on this door(s) shall be released by panic hardware.

Exception No. 2: Special locking arrangements as permitted in 8-2.2.2.4.

8-2.2.2.4 Special locking arrangements complying with 5-2.1.6 are permitted on doors other than main entrance/exit doors.

8-2.2.2.5 Revolving doors complying with 5-2.1.I0 are permitted.

8-2.2.2.6 Turnstiles. No turnst i les or other devices to res t r i c t the movement of persons shall be instal led in any assembly occupancy in such a manner as to interfere in any way with required means of egress f a c i l i t i e s .

370

8-2.2.3 Stairs. Stairs shall comply with 5-2.2.

8-2.2.4 Smokeproof Enclosures. Smokeproof enclosures shall comply with 5-2.3.

8-2.2.5 Horizontal Exits. Horizontal exits shall comply with 5-2.4.

8-2.2.6 Ramps.

8-2.2.6.1 Ramps shall comply with 5-2.5.

8-2.2.6.2 Ramps in Class A assembly occupancies shall be Class A ramps.

8-2.2.7 Exit Passageways. Exit passageways shall comply with 5-2.6.

8-2.3 Capacity of Means of Egress.

0-2.3.l The capacity of means of egress shall be in accordance with Section 5-3 or, in the case of means of egress serving theatre-type seating or similar seating arranged in rows, in accordance with 8-2.3.2.

Exception: Means of egress serving assembly seating shall be in accordance with 8-2.3.2.

8-2.3.2" Minimum clear widths of aisles and other means of egress shall be in accordance with Table 8-2.3.2(a) or, for buildings providing Smoke-Protected Assembly Seating and for which an Approved Life Safety Evaluation is conducted, Table 8-2.3.2(b). For Table 8-2.3.2(b) the number of seats specified n~Jst be within a single assembly space and interpolation shall be permitted between the specific values shown. For both tables the minimum clear widths shown shall be modified in accordance with a l l of the following:

(a) I f r isers exceed 7 in. in height, multiply the s ta i r width in the Tables by factor A, where A = I + ( r i~er heiqht -7.0 in . ) .

5

(b) Stairs r, ot having a handrail within a 30-in. (76 cm) horizontal distance shall be 25 percent wider than otherwise calcblated, i .e . , multiply by B = 1.25.

(c) Ramps steeper than 1 in 10 slope, used in ascent, shall Dave their width increased by tO percent, i . e . , mult iply by factor C = 1.10.

Table 8-2.3.2(a) (For Use Without Smoke Protected Assembly Seating)

No. of Seats

Inch of Clear Width Per Seat Served

Passageways, Nominal Ramps and

Flow Time (sec.) Stairs Doorway~

Unlimited 200 0.300 AB 0.220C

Table 8-2.~.2(b) (For Use With Smoke-Protected Assembly Seating)

No. of Seats


Passageways, Nominal Ramps and

flow Time (sec.) Stairs DoorwaYS

2,000 5,000

10,000 15,000 20,000 25,000 or more

200 0.300 AB 0.220C 260 0.200 AB 0.150 C 360 0.130 AB 0.100 C 46 0.096 AB 0.070 C 560 0.076 AB 0.056 C 660 0.060 AB 0.044 C

8-2.3.3 Main Entrance/Exit. Every assembly occupancy shall be provided with a main entrance~exit. The main entrance/exit shall be of suf f ic ient width to accommodate one-half of the total occupant load but shall be not less than the total required width of a l l aisles, ex i t passageways, and stairways leading thereto and shall be at the level of ex i t discharge or shall connect to a stairway or ramp leading to a street. Each level of an assembly occupancy shall have access to the main entrance/exit, and such access shall have Sufficient capacity to accommodate 50 percent of the occupant load of such levels.

Exception No. I: A bowling establishment shall have a main entrance/exit of suf f ic ient capacity to accommodate SO percent of the total occupant load without regard to the number of aisles that i t serves.

Exception No. 2: In assembly occupancies where there is no well defined main entrance/exit, such as stadiums, sports arenas, and passenger stations, exits may be distributed around the perimeter of the building provided the total ex i t width provides f ig 2/3 percent of the width needed to accommodate the permitted occupant load.

8-2.3.4 Other Exits. Each level of an assembly occupancy shall have access to the main entrance/exit and shall be provided with additional exits of suf f ic ient width to accommodate two-thirds of the total occupant load served by that level. Such exits shall discharge in accordance with 8-2.7. Such exits shall be located as far apart as practicable and as far from the main entrance/exit as practicable. Such exits shall be accessible From a cross aisle or a side aisle. (See 8-2.3.2.)

Exception No. l : Where only two exits are required, each exi t shall be of suf f ic ient width to accommodate not less than half the total occupant load.

Exception No. 2: In assembly OCCUpancies where there is no well defined main entrance/exlt, such as stadiums, sports arenas, and passenger stations, exits may be distributed around the perimeter of the building provided the total ex i t width provides f ig 2/3 percent of the width needed to accommodate the permitted occupant load.

8-2.4 Number of Exits.

8-2.4.1 Every Class A assembly occupancy shall have at least four separate means of egress as remote From each other as practicable.

8-2.4.2 Every Class B assembly occupancy shall have at least two separate means of egress as remote From each other as practicable and, i f of a capacity of over 500, at least three separate means of egress, each not less than two exi t units wide.

8-2.4.3 Every Class C assembly occupancy shall have at least two means of egress consisting of separate exits or doors leading to a corridor or other spaces giving access to two separate and independent exits in d i f ferent directions.

8-2.4.4 Balconies or mezzanines having an occupant load not greater than 50 may be served by a single means of egress and such means of egress may lead to the f loor below.

8-2.4.5 Balconies or mezzanines having an occupant load greater than 50 but not greater than I00 shall have at least two remote means of egress, but both such means of egress may lead to the f loor below.

8-2.4.6 Balconies or mezzanines having an occupant load greater than tO0 shall have means of egress provided as For a f loor .

371

8-2.5 Arrangement of Means of Egress.

8-2.5.1 Exi ts shall be remote From each other and shal l be arranged to minimize the p o s s i b i l i t y that they may be blocked by any emergency.

Exception No. I: A common path of t ravel may be permitted fo r the F i rs t 20 f t (6. I m) From any point.

Exception No. 2: AS provlded in 8-2.4.4.

8-2.5.2 Means of egress shal l not be permitted through kitchens, storerooms, restrooms, closets, or hazardous areas as described in 8-3.2.

8-2.5.3 Where the Floor area of auditoriums and arenas is used fo r areas described by 8 -1 .7 . ] , at least 50 percent of the occupant load shall have means of egress provided independent of the means of egress For adjacent f i x e d s e a t i n g a r e a s .

8 - 2 . 5 . 4 S e a t i n g .

8 - 2 . 5 . 4 . 1 The s p a c l n g o f rows o f c h a i r s s h a l l p r o v i d e a space o f no t l e s s t h a n 12 i n . ( 30 .5 cm) From the back o f one c h a i r t o the F r o n t o f t he most Forward p r o j e c t i o n o f t he c h a i r i m m e d i a t e l y beh ind ~ t . The rows o f c h a l r s s h a l l be spaced no t l e s s than 33 i n . (84 cm) back to back. Horizontal measurements shall be made between ve r t i ca l planes. Where a l l chairs in a row have automatic or s e l f - r i s i n g seats which comply with ASTM F851 Test Method For Self R~sing Seat Mechanisms, t he measurement may be made w i t h the s e a t s i n t he up P o s i t i o n . Where any c h a i r i n the row does no t have an a u t o m a t i c o r s e l f - r i s i n g s e a t , t he measurement s h a l l be made w i t h the sea t i n t he down p o s i t ~ o n .

8-2,5.4.2* For rows of chairs served by ais les or doorways at both ends, there shall be no more than I00 s e a t s pe r row and t he min imum c l e a r w i d t h between rows o f 12 i n . ( 3 0 . 5 cm) s h a l l be i n c r e a s e d by 0 .3 i n . (.76 cm) fo r every addi t ional seat beyond 14. but need not exceed 22 in. (55.9 cm).

8 - 2 . 5 . 4 . 3 For rows o f c h a i r s se r ved by an a i s l e o r doorway a t one end o n l y , t he minimum c l e a r w i d t h between rows o f 12 i n . ( 3 0 . 5 cm) s h a l l be i n c r e a s e d by O.G i n . ( I . 5 2 cm) f o r e v e r y a d d i t i o n a l seat beyond 7, bu t need no t exceed 22 i n . ( 5 5 . 9 cm).

8 - 2 . 5 . 4 . 4 For rows o f c h a i r s se rved by an a i s l e o r doorway a t one end o n l y , t he pa th o f t r a v e l s h a l l no t exceed 30 f t (9 .1 m) From anz s e a t to a p o i n t where a person has a choice of two paths of t ravel to two ex i t s .

8-2.5.4.5 Chairs without d iv ld ing arms shall have t h e i r capacity determined by allowing 18 in. (45.7 cm) per person.

8-2.5.4.6 Where bleacher or grandstand seatlng without backs is used indoors, rows of seats shal l be spaced not less than 22 in. (55.9 cm) back to back.

Exception: Folding or telescopic seating shal l comply with NFPA 102, Standard fo r Assembly Seating, Tents, and Membrane Structures, with a l i m i t of dead ends in ve r t i ca l a is les of 16 rows.

8-2.5,4.7 ~ Fixed or loose chairs, tables and s~milar furnishings or equipment shal l be so arranged and maintained that a path of t ravel to an a~sle or e x i t is provided. The path of t ravel shall not exceed 10 Ft (3 m) From any point to an a is le or ex i t .

8-2.5.4.8 ~ Rectangular banquet type tables used fo r dr inking or dining, or purposes having s im i la r seating conf igurat ions with the path of t ravel to an a is le exceeding I0 f t (3 m), shall be Spaced not less than 54 in. (137 cm) apart where seating occurs back to back

. J no r l e s s t han 36 i n . (91 cm) where s e a t i n g i s on one s i d e o n l y . The p a t h o f t r a v e l t o an a i s l e o r e x i t s h a l l n o t exceed 20 Ft (6 .1 m).

8-2.5.5* Tablet-Arm C h a i r Seating.

8-2.5,5.1 Tablet-arm chairs shall not be permitted unless f u l l compliance of row space requirements is provided when the tab le t arm is in the usable posit ion. Tablet-arm chairs that do not have a stored posi t ion fo r the tab le t arm shall not be permitted u n l e s s the c l e a r a n c e r e q u i r e d by 8 - 2 . 5 . 4 between rows o f c h a i r s i s p r o v i d e d and m a i n t a i n e d .

8-2.5.5.2 Where tab le t arm chairs are used, the clear width of rows of seats should be measured w~th a tab le t arm in the up or use posi t ion.

Exception: Tablet arms may be measured ~n stored posit ion where the tab le t arm automatical ly returns to the stored posi t lon when raised manually in one motion to a ver t i ca l posi t ion and Fal ls to the stored pos~tlon by force of grav i ty .

8 - 2 . 5 . 6 A i s l e s .

8-2.5.6.1 Aisle width shall provide s u f f i c i e n t egress capacity fo r the number of persons accommodated by the catchment areas served by the a is le . The catchment area served by an a is le is that port ion of the tota l space that is na tura l l y served by that section of the a is le . The establishment of catchment areas shall be based on a balanced use of a l l means of egress with the number of persons in proport ion to egress capaclty.

8 - 2 . 5 . 6 . 2 Where a i s l e s conve rge to f o r m a s l n g l e pa th o f egress t r a v e l , t he r e q u l r e d eg ress c a p a c i t y o f t h a t pa th s h a l l be no t l e s s t han the combined r e q u i r e d capacity of the converglng ais les,

8 - 2 . S . 6 , 3 A i s l e s s h a l l t e r m i n a t e a t a c ross a l s l e , Foyer , doo r , o r v o m i t o r y g i v i n g access to an e x l t .

8 - 2 . 5 . 6 . 4 Dead end a~s les s h a l l no t e . t e e d 20 f t (G.1 m) i n l e n g t h .

Exception: ~ longer dead-end axsle ~s permitted where seats served .by the dead-end a~sle are not more than 24 sea ts From a n o t h e r a l s l e measured a l o n g a row o f sea ts h a v i n g a minimum c l e a r w i d t h o f 12 ~n. ( 3 0 . 5 cm) p lus 0 .6 i n . ( I . 5 cm) f o r each a d d i t i o n a l sea t above 7 ~n t he row.

8 - 2 . 5 . 6 . 5 I n a i s l e s where eg ress i s p o s s i b l e in more than one d i rec t ion , the ais les shall be uniform in required widths•

8 - 2 . 5 . 6 . 6 The width of ais les shall be sized in accordance with 8 2.3.1.

8-2.5.G.7 In theater and s lm l la r type seating f a c i l i t l e s , the minimum clear width of a ls les shall be as determined by 8-2.3.2 but not less than:

(a) q8 in. (122 cm) For s ta i rs having seating on each side.

(b) 36 in. (9l cm) For s ta i rs having seating on only one s i d e .

(c) 23 In. (58 cm) between a handrail or guardrall and s e a t i n g where t he a ~ s l e ~s s u b d i v i d e d by a h a n d r a i l ,

(d) 42 in. (107 cm) for level or ramped aisles having seating on both sides,

(e ) 36 i n . (91 cm) For l e v e l or ramped a~s les h a v i n g s e a t i n g on o n l y one s i d e .

( f ) 23 i n . (58 cm) between a handra11 and s e a t i n g when ais le does not serve more than Five rows on one side.

372

8-2.5.6.8* In table and chair type seating Fac i l i t ies the minimum clear width of aisles shall be as determined by 8-2.3.1, but not less than 36 in. (91 cm). Where loose seating occurs bordering on the aisle, the minimum aisle width is required plus an additional 19 in. (48 cm) for chairs on one side or an additional 38 in. (97 cm) For chairs on both sides of the aisle.

8-2.5.6.9 Aisle Stairs and Ramps. Every aisle with a gradient l in 8 or less shall consist of a ramp. Every aisle with gradient exceeding l in 8 shall consist of a s ta i r having treads, r isers and handrails complying with the Following requirements:

(a)* Tread oepth shall be uniform in each aisle.

(b)* Treads shall be a minimum of II ~n. (27.9 cm).

(c) Riser heights shall be a minimum of 4 in. (I0.2 cm).

(d) Riser heights shall not exceed 8 in. (20.3 cm).

Exception No. ~ to (d): Where the gradient of an aisle exceeds 8 in. (20.3 cm) in r ise and II in. (27.9 cm) of run ( t o ma in ta in necessary s i g h t l i n e s in the a d j o i n i n g sea t ing a rea ) , the r i s e he igh t may exceed 8 in . (20.3 cm) but sha l l not exceed 9 in . (22.9 cm).

Exception No. 2 to (d): Folding and telescopic seating in accordance with NFPA I02, Standard For Assembly Seating Tents and Membrane Structures.

(e)* Riser heights shall be uniform within a Flight.

Exception to (e): Riser height may be nonuniform, but only to the ex1:ent necessary due to changes in gradient within a seating area to maintain necessary sight l ines. Where nonuniFormities exceed 3/IG in. (0.5 cm) between adjacent r isers, the exact locatlon of such nonuniformitie'~ shall be indicated by a dist inct ive marking stripe on each tread at the nosing or leading edge adjacent Lo the nonuniform r isers.

(F) Ramped ~isles having a gradient exceeding 1 in ]5 and aisle stairs, shall be provided w~th handrails at one side or a'long the center l ine.

Where there is seating on both sides of the aisle, the handrails shall be discontinuous with gaps or breaks at intervals not exceeding Five rows to Faci l i ta te access to seating, and to permit crossing from one side of the aisle to the other. These gaps or breaks shall have a clear width of at least 22 in. (55.9 cm) and noi~ greater than 36 in. (91 cm) measured horizontal ly, and the handrail shall have rounded terminations or bends. Where handrails are provided in the middle of aisle sta i rs, there shall be an additional intermediate ra i l located approximately 12 in. (30 cm) below the main handrail.

Exception No 1: Handrails are not required For ramped aisles having a gradient not greater than l in 8 and having seating on both sides.

Exception No. 2: Handrails are not required i f , at the side of the aisle, there Is a guardrail that complies with the graspability requirements For handrails.

(g)* A contrasting marking stripe shall be provided on each tread at the nosing or leading edge such that the location o f such t read is readily apparent, par t icular ly when viewed in descent. Such stripes shall be at least l in. wide and shall not exceed 2 in. wide.

Exception: The marking str ipe may be omitted where tread surfaces and environmental conditions in a l l conditions of use are such that the location of each tread is read'ly apparent, par t icular ly when viewed in descent.

8-2.5.6.]0 Where required by the authority having jur isd ic t ion, plans drawn to scale showing the arrangement of Furnishings or equipment shall be submitted to the authority by the building owner, manager or authorized agent to substantiate conformance with the provisions of this section and shall constitute the only acceptable arrangement unt i l revised or additional plans are submitted and approved.

Exception: Temporary deviations from the specifics of the approved plans shall be permitted provided the occupant load is not increased and the intent of this section is maintained.

8-2.6 Travel Distance to Exits. Exits shall be so arranged that the total length of travel From any point to reach an exit w i l l not exceed 150 Ft (45 m) in any assembly occupancy.

Exception: The travel distance may be increased to 200 f t (GO m) in assembly occupancies protected throughout by an approved automatic sprinkler system.

8-2.7 Discharge From Exits.

8-2.7.1 Exit discharge shall comply with Section 5-7.

8 2.7.2 The level o f exit discharge shall be measured at the point of principal entrance to the building.

8-2.7.3 Where the principal entrance to an assembly occupancy is via a terrace, either raised or depressed, such terrace may be considered to be the level of exi t discharge For the purposes of 8-1.6 i f :

(a) The terrace is at least as long (measured parallel to the building) as a total width of the exi t (s) ~t serves, but not less than 5 f t (153 cm) long, and

(b) The terrace is at least as wide (measured perpendicular to the building) as the ex i t (s) i t serves, but not less than tO f t (3 m) wide, and

(c) Required stairs leading From the terrace to grade are protected in accordance with 5-2.2.3,2 or are a minimum of 10 f t (3 m) From the building.

8-2.8 Illumination of Means of Egress. Means of egress shall be illuminated in accordance with Section 5-8.

8-2.9 Emergency Lighting. Emergency lighting shall be provided in accordance with Section 5-9.

8-2.10 Harking of Heans of Egress. Means of egress shall have signs in accordance with Section S-tO.

8-2.11 Special Features.

8 -2 .11 . I Railings.

(a) The Fasciae of boxes, balconies, and gal leries shall not rise less than 26 in. (86 cm) high above the adjacent Floor or shall have substantial ra i l ings not less than 26 in. (66 cm) high above the adjacent Floor.

(b) The height of the ra l l above Footrests on the adjacent Floor immediately in Front of a row of seats shall be no less than 26 in. (66 cm). Pailings at the ends of aisles shall not be less than 36 in. (91 cm) high for the Full width of the aisle and shall be not less than 42 in. (107 cm) high For the width of the aisle where steps occur.

(c) Cross aisles shall be provided with rai l ings not less than 26 in. (6G cm) high above the adjacent Floor.

Exception: Where the backs oF seats on the Front of the aisle project 24 in. (60 cm) or more above the adjacent Floor of the aisle.

373

SECTION 8-3 PROTECTION

8-3.1 Protection of Vertical OPenings. All in ter ior stairways and other vert ical openings shall be enclosed and protected as provided in Section 6 2.

Exception NO, I: Unprotected openings connecting not more than three f loors may be permitted provided that they comply with 6-2.4.4.

Exception No. 2: Atriums in accordance with 6-2.4.5 are permitted.

Exception No. 3: Stairs may be open between balconies and main assembly f l o o r s in t h e a t e r s , churches, or aud i t o r i ums where the t r a v e l d i s t a n c e is w i t h i n the a l l o w a b l e l i m i t s (see 8 - 2 . 6 ) .

8-3.2 Protection From Hazards.

8-3.2.1 Stages and Platforms. (See 8-1.3.)

8 3,2.1.1 Materials and Design. Materials used in the construction of platforms and stages shall conform to the applicable requirements of the local building code.

8-3.2.1.2 Platform Construction. Temporary platforms may be constructed of any materials. The space between the Floor and the platform above shall not be used For any purpose other than electr ical wiring to platform equipment.

Permanent p l a t f o r m s s h a l l be cons t ruc ted o f m a t e r i a l s r e q u i r e d For the type o f c o n s t r u c t i o n o f the b u i l d i n g in which the permanent p l a t f o r m is l oca ted . Where the space beneath the p l a t f o r m is used For s to rage or any purpose o the r than equipment w i r i n g or p lumbing, the f l o o r c o n s t r u c t i o n s h a l l be not less than l - h o u r f i r e - r e s i s t i v e . Where the space beneath the p l a t f o r m 7s not used For any purpose other than equipment wiring or plumbing, the underside of the permanent platform need not be protected.

8 3.2.1.3 Stage Construction. Regular stages and thrust stages shall be constructed of materials required For the type of construction of the building in which they are located. In a l l cases the Finish f loor may be of wood.

Legitimate stages shall be constructed of materials required for Type I buildings, except that the area extending From the proscenium opening to the back wall of the stage and for a distance of 6 Ft (183 cm) beyond the proscenium opening on each side, may be constructed of steel or heavy timber covered with a wood Floor not less than l I/2 in. (3.8 cm) in actual thickness.

Openings through Stage f loors (traps) shall be equipped with t i g h t - f i t t i n g trap doors of wood having an actual thickness of not less than 1 I/2 in. (3.8 cm) with approved safety locks.

8-3.2.1.4 Accessory Rooms. Dressing rooms, workshops and storerooms accessory to stages shall be separated From each other and From the stage by not less than l-hour Fire-resistive construction, and openings within such separations shall be protected as required for corridors (20 minute Fire door assemblies).

Exception: A separation is not required For stages having a Floor area not exceeding 500 sq Ft (46.5 sq m).

8 - 3 . 2 . 1 . 5 Vents. L e g i t i m a t e stages sha l l be p rov ided w i t h one or more vents c o n s t r u c t e d o f noncombust ib le m a t e r i a l . V e n t i l a t o r s s h a l l be l oca ted near the cen te r and above the h i g h e s t pa r t o f the stage. They s h a l l be ra i sed above the stage r o o f and s h a l l have a t o t a l v e n t i l a t i o n area equal to a t l e a s t 5 percent o f the f l o o r area o f the s tage.

Regular stages exceeding 1,000 sq Ft (93 sq m) in area s h a l l be prov ided w i th vents as r e q u i r e d For l e g i t i m a t e stages or s h a l l be p rov ided w i t h a mechanical vent i n s t a l l e d in an e x t e r i o r wa l l o f the stage i t s e l f . Such vent s h a l l be au tomat i c upon o p e r a t i o n o f the s p r i n k l e r system and s h a l l a l so be capable o f manual o p e r a t i o n . The c a p a c i t y o f the exhaust vent s h a l l be app rox ima te l y e q u i v a l e n t to t h a t which would be prov ided For a l e g i t i m a t e stage.

Vents shall open by spring action or Force of gravity sufficient to overcome the effects of neglect, rust, dirt, frost, snow, or expansion by heat or warping of the Framework. Glass, if used in vents, must be protected against falling onto the stage. A wire screen, if used under the glass, must be so placed that, if clogged, it cannot reduce the required vent area or interfere with the operating mechanism or obstruct the distribution of water From an automatic sprinkler. Vents shall be arranged to open autOmatically by the use of fusible links. The Fusible links and operating cable shall hold each door closed against the minimum 30 Ib (133 N) countergorce, which may be exerted by sprlngs or counterweights. This minimum counterForce shall be exerted on each door through its entire arc of travel and for a minimum of I15 degrees. A manual control shall also be provided.

Spr ings , where employed to ac tua te doors, s h a l l be capable of maintaining Ful l required tension, Springs shall not be stressed more than 50 percent of their rated capacity and shall not be located directly in the a i r s t ream nor exposed to the o u t s i d e .

A Fus ib le l i n k sha l l be placed in the cab le c o n t r o l system on the unders ide o f the vents at or above the r o o f l i n e or as approved by the a u t h o r i t y having j u r i s d i c t i o n and sha l l be so l oca ted as not to be a f f e c t e d by the ope ra t l on o f a F i r e s p r i n k l e r system. Remote, manual or e l e c t r i c a l c o n t r o l s s h a l l p rov lde For both opening and c l os i ng o f the vent doors For p e r i o d l c t e s t l n g and s h a l l be loca ted at a p o i n t on the stage designated by the authority having jurisdiction. Where remote control vents are electrical, power fallure shall not affect their instant operation in the event of Fire. Hand winches may be employed to Facilitate operation of manually controlled vents.

8 - 3 . 2 . 1 . 6 Proscenium Wal ls . L e g i t i m a t e stages s h a l l be comp le te l y separated From the sea t i ng area by a proscenium wa l l o f not less than 2-hour F ~ r e - r e s i s t i v e noncombust lb le c o n s t r u c t i o n . The proscenlum wal l s h a l l extend a t l e a s t 4 Ft (122 cm) above the r o o f o f the a u d i t o r i u m .

Proscenium w a l l s may have, in a d d i t i o n to the main proscenium opening, one opening at the orchestra pit level and not more than two openings ~nto the auditorium at the legitimate Stage floor level. Each such opening shall not be more than 25 sq Ft (2.3 sq m) in area.

A l l openings in the proscenium wa l l o f a l e g i t i m a t e stage s h a l l be p ro tec ted by a f i r e assembly hav ing a I I/2-hour Fire protection rating, except that the main proscenium opening used For viewing performances shall be provided with an automatic-closing Fire-resistive curtain as described below.

8 3 . 2 . 1 . 7 Proscenium C u r t a i n . The proscenium opening o f every l e g i t i m a t e stage sha l l be p rov ided w i t h a c u r t a i n cons t ruc ted and mounted so as to i n t e r c e p t hot gases, f lames and smoke and to guard agaTnst seeing f lame From a F i re on the stage From the a u d i t o r i u m s ide w l t h i n a F i ve -m inu te per iod when the c u r t a i n is o f asbestos. Other m a t e r i a l s may be used i f they have passed a t h l r t y - m i n u t e F i re t e s t in a smal l sca le Furnace, 3 f t by 3 f t , w i t h the sample mounted in the h o r i z o n t a l p lane at the top o f the fu rnace and sub jec ted to the standard t i m e - t e m p e r a t u r e curve .

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The curtain shall be automatic closing without the use of applied power.

Exception: In l ieu of the protection required herein, a l l the following may be provided:

(a) A noncombustible opaque fabric curtain so arranged that i t w i l l close automatically, and

(b) An automatic fixed waterspray deluge system shall be located on the auditorium side of the proscenium opening and be so arranged that the entire Face of the curtain wi l l be wetted. The system shall be activated by a combination of ra te-o f - r ise and fixed-temperature detectors located on the ceil ing of the stage. Detectors shall be spaced in accordance with their l is t ing. The water supply shall be controlled by a deluge valve and shall be suf f ic ient to keep the curtain completely wet for 30 minutes or unti l the valve is closed by Fire department personnel, and

(c) The curtain shall be automatically operated in case of Fire by a combination of ra te-of - r ise and Fixed-temperature detectors which also activate the deluge spray system. Stage sprinklers and vents shall be automatically operated in case of f i r e by Fusible elements, and

(d) Operation of the stage sprinkler system or spray deluge valve shall automatically activate the emergency ventilating szstem and close the curtain, and

(e) The cu'-tain, vents and spray deluge system valve shall also be capable of manual operation.

8 - 3 . 2 . 1 . 8 G r i d i r o n s , Fly G a l l e r i e s and P~n ra i l s , G r i d i r o n s , f l / g a l l e r i e s and p i n ra~ I s sha l l be cons t ruc ted o ,= noncombustlble m a t e r i a l s .

8-3.2.1.9 Fire Protection. Every stage (legitimate, regular, or thrust) larger than 500 sq f t (46.S sq m) in area shall have a system of automatic sprinklers at the cei l ing, in usable spaces under the stage, in aux i l ia ry spaces and dresslng rooms, storerooms, and workshops. Where there is a stage gridiron, 13S°F (57°C) rated ~idewall sprinklers with heat-baffle plates shall )e installed around the perimeter of the stage, except above the proscenium opening, at points not more than 30 in. (76 Cm) below the gridiron, and with sprinklers positioned 4 to 6 in. (I0.2 to 15.2 cm) below the baff le plate.

8-3.2.1.10 S,)ecial Exiting. Each side of a legitimate stage shall be provided with at least one well marked ex i t providing not less than 32 in. (81 cm) clear width. Such exit shall open d i rec t ly to a street, exi t court or ex i t passageway leading to a street.

Fly galleri~s shall be provided with a means of egress s ta i r mot less than 30 in. (76 cm) in width. Each t i e r of 3ressing rooms shall be provided with two means o f egress meeting the requi rements o f the Code.

S ta i rways r~qu i red by t h i s subsect ion need not be enclosed.

8-3.2.1,11 Flame-Retardant Requirements. Combustible scenery of cloth, Film, vegetarian (dry), and similar effects shall meet the requirements of NFPA 701, Standard Methods of Fire Tests For Flame Resistant Textiles and Films. Foamed plastics (see A 6-5.1.3) may be used only by specific approval of the authority having jur isd ic t ion. Scenery and stage properties on thrust stages shall be either noncombustible or limited combustible materials.

8-3.2.1,12 Each legitimate or regular stage shall be equipped with a Class I I l standpipe located on each side of the stage, installed in accordance with 7-7.4.2.

8-3.2.2 Projection Booths.

8-3.2.2.1 Every assembly occupancy where an e lect r ic arc, Xenon, or other l ight source that generates hazardous gases, dust, or radiation is used shall have a projection room that complies with 8-3.2.2,2, From which the projection shall be made. Where cellulose ni t rate f i lm is used, the projection room shall comply with NFPA 40, Standard For the Storage and Handling of Cellulose Nitrate Motion Picture Film. (See also Chapter 3].)

8-3.2.2.2 Projection Rooms for Safety Film. Projection rooms For safety Film shall comply with 8-3.2.2.3 through 8-3.2.2.8.

8-3.2.2.3 Every projection room shall be of permanent construction consistent with the constructlon requirements For the type of building in which the projection room is located. Openings need not be protected. The room shall have a f loor area of not less than 80 sq Ft (7.4 sq m) For a single machine and at least 40 sq f t (3.7 sq m) for each additional machine. Each motion picture projector, Floodlight, spotlight, or similar piece of equipment shall have a clear working space of not less than 30 in. (76 cm) on each side and at i ts rear, but only one such space sha l l be requ i red between ad jacent p r o j e c t o r s .

The p r o j e c t i o n room and the rooms appur tenant t h e r e t o sha l l have a c e i l i n g he igh t o f not less than 7 f t 6 in . (229 cm).

8-3.2.2.4 Each projection room shall have at least one out swinging, self-closing door not less than 2 f t 6 in. (76 cm) wlde by 6 Ft 8 in. (203 cm) high.

8-3.2.2.5 The aggregate of ports and openings For projection equipment shall not exceed 25 percent of the area of the wall between the projection room and the auditorium.

All openings shall be provided with glass or other approved material so as to completely close the opening.

8-3.2.2.6 Projection room venti lat ion shall be not less than the Following:

(a) Supply Air. Each projection room shall be provided with adequate a i r supply inlets so arranged to provide we l l distributed a i r throughout the room. Air in let ducts shall provide an amount of a i r equivalent to the amount of a i r being eKhausted by projection equipment. Air may be taken From the outside; from adjacent spaces wlthin the building provided the volume and i n f i l t r a t i o n rate is suf f ic ient ; or From the building a i r conditioning system, provided i t is so arranged as to provlde suf f ic ient a i r whether or not other systems are in operation.

(b) Exhaust Air. Projection booths may be exhausted through the lamp exhaust system. The lamp exhaust system shall be posi t ively interconnected with the lamp so that the lamp w i l l not operate unless there is the ai r f low required For the lamp. Exhaust a i r ducts shall terminate at the exter ior of the building in such a location that the exhaust a i r cannot be readily recirculated into any a i r supply system. The projection room vent i lat ion system may also serve appurtenant rooms such as the generator room and the rewind room.

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8-3.2.2.7 Each projection machine shall be provided with an exhaust duct that w i l l draw a i r from each lamp and exhaust i t d i rect ly to the outside of the building. The lamp exhaust may serve to exhaust a i r From the projection room to provide room ai r circulat ion. Such ducts shall be of r ig id materials, except for a Flexible connector approved for the purpose. The projection lamp and projection room exhaust systems may be combined, but shall not be interconnected with any other exhaust or return a i r system within the buildings.

(a) Electric Arc Projection Equipment. The exhaust capacity shall be 200 cfm (.09 cu m/s) for each lamp connected to the lamp exhaust system, or as recommended by the equipment manufacturer. Auxi l iary a i r may be introduced into the system through a screened opening to stabi l ize the arc.

(b) Xenon Projection Equipment. The lamp exhaust system shall exhaust not less than 300 cgm (. I~ cu m/s) per lamp, or not less than that exhaust volume required or recommended by the equipment manufacturer, whichever is the greater.

8-3.2.2.8 Miscellaneous Equipment and Storage.

(a) Each projection room shall be provided with rewind and Film storage Faci l i t ies.

(b) A maximum of four containers for Flammable liquids of not greater than 16 oz (.5 L) capacity and of a nonbreakable type may be permitted in each projection booth.

(c) Appurtenant electr ical equipment such as rheostats~ transformers, and generators may be located within the booth or in a separate room of equivalent construction.

8-3.2.3 Service Equipment, Hazardous Operations or Processes, and Storage Faci l i t ies.

8-3.2.3.1 Rooms containing high-pressure boilers, refr igerat ing machinery of other than domestic refr igerator type, large transformers, or other service equipment subject to possible explosion shall not be located d i rect ly under or adjacent to required exits. All such rooms shall be separated by a l-hour Fire barr ier From other parts of the building.

8-3.2.3.2 All openings between the balance of the building and rooms or enc losures f o r hazardous o p e r a t i o n s or processes s h a l l be p r o t e c t e d by s tandard s e l f - c l o s i n g or smoke-actuated f i r e doors and sha l l be p rov ided w i t h adequate vents to the ou te r a i r , in accordance w i t h Sec t ion 6-4 o f t h i s Code.

8-3.2.3.3 Rooms or spaces For the storage, processing, or use of the materials specified in this section shall be protected in accordance with the Following:

(a) Rooms or spaces used for the storage of combustible supplies in quantities deemed hazardous by the authority having jur isdict ion, hazardous materials in quantities deemed hazardous by recognized standards, or fuel shall be separated From the remainder of the building by construction having not less than a l-hour f i r e resistance rating with a l l openings protected by self-closing or smoke-actuated f i r e doors, or such rooms or spaces may be p ro tec ted by an au tomat ic e x t i n g u i s h i n g system as set f o r t h in Sec t ion 6-4.

(b) Rooms or spaces used f o r p rocess ing or use o£ combus t i b le s u p p l i e s in q u a n t i t i e s cons idered hazardous by the a u t h o r i t y hav ing j u r i s d i c t i o n , hazardous m a t e r i a l s , or f lammable or combus t ib le l i q u i d s i n q u a n t i t i e s deemed hazardous by recogn ized s tandards , s h a l l be separated From the remainder o f the b u i l d i n g by construction having not less than a l-hour Fire resistance rating with al l openings protected by self-closing or smoke-actuated Fire doors and shall also be protected by an automatic extinguishing system as set Forth in Section 6-4.

(c) Boiler and Furnace rooms, laundries, and maintenance shops, including woodworking and painting areas, shall be separated from the remainder of the building by construction having not less than a l-hour Fire resistance rating with a l l openings protected by self=closing or smoke actuated Fire doors,

Exception to (c): Rooms enclosing air-handling equipment.

(d)* When automatic extinguishing Systems are used to meet the requirements of this section, the rooms or spaces shall be separated From the remainder of the building by construction which rest r ic ts the passage of smoke.

(e) When automatic extinguishing is used to meet the requirements of this section, the protection may be in accordance with 7-7.1.2.

8-3.2.4 Special Provisions For Food Service Establishments.

8 3.2.4.1 All devices In connection with the preparation of Food shall be so installed and operated as to avoid hazard to the safety of occupants.

8-3.2.~.2 All devices in connection with the preparation of Food shall be o£ an approved type and s h a l l be i n s t a l l e d in an approved manner.

8-3.2.4.3 Food preparation f a c l l i t i e s shall be protected in accordance with 7-2.3 and are not required to have openings protected between food preparation areas and dining areas.

8-3.3 Inter ior Finish.

8 3.3.1 The ~nterior Finish requirements of this section shall be in accordance with Section G-5.

8 3.3.2 In ter ior Finish in a l l corridors and lobbies shall be Class A or B and, in enclosed stairways, Class A.

8-3.3.3 In ter ior Finish in general assembly areas of Class A and B assembly occupancies shall be Class A or B. In Class C assembly occupancies i t shall be Class A, B, or C.

Exception: In any assembly occupancy, exposed portions of structural members complying with the requirements For Type IV (2HH) construction may be permitted.

8 - 3 . 3 . 4 Screens on which p i c t u r e s are p r o j e c t e d s h a l l comply with requirements of Class A or Class B in te r io r Finish.

8 3.4 Detection, Alarm and Communication Systems.

8 3.4.1 Genera l . A l l Class A and a l l Class B assembly occupancies, and a l l t h e a t e r s w i t h more than one audience viewing room, shall be provided with an approved Fire alarm system in accordance with this section.

Exception: Assembly occupancies that are a part of a mixed occupancy (see I-4.7) may be served by a common Fire alarm system provided the individual requirements of each occupancy are met.

8-3,4.2 In i t ia t ion . I n i t i a t i on of the required Fire alarm system shall be by manual means in accordance with 7-6.2.1(a) which shall be provided with an emergency power source. The in i t i a t i ng device shall be capable of transmitting an alarm to a receiving station, located within the building, that is constantly attended when the assembly occupancy is occupied.

Exception No. I: I n i t i a t i on may be by means of an approved automatic f i r e detection system, in accordance with 7-6.2.l(b), providing Fire detection throughout the building.

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Exception No. 2" In i t i a t i on may be by means of an approved automatic sprinkler system, in accordance with 7-6.2.1(c), providing f i r e detection and protection throughout the building.

8-3,4.3 Noti f icat ion.

8-3.4.3.1 The required f i r e alarm system shall sound an audible alarm in a constantly attended receiving station within the building For purposes of i n i t i a t i ng emergency aetio,l.

8-3.4.3.2 Occupant not i f icat ion shall be by means of either voice or prerecorded message announcement in i t ia ted by the person in the constantly attended receiving station.

8-3.4.3.3 The announcement shall be made via an approved voice communication or public address system, provided with an emergency power source, that is audible above the ambient noise level of the assembly occupancy.

8-3.4.3.4 Where the authority having jur isdict ion determines that i t is impractical to have a constantly attended location in an assembly occupancy other than a theater, a Fire alarm system in accordance with Section 7-6 in i t ia ted by manual stations in accordance with 7-6.2.1(a) or other approved means of i n i t i a t i on , that automatically provides prerecorded evacuation instructions in accordance with 7-6.3,8, may be used.

8-3.5 Extinguishment ReQuirements. (See 8-1.6, 8-2.6, and 8-3.2.)

8-3.5.1 Build'ngs containing Class A or Class B assembly occupancies shall be protected by an approved supervised automatic sprinkler system installed in accordance with Section 7-7 as follows:

(a) Throughout the story containing the assembly occupancy, and

(b) Throughout any story below the story containing the assembly occupancy and

(c) In the case of an assembly occupancy located below the leve] of exi t discharge, throughout any story intervening between that story and the level of ex i t discharge inclJd~ng the level of exi t discharge.

Exception No. l : Assembly occupancies used primarily for worship with fixed seating.

Exception No. 2*: Assembly occupancies consisting of a single multipurpose room less than 12,000 sq f t (I,100 sq m) and not used For exhibition or display.

Exception No, 3: Gymnasiums, skating rinks, swimming Pools used exclusively for participant sports with no audience f a c i l i t i e s For more than 300.

8-3.6 Corridcrs.

8-3.6.1 In ter ior corridors and lobbies shall be constructed Jr, accordance with 5-I.3,3.

Exception No. l : Corridor and lobby protection shall not be required where assembly rooms served by the corridor or lobby have at least 50 percent of their ex i t capacity discharging d i rect ly to the outside independent of corridors and lobbies.

Exception No. 2: Corridor and lobby protection is not required in buildings protected throughout by an approved super-vised automatic sprinkl'er system instal led in accordance with Section 7-7,

Exception No. 3: Lobbies serving only one assembly area that meet the requirements for intervening rooms (see 5-5.1.6) need not have a f i r e resistance rating.

SECTION 8-4 SPECIAL PROVISIONS

8-4.1 Windowless or Underground Buildings.

8-4.1.1 Windowless or underground buildings shall comply with this chapter and Section 30-7.

8-4.1.2 Underground buildings or portions of buildings having a Floor level more than 30 f t (9.1 m) below the level of exit discharge shall comply with the requirements contained in 8-4.1.3 through 8-4.1.6,

Exception No. 1: Areas within buildings used only For service to the building such as boiler/heater rooms, cable vaults, dead storage and the l ike.

Exception NO, 2: Auditoriums without intervening occupiable levels complying with the requirements of Chapter 8.

8-4.1.3 Each level more than 30 f t (9.1 m) below the level of exi t discharge shall be divided into not less than two smoke compartments by a smoke barrier complying with Section 6-3 and having a l-hour Fire resistance rating.

(a) Each smoke compartment shall have access to at least one exit without passing through the other required compartment. Any doors connecting required compartments shall be t igh t -F i t t ing , l-hour minimum f i r e doors designed and installed to minimize smoke leakage and to close and latch automatically upon detection of smoke.

(b) Each smoke compartment shall be provided with a mechanical means of moving people ver t i ca l l y , such as an elevator or escalator.

(c) Each smoke compartment shall have an independent a i r supply and exhaust system capable of smoke control or smoke exhaust Functions and providing a minimum smoke exhaust rate of six a i r changes per hour.

(d) Each smoke compartment shall be provided with an automatic smoke detection system throughout. The system shall be designed such that the activation of any two detectors shall cause the smoke control system to operate and the building voice alarm to sound,

8-4.1.4 Any required smoke control or exhaust system shall be provided with a standby power system complying with Art icle 701 of NFPA 70, National Electrical Code.

8-4.1.5 The building shall be provided with an approved supervised voice alarm system in accordance with Section 7-6. The voice alarm system shall comply with 7-6.3.8. A prerecorded evacuation message shall be provided.

8-4.2 High Rise Buildings. High rise assembly occupancy buildings, and high rise mixed occupancy buildings that house assembly occupancies in the high rise portions of the building, shall comply with Section 30-8.

8-4.3 Outdoor Assembly.

8-4.3.1 All assembly seating considered "smoke-protected assembly seating" as defined by NFPA 102, outdoor assembly occupancies, ten ts , membrane s t ruc tu res , bleachers, grandstands, and stadiums, sha l l comply wi th the requirements of NFPA 102, Standard For Assembly Seating, Tents and Membrane Structures.

Exception: Smoke-protected assembly seating complying with 8-2.3.2 need not comply with 3-3.2 or NFPA I02, Standard For Assembly Seating, Tents and Membrane Structures.

8-4.4 Special Provisions For Exhibition Halls.

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2. Devi least 4 f t the public.

8-4.4.1 No display or exhibit shall be so installed or operated as to interfere in any way with access to any required ex i t or with the v i s i b i l i t y of any required ex i t or any required ex i t sign, nor shall any display block access to f i r e Fighting equipment.

8-4.4.2 A storage room having an enclosure with a smoke barrier having a f i r e resistance rating of l hour and protected by an automatic Fire extinguishing system shall be provided for combustible materials not on display.

8-4.4.3 Exhibits. Exhibits shall comply with the following:

(a) The travel distance within the exhibit booth or exhibit enclosure to an ex i t access aisle shall not be greater than SO f t (15 m).

(b) Exhibit booths shall be constructed of noncombustible or limited combustible materials, pressure-treated Fire retardant wood meeting the requirements of NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials, or of flame-retardant materials complying with NFPA 701, Standard Methods of F~re Tests For Flame-Resistant Textiles and Films, both small and large scale tests. Text i le wall coverings, such as carpeting having a napped, tufted, looped, or similar surface used as wall or cei l ing Finish, shall comply with 6-5.2.3(a). Plastic shall be limited to Class A or Class B in ter ior wall and cei l ing Finish. Foamed plastics (see A-6-5.2.4) are prohibited.

(c) Curtains, drapes and decorations shall comply with 3 1 - I . ~ .

(d) ~ Acoustical and decorative material including, but not limited to, cotton, hay, paper, straw, moss, sp l i t bamboo, and wood chips shall be flame-retardant treated to the satisFication of the authority having jur isdict ion. Materials that cannot be treated for flame retardancy shall not be used.

(e) Exhibit booths that are mult i level , consist of multiple rooms with ceil ings, or are over 225 sq f t (20.9 sq m) with ceil ings, shall be protected by automatic sprinklers in buildings so protected.

Exception: Vehicles, boats, and similar exhibited products having over lO0 sq f t (93 sq m) of roofed area shall be provided with smoke detectors acceptable to the authority having jur isd ic t ion.

(F) Open flame devices within exhibit booths shall comply with 31-2.3.

(g) Cooking and food warming devices in exhibit booths shall comply with 31-2.4 and the following:

I. Gas Fired devices shall be installed in accordance with 7-1.1.

ces shall be isolated from the public by at (122 cm) or a barr ier between the device and

3. Devi m) of cooki

ces shall be limited to 288 sq in. (.19 sq ng surface area.

4. Devices shall be placed on noncombustible surface materials.

5. Devices used for cooking shall be separated from each other by a minimum distance of 2 f t (61 cm).

6. Devices shall be kept a minimum of 2 f t (61 cm) From any combustible materials.

7. Single well cooking equipment using combustible o i ls or solids shall have l ids available for immediate use. Multi-vat cooking equipment using combustible o i l s or solids shall comply with 7-2.3.

8, A 20 BC f i r e extinguisher shall be provided within the booth For each device or an approved automatic extinguishing system shall be provided.

(h) Combustible materials within exhibit booths shall be limited to a one day supply. Storage of combustible materials behind the booth is prohibited (see 8-4.4.2 and 31-2.6.2).

( i ) Plans, in a form acceptable to the authority having jur isdict ion, shall be submitted to the authority having jur isdict ion For approval pr ior to the move in of any exhibit or trade show. The plan shall show a l l details of the proposed exhibit or show. No exhibit or trade show shall occupy any exhibit hall without approved plans.

8-4.4.4 Vehicles. Vehicles within an exhibit hall shall comply with the following:

(a) All fuel tank openings shall be locked and sealed in an approved manner to prevent the escape of vapors. Fuel tanks shall be not more than 3/4 nor less than I/8 f u l l .

(b) At least one battery cable shall be removed From each set of batteries.

(c) Fueling or defueling of vehicles shall be prohlbited.

(d) Vehicles shall not be moved during show hours.

8-4.4.5 Compressed flammable gases, flammable or combustible liquids, hazardous chemicals or materials, Class I I or greater lasers, blasting agents, and explosives shall be prohibited within exhibit halls.

Exception: The authority havlng jur isd ic t ion may permit the limited use of any of the above items under special circumstances.

8-4.5 ~ Special Provisions For the Handicapped. When assembly occupancies are required to be made accessible to the handicapped, the assembly area shall have accommodations for not less than two such persons.

8-4.6 Special Provisions For Special Amusement Buildings.

8-4.6.1 Special amusement buildings shall meet the requirements for assembly occupancies in addition to the requirements of this subsection. Special amusement buildings with an occupant load not greater than 300 persons, shall be considered Class C assembly occupancies.

8-4.6.2* Every special amusement building shall be protected throughout by an approved automatic sprinkler system installed and maintained in accordance with Section 7-7. Where the special amusement building is moveable or portable, sprinkler water Supply may be by an approved temporary means.

8-4.6.3 Where the nature of the special amusement building is such that i t operates in reduced l ighting levels, the building shall be protected throughout by an approved automatic smoke detection system in accordance with Section 7-6. Actuation of any smoke detection system device shall sound an alarm at a constantly attended location on the premises. Actuation of the automatic sprinkler system or actuation of a smoke detection system having an approved ver i f i ca t ion or cross zoning operation capabi l i ty shall:

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(a) Cause "~llumination in the means of egress to increase to that required by Section 5-8, and

(b) stop any confl ict ing or confusing sounds and visuals.

8-4.6.4 Exit Marking.

8-4.6.4.1 Exit marking shall be in accordance with Section 5-10.

8-4.6.4.2 Exit marking in mobile special amusement buildings shall be of the luminescent, self-luminous, or electro-luminescent type.

8-4.6.4.3 Low level exi t signs shall be provided in accordance with 5-I0.I.3.

8-4.6.4.4" In special amusement buildings where mazes, mirrors or other designs are used to confound the egress path, approved directional ex i t marking that w i l l become apparent in an emergency shall be provided.

8-4.6.5 Inter ior f inish. In ter ior f in ish shall be Class A throughout in accordance with Section 6-5.

8-4.7 Operating Features. (See Chapter 31.

SECTION 8-5 BUILDING SERVICES

8-5.1 U t i l i t i e s shall comply with the provisions of Section 7-I.

8-5.2 Heating, venti lating, and a i r conditioning equipment shall comply with the provisions of Section 7-2.

8-5.3 Elevators, dumbwaiters, and vert ical conveyors shall comply with the provisions of Section 7-4.

8-5.4 Rubbish chutes, incinerators, and laundry chutes shall comply with the provisions of Section 7-5.

CHAPTER 9 EXISTING ASSEMBLY OCCUPANCIES (See also Chapter 31.)

SECTION 9-I GENERAL REQUIREMENTS

9-1.1 Application.

9 - i . I . I The requirements of this chapter apply to existing assembly occupancies. (See 9-1.3 for de f in i t ion . )

Exception: An existing building housing an assembly occupancy established prior to the ef fect ive date of this Code may have i ts use continued i f i t conforms to or is made to conform to the provisions of this Code to the extent that, in the opinion of the authority having jur isd ic t ion, reasonable l i f e safety against the hazards of f i r e , explosions, and panic is provided and maintained.

9-1.1.2 Additions to existing buildings shall conform to the requirements for new construction. Existing portions of the structure need not be modified provided that the new construction has not diminished the f i r e safety features of the f a c i l i t y .

Exception: Existing portions must be upgraded i f the addition results in a change of assembly c lassi f icat ion.

9 - I . I .3 An assembly occupancy that has i ts occupant load increased resulting in a change of assembly c lassi f icat ion shall meet the requirements for new assembly occupancies.

9-1.2 Mixed Occupancies. (See also 1-4.7.)

9-1.2.1" Any assembly occupancy and i ts access to exits in buildings of other occupancy, such as ballrooms in hotels, restaurants in stores, rooftop assembly occupancies, or assembly rooms in schools, shall be so located, separated, or protected as to avoid any undue danger to the occupants of the assembly occupancy from a f i r e originating in the other occupancy or smoke therefrom.

9 - 1 . 2 . 2 Occupancy o f any room or space For assembly purposes by fewer than 50 persons in a b u i l d i n g o f other occupancy and incidental to such other occupancy shall be classed as part of the other occupancy and subject to the provisions applicable thereto.

9-I.2.3 Assembly occupancies in buildings of other occupancy may use exits common to the assembly occupancy and the other occupancy provided that the assembly area and the other occupancy considered separately each have exits suf f ic ient to meet the requirements of this Code.

9-1.2.4 Exits shall be suf f ic ient for simultaneous occupancy o f both the assembly occupancy and o t h e r pa r t s o f the b u i l d i n g .

Exception': Where the authority having jur isd ic t ion determines that the conditions are such that simultaneous occupancy w i l l not occur.

9-1.3" Special Definitions,

Assembly Occupancies. Include, but are not l imited to, a l l buildings or portions of buildings used for gathering together 50 or more persons for such purpose as deliberation, worship, entertainment, dining, amusement, or awaiting transportation.

Cyclorama. The name generally applied to a neutral background that, with suitable l~ghting, can suggest the i n f i n i t e space of the sky. I t may be curved and may be painted to depict any required background.

Flow Time. Flow time is the time during which there is crowd flow past a point in the means of egress system and i t is a component of total evacuation time.

Drop. A large piece of scenic canvas that hangs ver t i ca l l y , usually across the stage area.

Fly. The space over the stage of a theater where scenery and equipment can be hung out of view. AIso called lo f t s and rigging lo f ts .

Fly Gallery. A narrow raised platform at the side of a legitimate stage from which the lines for f ly ing scenery are manipulated.

Gridiron. The arrangement of beams over a legitimate stage supporting the machinery for f ly ing scenery and banging battens From which l ighting is hung.

Leg Drop. A long narrow st r ip of fabric used for masking. Where used on either or both sides of the acting area, to provide entry to the stage by the actors, but also to mask. They may also be called "wings."

Life Safety Evaluation. A l i f e safety evaluation is a written review dealing with the adequacy of l i f e safety features re lat ive to f i r e , storm, collapse, crowd behavior, and other related safety considerations.

Pinrai l . A beam at one side of a legitimate stage through which wooden or metal pins are driven and to which lines from the f l i es are fastened.

379

Platform. " That raised area wi th in a bui ld ing used fo r the presentation of music, plays or other entertainment; the head tables fo r special guests; the raised area fo r lecturers and speakers; boxing and wrest l ing r ings; theater - in - the round; and s im i la r purposes wherein there are no overhead drops, scenery or stage e f fec ts other than l i gh t i ng and a screening valance.

Platform, Temporary. A platform erected wi th in an area fo r not more than 30 days.

Platform, Permanent. A platform erected wi th in an area fo r more than 30 days.

Proscenium Wall. The wall that separates the stage from the auditorium or house.

Smoke-Protected Assembly Seating. Seating served by means of egress that is not subject to blockage by smoke accumulation wi th in or under a structure.

Stage. An area wi th in a bui ld ing used For the purpose of entertainment and u t i l i z i n g drops or scenery or other stage e f fec ts and shall be c lass i f ied as one of the fo l lowing:

( a ) Stage, Legitimate. A stage wherein scenery is ret ractable mechanically e i ther hor izon ta l l y , v e r t i c a l l y or suspended overhead.

(b) Stage, Regular. A stage wherein scenery is not ret ractable.

(C) Stage, Thrust. A platform extending beyond the proscenium arch and into the audience.

Stage Propert ies. Furniture, carpet and s im i la r materials general ly having an overal l height of less than 5 f t and used to provide an appearance simulat ing a room or area.

Stage Scenery. Decorative materials such as f l a t s , cycloramas, painted or photographic backings, and s imi la r mater ials to "dress" the stage.

9-1.4 C lass i f i ca t ion of Occupancy. (See 4-1.2. )

9 -1 .4 .1 S u b c l a s s i f i c a t i o n o f Assembly Occupanc}es. Each assembly occupancy s h a l l be s u b c l a s s i f i e d accord ing to i t s occupant load, as f o l l o w s : Class A, occupant load greater than I000 persons; Class B, occupant load greater than 300 but not greater than IO00 persons; Class C, occupant load o£ 50 or more but not greater than 300 persons.

9 -1 .5 C l a s s i f i c a t i o n o f Hazard o f Contents . Contents o f assembly occupancies s h a l l be c l a s s i f i e d in accordance w i t h the p r o v i s i o n s o f Sec t ion 4-2.

9-1.6 Minimum Construction Requirements (see 6-2.1) . The locat ion of an assembly occupancy shall be l im i ted as Follows:

Type of Below Construction LED

I ( 4 4 3 ) ) A t B t C t I (332) }. Any Number

II (222) J of Levels

11 ( l l l ) A~ B'~CI" One Level

Below LED

I I1 (211) | A t B f C t IV (2HH) / One Level

V (I I 1 ) Below LED

II (000) B~?Ct One Level

Below LED

Il l (200) / BtCi" V (000) / One Level

Below LED

Number of Levels Above LED

4 & LED i 2 3 Above

ABC ABC ABC ABC A t B C

ABC ABC A t B C B~Ct N.P.

ABC ABC A t B t C B t C t N.P.

A'~BC C t N.P. N.P. N.P.

A'~BC Ct N.P. N.P. N.P.

tPermitted if the level of the assembly ~cupancy and any story inte~ening ~tween that level and the level of exit discharge arep~te~ed throughout by an approved automatic sprinkler system. If the~ are any o~nings ~tween the level of exit discharge and the exits serving the place of assembly, the level of exit discharge shall also be protected throughout by an approv~ automaue sprinkler system (see Section 7-7 }. N.P. - - Not Permitted LED - - Level of Exit Discharge

9 -1 .7 Occupant Load.

9 - 1 . 7 . 1 " The occupant load p e r m i t t e d in any assembly b u i l d i n g , s t r u c t u r e , or p o r t i o n t h e r e o f , s h a l l be determined on the bas1s o f the Fo l l ow ing occupancy load Fac to rs :

( a ) * An assembly area o f concen t ra ted use w i t h o u t F ixed seats such as an a u d i t o r i u m , p lace o f worsh ip , dance Floor, d~scotheque or lodge hal l - one person per 7 net sq f t (.65 sq m).

(b) An assembly area of less concentrated use such as a conference room, dining room, dr inking establishment, exh ib i t room, gymnasium, or lounge - one person per 15 net sq f t ( I . 4 sq m).

(c) Bleachers, pews and s im i la r bench-type seating one person fo r 18 l i near in. (45.7 l inear cm).

(d) Fixed Seating. The occupant load of an area having Fixed seats shal l be determined by the number of f i xed seats ins ta l led . Required a is le space servlng the Fixed seats shall not be used to increase the occupant load.

(e) Kitchens. One person per tO0 gross sq Ft (9.3 sq m).

( f ) L ibrar ies , In stack areas one person per IOO gross sq f t (9.3 sq m); in reading rooms - one person per 50 net sq Ft (4.6 sq m).

Exception: The author i ty having j u r i s d l c t i o n may permit occupancy by number of persons not to exceed that For which the ex is t ing means of egress are adequate, provided that measures are established to prevent occupancy by any greater number of persons than permitted by room area or by Fixed seating.

380

9-1.7.2" The occupant load permitted in a building or portion thereof may be increased above that specified in 9-1.7.1 i f the necesssary aisles and exits are provided. To increase the occupant load, a diagram indicating placement of equipment, aisles, exits, and seating shall be provided to and approved by the authority having j u r i sd ic t ion prior to any increase in occupant load. In areas not greater than 10,000 sq Ft (930 sq m) the occupant load shall not exceed one person in 5 sC f t (.46 sq m); in areas greater than 10,000 sq f t (930 sq m) the occupant load shall not exceed one person in 7 sq f t (.65 sq m).

9-1.7.3 Waiting Spaces. In theaters and other assembly occupancies where persons are admitted to the building at times when seats are not available to them, or when the permitted occupant load has been reached based on 9-I.7.1 or 9-1.7.2, and persons are allowed to wait in a lobhy or similar space unti l seats or space are available, such use of a lobby or similar space shall not encroach upon the required clear width of exits. Such waiting shall be restricted to areas other than the required means Of egress. Exits shall be provided for ~uc:h waiting spaces on the basis of one person for each 3 sq f t (0.28 sq m) of waiting space area. Such exits shall be in addition to the exits specified for the main auditorium area and shall conform in c o n s t r u c t i o n and arrangement to the general r u l es f o r e x i t s g iven in t h i s chapter .

SECTION 9-2 MEANS OF EGRESS REQUIREMENTS

9-2.1 General. All means OF egress shall be in accordance with Chapter 5 and this chapter.

9-2.2 Means of Egress Components.

9-2.2.1 Components of means of egress shall be limited to the types described in 9-2.2.2 through 9-2.2.8.

9-2.2.2 Doors.

9-2.2.2.1 Doors shall comply with 5-2.1.

9-2.2.2.2 Class C assembly occupancies in covered malls (see 25-¢.3.1 Exception) may have horizontal or vert ical security g r i l l es or doors complying with 5-2.1.4.1 Exception No. 3 on the main entrance/exits.

9-2.2.2.3 Panic Hardware or Fire Exit Hardware. Any door in a recluired means of egress from an area having an occupant load of I00 or more persons may be provided with a latch or lock only i f i t is panic hardware or Fire ex i t hardware complying with 5-2.1.7.

Exception No I: In assembly occupancies having an occupant load not greater than 500, when the main exi t consists of a single door or single pair of doors, locking devices complying with 5-2.1.5.1 Exception No. 2 may be used on the main exi t . Any latching device on this door(s) shall be released by panic hardware.

Exception No. 2: Special locking arrangements as permitted in 9-2.2.2.4.

9-2.2.2,4 Special locking arrangements complying with 5-2.1.6 are oer'mitted on doors other than main entrance/exit doors.

9-2.2.2.5 Revolving doors complying with the requirements of 5-2.1.10 for new construction are permitted.

9-2.2.2.6 Turnstiles. No turnst i les or other devices to res t r i c t the movement of persons shall be installed in any assembly occupancy in such a manner as to interfere in any way with required means of egress f a c i l i t i e s .

40. of Seats

9-2,2.3 Stairs. Stairs shall comply with 5-2.2.

9-2.2.4 Smokeproof Enclosures. Smokeproof enclosures shall comply with 5-2.3.

9-2.2.5 Horizontal Exits. Horizontal exits shall comply with 5-2,4.

9-2.2.6 Ramps. Ramps shall comply with 5-2.5.

9-2.2.7 Exit Passageways. Exit passageways shall comply with 5-2.6.

9-2.2.8 Escalators and Moving Walks. Escalators and moving walks complying with 5-2.7 are permitted.

9 2.2.9 Fire Escape Stairs. Fire escape stairs complying with 5-2.8 are permitted.

9-2.3 Capacity of Means of Egress.

9-2.3.1 The capacity of means of egress shall be in accordance with Section 5-3 or in the case of means of egress serving theatre-type seating or similar seating arranged in rows, in accordance with 9-2.3,2.

9-2.3.2* Minimum clear widths of aisles and other means OF egress shall be in accordance with Table 9-2.3.2(a) or, for buildings providing Smoke-Protected Assembly Seating and for which an Approved Life Safety Evaluation is conducted, Table 9-2,3.2(b). For Table 9-2.3.2(b) the number of seats specified must be within a single assembly space and interpolation shall be permitted between the specific values shown. For both tables the minimum clear widths shown shall be modified in accordance with a l l of the following:

(a) IF r isers exceed 7 in. in height, multiply the s ta i r width in the tables by factor A, where A = 1 + ( r i ser height -7.0 in . ) .

5

(b) Stairs not having a handrail within a 30-in. horizontal distance shall be 25 percent wider than otherwise calculated, i .e . , multiply by B = 1.25.

(c) Ramps steeper than I in lO slope, used in ascent, shall have their width increased by 10 percent, i . e . , multiply by Factor C = l. lO.

9-2.3.3 Main Entrance/Exit. Every assembly occupancy shall be provided with a main entrance/exit. The main entrance/exit shall be of suf f ic ient width to accommodate one half of the total occupant load but shall be not less than the total required width of a l l aisles, exit passageways, and stairways leading thereto and shall be at the level of ex i t discharge or shall connect to a stairway or ramp leading to a street.

Table 9-2.3.2(a) (For Use Without Smoke-Protected Assembly Seating)

Inch of Clear Width Per Seat Served,

Passageways Nominal Ramps and

Flow Time (sec.) Stair~ Doorways

Unlimited 200 0,300 AB 0.220C

Table 9-2.3.2(b) (For Use With Smoke-Protected Assembly Seating)


Passageways Nominal Ramps and

40. o f ~ Flow Time ~sec.~ Stairs Doorway~ 2,000 200 0.300 AB 0.220C 5,000 260 0.200 AB 0.150 C

lO,O00 360 0.130 AB 0.I00 C 15,000 460 0.096 AB 0.070 C 20,000 560 0.076 AB 0.056 C 25,000 or more 660 0.060 AB 0.044 C

381

Exception No. l : A bowling establishment shall have a main entrance/exit of su f f i c ien t capacity to accommodate 50 percent of the total occupant load without regard to the number of aisles that i t serves.

Exception No. 2: In assembly occupancies where there is no well defined main entrance/exit, such as stadiums, sports arenas, and passenger stations, exits may be distr ibuted around the perimeter of the building provided the total ex i t width provides 116 2/3 percent of the width needed to accommodate the permitted occupant load.

9-2.3.4 Other Exits. Each level of an assembly occupancy shall have access to the main entrance/exit and shall be provided with additional exits of su f f i c ien t width to accommodate two-thirds of the total occupant load served by that level. Such exits shall discharge in accordance with 9-2.7. Such exits shall be located as Far apart as practicable and as far From the main entrance/exit as practicable. Such exits shall be accessible From a cross aisle or a side aisle (see 9-2.3.2).

Exception No. I: Where only two exi ts are required, each ex i t shall be of su f f i c ien t width to accommodate not less than half the total occupant load.

Exception No. 2: In assembly occupancies where there is no well defined main entrance/exit, such as stadiums, sports arenas, and passenger stations, exits may be dlstr ibuted around the perimeter of the building provided the total ex i t width provides I16 2/3 percent of the width needed to accommodate the permitted occupant load.

9-2.4 Number of Exits.

9 2.4.1 Every Class A assembly occupancy shall have at least Four separate means of egress as remote From each o t h e r as p r a c t i c a b l e .

9 - 2 . 4 . 2 Every C lass B assemb ly occupancy s h a l l have a t least two separate means of egress as remote From each other as practicable and, if of a capacity of over GO0, at least three separate means of egress, each not less than two exit units wide.

9-2.4.3 Every Class C assembly occupancy shall have at least two means of egress, consisting of separate exits or doors leading to a corridor or other spaces giving access to two separate and independent exits in d i f fe ren t directions.

9-2.4.4 Balconies or mezzanines having an occupant load not greater than 50 may be served by a single means of egress and such means of egress may lead to the f loo r below.

9-2.4.5 Balconies or mezzanines having an occupant load greater than SO but not greater than lO0 shall have at least two remote means of egress but both such means of egress may lead to the floor below.

9 - 2 . 4 . 6 B a l c o n i e s o r mezzan ines h a v i n g an occupan t l o a d g r e a t e r than I00 s h a l l have means o f eg ress p r o v i d e d as f o r a f l o o r .

9-2.5 Arrangement of Means of Egress.

9-2.5.1 Exits shall be remote From each other and shall be arranged to minimize the poss ib i l i t y that they may be blocked by any emergency.

Exception NO. l : A common path of travel may be permitted For the f i r s t 20 f t (6.1 m) From any point.

Exception NO. 2: As provided in 9-2.4.4.

9-2.5.2 Means of egress shall not be permitted through kitchens, storerooms, restrooms, closets, or hazardous areas as described in 9-3.2.

9-2.5.3 (Reserved)

9-2.5.4 Seating.

9-2.5,4.1 The Spacing of rows of chairs shall provide a space of not less than 12 in. (30.5 cm) from the back of one chair to the front of the most forward projection of the chair immediately behind i t . Horizontal measurements shall be made between vert ical planes. Where al l chairs in a row have automatic or se l f - r i s ing seats that comply with ASTM F851 Test Method for Self Rising Seat Mechanisms, the measurement may be made with the seats in the up posltion. Where any chair in the row does not have an automatic or se l f - r i s ing seat, the measurement shall be made with the seat in the down position.

9-2.5.4.2 ~ For rows of chairs served by aisles or doorways at both ends, there shall be no more than I00 seats per row and the minimum clear width between rows of 12 in. (30.5 cm) shall be increased by 0.3 in. (.76 cm) for every additional seat beyond 14 but need not exceed 22 in. (55.9 cm).

9-2.5.4.3 For rows of chairs Served by an aisle or doorway at one end only, the minimum clear width between rows of 12 in. (30.5 cm) shall be increased by O.G in. (1.52 cm) For every additional seat beyond 7, but need not exceed 22 in. (55.9 cm).

9-2.5.4.4 For rows of chairs served by an a~sle or doorway at one end only, the path of travel shall not exceed 30 Ft From any seat to a point where a person has a choice of two paths of travel to two exi ts.

9-2.5.4.5 Chairs without dividing arms shall have thei r capacity determined by allowing IB in. (45.7 cm) per person.

9-2,5.4.6 Where bleacher or grandstand seating without backs is used indoors, rows of seats shall be spaced not less than 22 in. (55.9 cm) back to back.

Exception: Folding or telescopic seating shall comply with NFPA I02, Standard For Assembly Seating, Tents, and Membrane Structures, with a l im i t of dead ends in vert ical aisles of 16 rows.

9-2.5.4.7 ~ Fixed or loose chairs, tables and s imi lar furnishings or equipment shall be SO arranged and maintained that a path of travel to an aisle or ex i t is provided. The path of travel shall not exceed To f t . (3 m) from any point to an aisle or ex i t .

9-2.5.4.8* Rectangular banquet type tables used For drinking or dining or purposes having s imi lar seating configurations with the path of travel to an aisle exceeding lO f t (3 m), shall be spaced not less than 54 in. (137 cm) apart where seating occurs back to back nor less than 36 in. (9] cm) where seating is on one side only. The path of travel to an aisle or ex i t shall not exceed 20 Ft. (6.1 m).

9-2.5.5" Tablet-Arm Chair Seating.

9-2.5.5.1 Tablet arm chairs shall not be permitted unless Full compliance of row space requirements is provided when the tablet arm is in the usable position. Tablet-arm chairs that do not have a stored position for the tablet arm shall not be permitted unless the clearance required by 9-2.5.4 between rows of chairs is provided and maintained.

9-2.5.5.2 Where tablet-arm chairs are used, the clear width of rows of seats should be measured with a tablet arm in the up or use Position.

382

Exception: Tablet arms may be measured in stored position where the tablet arm automatically returns to the stored position when raised manually in one motion to a vert ical position and Falls to the stored position by force of gravity.

9-2.5.6 Aisles.

9-2.5.6.1 Aisle width shall provide suf f ic ient egress capacity For the number OF persons accommodated by the catchment areas served by the aisle. The catchment area served by an aisle is that portion of the total space that is naturally served by that section of the aisle. The establishment of catchment areas shall be based on a balanced use of a l l means of egress with the number of persnns in proportion to egress capacity.

9-2.5.6.2 When aisles converge to form a single path of egress travel, the required egress capacity of that path shall be not less than the combined required capacity of the converging aisles.

9-2.5.6.3 Aisles shall terminate at a cross aisle, foyer, door, or vomitory giving access to an exi t .

9-2.5.6.4 Dead-end aisles shall not exceed 20 f t (G.l m) in length.

Exception: A longer dead-end aisle is permitted where seats served by the dead-end aisle are not more than 24 seats From another aisle measured along a row of seats having a minimum clear width of ]2 in. (30.5 cm) plus 0.6 in. ( l .S cm) for each additional seat above 7 in the row.

9-2.5.6.5 In aisles where egress is possible in more than one direction, the aisles shall be uniform in required widths.

9-2.5.G.6 The width of aisles shall be sized in accordance wit.h 9-2.3.l.

9-2.5.6.7* IrJ theater and similar type seating Fac i l i t ies , the minimum clear width of aisles shall be as determined by 9-2.3.2 but not less than:

(a) ¢2 in. (I07 cm) For stairs having seating on each side.

Exception: 30 in. (76 cm) for catchment areas having not greater than 60 seats.

(b) 36 in. (¶)l cm) For stairs having seating on only one side.

Exception: 30 "in. (76 cm) For catchment areas having not greater t~an GO seats.

(c) 20 in. (Sl cm) between a handrail or guardrail and seating when the aisle is subdivided by a handrail.

(d) 42 in. (I07 cm) For level or ramped aisles having seating on both sides.

Exception: 30 in. (76 cm) For a catchment area of not greater than 60 seats.

(e) 36 in. (91 cm) for level or ramped aisles having seating on or=ly one side.

Exception: 30 in. (76 cm) For catchment areas with not greater than 60 seats.

( f ) 23 in. (58 cm) between a handrail and seating when aisle does not serve more than Five rows on one side.

9-2.5.6.8* In table and chair type seating f a c i l i t i e s the minimum clear width of aisles shall be as determined by 9-2.3.1 but not less than 36 in. (91 cm). Where loose seating occurs bordering on the aisle, the minimum aisle width is required plus an additional 19 in. (48.3 cm) For chairs on one side or an additional 38 in. (97 cm) For chairs on both sides of the aisle.

9-2.5.6.9 Aisle Stairs and Ramps. Every aisle with a gradient l in 8 or less shall consist of a ramp. Every aisle with gradient exceeding I in 8 shall consist of a s ta i r having treads, r isers and handrails complying with the following requirements:

(a)" Tread depth shall be uniform in each aisle.

Exception to (a): In aisle stairs where a single intermediate tread is provided halfway between seating platforms, such intermediate treads may have a re la t i ve ly smaller but uniform depth, but not less than 13 in. (33 cm).

(b)* Treads shall be a minimum of II in. (27.9 cm).

(c) Riser heights shall be a minimum of 4 in. (I0.2 cm).

(d) Riser heights shall not exceed 8 in. (20.3 cm).

Exception No. l to (d): Where the gradient of an aisle exceeds 8 in. (20.3 cm) in rise and 11 in. (27.9 cm) of run (to maintain necessary sight lines in the adjoining seating area) the rise height may exceed 8 in. (20.3 cm) but shall not exceed II in. (27.9 cm).

Exception No. 2 to (d): Folding and telescopic seating in accordance with NFPA I02, Standard for Assembly Seating Tents and Membrane Structures.

(e)* Riser heights shall be uniform within a f l i gh t .

Exception to (e): Riser height may be nonuniform but only to the extent necessary due to changes in gradient within a seating area to maintain necessary sight l ines. Where nonuniFormities exceed 3/16 in. (0.5 cm) between adjacent r isers, the exact location of such nonuniformities shall be indicated by a d is t inct ive marking stripe on each tread at the nosing or leading edge adjacent to the nonuniform risers.

( f ) Ramped aisles having a gradient exceeding l in 15 and aisle stairs, shall be provided with handrails at one side or along the center l ine.

Where there is seating on both sides of the aisle, the handrails shall be discontinuous with gaps or breaks at intervals not exceeding f ive rows to f a c i l i t a t e access to seating, and to permit crossing From one side of the aisle to the other. These gaps or breaks shall have a clear width OF at least 22 in. (55.9 cm) and not greater than 3G in. (91 cm) measured horizontal ly, and the handrail shall have rounded terminations or bends. Where handrails are provided in the middle of aisle stairs, there shall be an additional intermediate ra i l located approximately 12 in. (30 cm) below the main handrail.

Exception No l to (F): Handrails are not required For ramped aisles having a gradient not greater than l in 8 and having seating on both sides.

Exception No. 2 to (F): Handrails are not required i f , at the side of the aisle, there is a guardrail that complies with the graspabil i ty requirements for handrails.

383

(g)~ A contrasting marking stripe shall be provided on each tread at the nosing or leading edge such that the location of such tread is readily apparent, par t icular ly when viewed in descent. Such stripes shall be at least 1 in. wide and shall not exceed 2 in. wide.

Exception to (g): The marking stripe may be omitted where tread surfaces and environmental conditions and a l l conditions of use are such that the location of each tread is readily apparent, par t icu lar ly when viewed in descent.

9-2.5.6.10 Where required by the authority having jur isd ic t ion, plans drawn to scale showing the arrangement of furnishings or equipment shall be submitted to the authority by the building owner, manager or authorized agent to substantiate conformance with the provisions of this section and shall constitute the only acceptable arrangement unti l revised or additional plans are submitted and approved.

Exception: Temporary deviations From the specifics of the approved plans shall be permitted provided the occupant load is not increased and the intent of this section is maintained.

9-2.6 Travel Distance to Exits. Exits shall be so arranged that the total length of travel From any point to reach an ex i t w i l l not exceed 150 f t (45 m) in any assembly occupancy.

Except ion: The t r a v e l d is tance may be increased to 200 f t (60 m) in assembly occupancies p ro tec ted throughout by an approved automat ic s p r i n k l e r system.

9-2 .7 Discharge From Exits.

9-2.7.1 Exit discharge shall comply with Section 5 7.

9-2.7.2 The level of exit discharge shall be measured at the point of principal entrance to the building.

9-2.7.3 Where the principal entrance to an assembly occupancy is via a terrace, either raised or depressed, such terrace may be considered to be the level of ex i t discharge for the purposes of 9-1.6 i f :

(a) The terrace is at least as long (measured paral lel to the building) as a total width of the exi t (s) i t serves, but not less than 5 Ft (153 cm) long, and

(b) The terrace is at least as wide (measured perpendicular to the building) as the ex i t (s) i t serves, but not less than 5 f t (153 cm) wide, and

(c) Required stairs leading from the terrace to grade are protected in accordance with 5-2.2.3.2 o r are a minimum of I0 f t (3 m) From the building.

9-2.8 Illumination of Means of Egress. Means of egress shall be illuminated in accordance with Section 5-8.

9-2.9 Emergency Lighting. Emergency l ighting shall be provided in accordance with Section 5 9.

Exception: Class C assembly occupancies, used exclusively for a place of worship, shall not be required to have emergency l ighting.

9-2.10 Marking of Means of Egress. Means of egress shall have signs in accordance with Section 5-I0.

9-2.11 Special Features.

9-2.11.1 Railings.

(a) The fasciae of boxes, balconies, and gal ler ies shall not rise less than 26 in. (66 cm) high above the adjacent f loor or shall have substantial rai l ings not less than 26 in. (66 cm) high above the adjacent f loor .

(b) The height of the ra i l above footrests on the adjacent Floor immediately in front of a row of seats shall be not less than 26 in. (66 cm). Railings at the ends of aisles shall be not less than 36 in. (91 cm) high for the Full width of the aisle and shall be not less than 42 in. (I07 cm) high for the width of the a i s l e where steps occur.

(c) Cross aisles shall be provided with rai l ings not less than 26 in. (66 cm) high above the adjacent Floor.

Exception No. l : Where the backs of seats on the front of the aisle project 24 in. (60 cm) or more above the adjacent f loor of the aisle.

Exception No. 2: Existing rai l ings 36 in. (91 cm) high at the ends of aisles where steps occur may continue to be used.

SECTION 9 3 PROTECTION

9-3.1 P r o t e c t i o n o f V e r t i c a l Openings. A l l i n t e r i o r stairways and other vert ical open~ngs shall be enclosed and protected as provided in Section 6-2.

Exception No. I: Unprotected openings connecting not more than three Floors may be permitted provided that they comply with 6-2.4.4.

Exception No. 2: Atriums in accordance with 6-2.4.5 are permitted.

Exception No. 3: Stairs may be open between balconies and main assembly f l o o r s in t h e a t e r s , churches, or aud i to r iums where the t r a v e l d is tance is w i t h i n the a l l o w a b l e l i m i t s (see 9 - 2 . 6 ) .

Exception NO. 4: Existing wood lath and plaster, existing I /2- in. (1.3-cm) gypsum wallboard, existing instal lat ions of I /4- in, (.6 cm) thick wired glass that are, or are rendered, inoperative and fixed in the closed positlon, or other existing materials having similar f i r e resistance capabil i t les shall be acceptaale. All such assemblies shall be in good repair and free of any condition that would diminish their original Fire-resistance characteristics.

9-3.2 Protection from Hazards.

9-3.2.1 Stages and Platforms. (See 9-1.3.)

9-3.2.1.1 Materials and Design. (Reserved)

9-3.2.1.2 Platform Construction (Reserved)

9 3,2.1.3 Stage Construction. (Reserved)

9 - 3 . 2 . 1 . 4 Accessory Rooms. (Reserved)

9-3.2.1.5 Vents. Legitimate stages shall be provided with one or more vents constructed of noncombustible material. Ventilators shall be located near the center and above the highest part of the stage. They shall be raised above the stage roof and shall have a total vent i lat ion area equal to at least 5 percent of the Floor area of the stage.

Regular stages exceeding 1,000 sq f t (93 sq m) in area shall be provided with vents as required for legitimate stages or shall be provided with a mechanical vent installed in an exter ior wall of the stage i t se l f . Such vent shall be automatic upon operation of the sprinkler system and shall also be capable of manual operation. The capacity of the exhaust vent shall be approximately equivalent to that which would be provided for a legitimate stage.

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Vents shall open by spring action or force of gravity suf f ic ient to overcome the effects of neglect, rust, d i r t , f rost , snow, or expansion by heat or warping of the Framework. Glass, i f used in vents, must be protected against Falling onto the stage. A wire screen, i f used under the glass, must be so placed that, i f clogged, i t cannot reduce the required vent area or interfere with the operating mechanism or obstruct the distr ibut ion of water From an automatic sprinkler. Vents shall be arranged to open automatically by the use of Fusible links. The fusible links and operating cable shall hold each door closed against the minimum 30 Ib (133 N) counterforce, which may be exerted by springs or counterweights. This minimum counterforce shall be exerted on each door through its entire arc of travel and for a minimum of 115 degrees. ~ manual control shall also be provided.

Springs, where employed to actuate doors, shall be capable of mairtaining f u l l required tension. Springs shall not be stressed more than 50 percent of their rated capacity and shall not be located d i rect ly in the a i r stream nor exposed to the outside.

A Fusible lirJk shall be placed in the cable control system on the underside of the vents at or above the roof l ine or as approved by the authority having jur isd ic t ion arid shall be so located as not to be affected by the operation of a Fire sprinkler system. Remote, manual or electr ical controls shall provide for both opening and closing of the vent doors For periodic testing and shall be located at a point on the stage designated by ,:he authority having jur isdict ion. Where remote control vents are e lect r ica l , power fa i lure shall not affect i ts instant operation in the event of f i r e . Hand winches may be employed to f a c i l i t a t e operation of m~nually controlled vents.

9-3.2.1.6 Proscenium Walls. Where automatic sprinkler protection is :~ot provided, the proscenium wall of every theater ,Jsing movable scenery or decorations shall not have more than two openings entering the Stage, exclusive of the proscenium opening. Such openings shall not exceed 21 sq Ft (2.0 sq m) each and shall be Fitted with self-closing Fire doors.

9-3.2.1.7 Proscenium Curtain. The proscenium opening of every legitimate stage shall be provided with a curtain constructed and mounted so as to intercept hot gases~ Flames and smoke and to guard against seeing Flame From a Fire on the stage from the auditorium side within a Five minute period where the curtain is of asbestos. Other materials may be used i f they have passed a thirty-minute Fire test in a small scale furnace, 3 f t by 3 f t , with the sample mounted in the horizontal plane at the top of the furnace and subjected to the standard time-temperature curve.

The curtain shall be automatic closing without the use of applier power.

Exception: In l ieu of the protection required herein, a l l the follovring may be provided:

(a) A noncombustible opaque Fabric curtain so arranged that i t w i l l close automatically, and

(b) An automatic Fixed waterspray deluge system shall be located on the auditorium side of the proscenium opening and be so arranged that the entire face of the curtain w i l l be wetted. The system shall be activated by combination of ra te-of - r ise and fixed-tempera:ure detectors located on the cei l ing of the stage. Detectors shall be spaced in accordance with their l i s t ing . The water supply shall be controlled by a deluge valve and shall be suf f ic ient to keep the cur t l in completely wet For 30 minutes or unt i l the valve is =losed by f i r e department personnel, and

(c) The curtain shall be automatically operated in case of f i r e by a combination of ra te-o f - r ise and fixed temperature detectors that also activates the deluge spray system. Stage sprinklers and vents shall be automatically operated in case of Fire by fusible elements, and

(d) Operation of the stage sprinkler system or Spray deluge valve shall automatically activate the emergency venti lat ing system and close the curtain, and

(e) The curtain, vents and spray deluge system valve shall also be capable of manual operation.

9-3.2.1.6 Gridirons, Fly Galleries and Penrails. (Reserved)

9-3.2.1.9 Fire Protection. Every stage (legitimate, regular or thrust) larger than 500 sq f t (46.5 sq m} in area shall have a system of automatic sprinklers at the cei l ing, in usable spaces under the stage, in aux i l i a r y spaces and dressing rooms, storerooms, and workshops. Where there is a stage gridiron, 135°F (57°C) rated sidewall sprinklers with heat-baffle plates shall be installed around the perimeter of the stage, except above the proscenium opening, at points not more than 30 in. (76 cm) below the gridiron, and with sprinklers positioned 4 to 6 in. (10.2 to 15.2 cm) below the baff le plate.

9-3.2.1.10 Auxi l iary Stage Spaces. Auxi l iary stage spaces such as understage areas, dressing rooms, workshops, and similar spaces associated with the functioning of a stage shall comply with the Following:

(a) No point within any aux i l iary space shall be more than 50 f t (15 m) from a door providing access to an exi t .

(b) There shall be at least two exits available From every auxi l iary stage space, one of which shall be available within a travel distance of 75 f t (23 m). A common path of travel of 20 f t (6.1 m) shall be permitted.

(c) Auxi l iary stage spaces shall be equipped with automatic sprinklers when required by 9-3.2.1.3.

(d) No workshop involving the use of a combustible or Flammable paint, l iquids, or gases, or their storage shall open d i rect ly upon a stage.

9-3.2.1.II Flame Retardant Requirements. Combustible scenery of cloth, f i lm, vegetation (dry), and similar effects shall meet the requirements of NFPA 701, Standard Methods of Fire Tests For Flame Resistant Textiles and Films. Foamed plastics (see A-6-5.1.3) only may be used by specific approval of the authorlty having jur isdict ion. Scenery and stage properties on thrust Stages shall be either noncombustible or limited combustible materials.

9-3.2.1.12 Each legitimate or regular stage shall be equipped with a Class I I I standpipe located on each side of the stage installed in accordance with 7-7.4.2.

9-3.2.2 Projection Booths.

9-3.2.2.1 Every place of assembly where an e lect r ic arc, Xenon, or other l ight source that generates hazardous gases, dust, or radiation is used shall have a projection room that complies with 9-3.2.2.2 from which the projection shall be made, Where cellulose ni t rate f i lm is used, the projection room shall comply with NFPA 40, Standard For the Storage and Handling of Cellulose Nitrate Motion Picture Film. (See also Chapter 31.}

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9-3.2.2.2 Projection Rooms for Safety Film. Projection rooms for safety f i lm shall meet the requirements OF 9-3.2.2.3 through 9-3.2.2.8.

9-3.2.2.3 Every projection room shall be of permanent construction consistent with the construction requirements for the type of building in which the projection room is located. Openings need not be protected. The room shall have a Floor area of not less than 80 sq ft (7.4 sq m) for a single machine and at least 40 sq f t (3.7 sq m) For each additional machine. Each motion picture projector, f loodl ight , spotlight, or similar piece of equipment shall have a clear working space not less than 30 in. (76 cm) on each side and at the rear thereof, but only one such space shall be required between adjacent projectors.

The projection room and the rooms appurtenant thereto s h a l l have a c e i l i n g h e i g h t o f not less than 7 f t G i n . (229 cm).

9-3.2.2.& Each projection room shall have at least one out-swinging, self-closing door not less than 2 Ft G in. (76 cm) wide by 6 f t 8 in. (203 cm) high.

9-3.2.2.5 The aggregate of ports and openings For projection equipment shall not exceed 25 percent of the area of the wall between the projection room and the auditorium.

All openings shall be provided with glass or other approved material, so as to completely close the opening.

9-3.2.2.6 Projection room venti lat ion shall be not less than the Following:

(a) Supply Air. Each projection room shall be provided with adequate a i r supply inlets so arranged to provide well distributed a i r throughout the room. Air in let ducts shall provide an amount of a i r equivalent to the amount of a i r being exhausted by projection equipment. Air may be taken From the outside; From adjacent spaces within the building provided the volume and i n f i l t r a t i o n rate is suf f ic ient ; or from the building a i r conditioning system, provided i t is so arranged as to provide suf f ic ient a i r whether or not other systems are in operation.

(b) Exhaust Air. Projectlon booths may be exhausted through the lamp exhaust system. The lamp exhaust System shall be posit ively interconnected with the lamp so that the lamp w i l l not operate unless there is the ai r f low required For the lamp. Exhaust a i r ducts shall terminate at the exter ior of the building in such a location that the exhaust a i r cannot be readily recirculated into any a i r supply system. The projection room vent i lat ion system may also serve appurtenant rooms such as the generator room and the rewind room.

9-3,2,Z.7 Each projection machine shall be provided with an exhaust duct that will draw air From each lamp and exhaust it directly to the outside of the building. The lamp exhaust may serve to exhaust a i r From the projection room to provide room a i r circulat ion. Such ducts shall be of ridgid materials, except for a f lex ib le connector approved for the purpose. The projection lamp and projection room exhaust systems may be combined, but shall not be interconnected with any other exhaust or return a i r system within the buildings.

(a) Electric Arc Projection Equipment. The exhaust capacity shall be 200 cfm (.09 cu m/s) For each lamp connected to the lamp exhaust system, or as recommended by the equipment manufacturer. Auxi l iary a i r may be introduced into the system through a screened opening to stabi l ize the arc.

(b) Xenon Projection Equipment. The lamp exhaust system shall exhaust not less than 300 cfm (.14 cu m/s) per lamp, not less than that exhaust volume required or recommended by the equipment manufacturer, whichever is the greater.

9-3.2.2.8 Miscellaneous Equipment and Storage.

(a) Each projection room shall be provided with rewind and f i lm storage Fac i l i t ies .

(b) A maximum of Four containers for Flammable liquids not greater than 16 oz (.5 L) capacity and of a nonbreakable type may be permitted in each projection booth.

(c) Appurtenant electr ical equipment such as rheostats, transformers, and generators may be located within the booth or in a separate room of equivalent construction.

9-3.2.3 Service Equipment, Hazardous Operations or Processes, and Storage Faci l i t ies .

9-3.2.3.1 Rooms containing high pressure boilers, refr igerat ing machinery of other than domestic refr igerator type, large transformers, or other service equipment subject to possible explosion shall not be located d i rect ly under or adjacent to required exits. All such rooms shall be separated by a l-hour Fire barr ier From other parts of the building.

9-3.2.3.2 Opening Protection. (Reserved)

9-3.2.3.3 Rooms or space for the storage, processing, or use of the materials specified in this section shall be protected in accordance with the Following:

(a) Rooms or spaces used for the storage of combustible supplies in quantities deemed hazardous by the authority having jur isdict ion, hazardous materials in quantities deemed hazardous by recognized standards, or Fuel shall be separated from the remainder of the building by construction having not less than a l-hour Fire resistance rating with a l l openings protected by self-closing or smoke-actuated Fire doors, or such rooms or spaces may be protected by an automatic extinguishing system as set Forth in Section 6-4.

(b) Rooms or spaces used for processing or use of combustible supplies in quantities considered hazardous by the authority having jurisdiction, hazardous materials, or for flammable or combustible liquids in quantities deemed hazardous by recognized standards shall be separated from the remainder of the building by construction having not less than a l-hour Fire resistance rating with a l l openings protected by self-closing or smoke-actuated Fire doors and shall also be protected by an automatic extinguishing system as set Forth in Section 6-4.

(c) Boiler and furnace rooms, laundries, and maintenance shops, including woodworking and painting areas, shall be separated From the remainder of the building by construction having not less than a l-hour f i r e resistance rating with a l l openings protected by self-closing or smoke-actuated Fire doors or such rooms or spaces may be protected by an automatic extinguishing system as set forth in Section G-4.

Exception to (c): Rooms enclosing air-handling equipment.

(d) ~ Where automatic extinguishing systems are used to meet the requirements of this section, the rooms or spaces shall be separated From the remainder of the building by construction which restricts the passage of smoke.

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(e) Where a~tomatic extinguishing is used to meet the requirements of this section, the protection may be in accordance with 7-7.1.2.

9-3.2.4 Special Provisions for Food Service Establishments,

9-3.2.4.1 All devices in connection with the preparation of food shall be so installed and operated as to avoid hazard to the safety of occupants.

9-3.2.4.2 All devices in connection with the preparation of Food shall be of an approved type and shall be installed in an approved manner.

9-3.2.4.3 Food preparation f a c i l i t i e s shall be protected in accordance with 7-2.3 and are not required to have openings protected between food preparation areas and dini,~g areas.

9-3.3 Inter ior Finish.

9-3.3.l The in ter ior f in ish requirements of this section shall be in accordance with Section 6-5.

9-3.3.2 Inter ior Finish in a l l corridors and lobbies shall be Class A or B and, in enclosed stairways, Class A.

9-3.3.3 Inter ior f in ish in general assembly areas of Class A or Class B assembly occupancies shall be Class A or Class B. In Class C assembly occupancies i t shall be Class A, B, or C.

Exception: Im any assembly occupancy, exposed portions of structural members complying with the requirements for Type IV (2HH) construction may be permitted.

9-3,3.4 Screens on which pictures are projected shall comply with requirements of Class A or Class B in ter ior f in ish.

9-3.4 Detection, Alarm and Communications SysCems.

9-3.4.1 General. All Class A and a l l Class B assembly occupancies, and a l l theaters with more than one audience viewing room, shall be provided with an approved f i r e alarm system in accordance with this section.

Exception No. l : Assembly occupancies which are a part of a mixed occupancy (see I-4.7) may be served by a common Fire alarm system provided the individual requirements of each occupancy are met.

Exception No. 2: Assembly occupancies where, in the judgment of the authority having jur isd ic t ion, adequate alternative provisions exist or are provided for the discovery of ~ f i r e condition and for the prompt alert ing of t~e occupants.

9-3.4,2 In i t ia t ion . In i t i a t i on of the required f i r e alarm system shall be by manual means in accordance with 7-6.2.1(a), which shall be provided with an emergency power source. The in i t i a t i ng device shall be capable of transmitting an alarm to a receiving station, located within the building, that is constantly attended when the assembly occupancy is occupied.

Exception No. l : I n i t i a t i on may be by means of an approved automatic f i r e detection system, in accordance with 7-6.2.1(b), providing f i r e detection throughout the building.

Exception No. 2: In i t i a t i on may be by means of an approved automatic sprinkler system, in accordance with 7-6.2.1(c), providing f i r e detection and protection throughout the building.

9-3.4.3 Not i f icat ion.

9-3.4.3.1 The required Fire alarm system shall sound an audible alarm in a constantly attended receiving station within the building for purposes of i n i t i a t i ng emergency action.

9-3.4.3.2 Occupant not i f icat ion shall be by means of either voice or prerecorded message announcement in i t ia ted by the person in the constantly attended receiving station.

9-3.4.3.3 The announcement shall be made via an approved voice communication or public address system that is audible above the ambient noise level of the assembly occupancy.

9-3.4.3.4 Where the authority having jur isd ic t ion determines that i t is impractical to have a constantly attended location in an assembly occupancy other than a theater, a f i r e alarm system in accordance with Section 7-6 in i t ia ted by manual stations in accordance with 7-6.2.1(a) or other approved means of i n i t i a t i on , that automatically provides prerecorded evacuation instructions in accordance with 7-6.3.8, may be used.

9-3.5 Extinguishment Requirements. (See 9-1.6, 9-2.6, and 9-3.2.)

9-3.5.l Fire Suppression Systems. Any assembly occupancy used or capable of being used for exhibit ion or display purposes shall be protected throughout by an approved automatic sprinkler system in accordance with Section 7-7 when the exhibition or display area exceeds IS,O00 sq f t (1400 sq m).

9-3.6 Corridors. (Reserved)

9-3.6 .1 I n t e r i o r C o r r i d o r and Lobby Cons t ruc t i on . (Reserved)

SECTION 9-4 SPECIAL PROVISIONS

9-4.1 Windowless or underground buildings shall comply with this chapter and Section 30-7.

9-4.2 High Rise Buildings. (Reserved)

9-4.3 Outdoor Assembly.

9-4.3.l All grandstands, tents, and other places of outdoor assembly shall comply with the requirements of NFPA 102, Standard For Assembly Seating, Tents, and Membrane Structures.

9-4.4 Special Provisions For Exhibition Halls.

9-4.4.1 No display or exhibit shall be so installed or operated as to interfere in any way with access to any required ex i t or with the v i s i b i l i t y of any required exi t or any required exi t sign, nor shall any display block access to f i r e fighting equipment.

9-4.4.2 A Storage room having an enclosure with a smoke barr ier having a f i r e resistance rating of l hour and protected by an automatic f i r e extinguishing system shall be provided For combustible materials not on display.

9-4.4.3 Exhibits. Exhibits shall comply with the following:

(a) The travel distance within the exhibit booth or exhibit enclosure to an exit access aisle shall not be greater than 50 f t (15 m).

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(b) Exhibit booths shall be constructed of noncombustible or limited combustible materials, pressure-treated Fire retardant wood meeting the requirements of NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings For Building Materials, or of Flame retardBnt materials complying with NFPA 701, Standard Methods of Fire Tests For Flame-Resistant Textiles and Films, both small and large scale tests. Texti le wall coverings, such as carpeting having a napped, tufted, looped, or similar surface used as wall or ceil ing Finish shall comply with 6-5.2.3. Plastic shall be limited to Class A or Class B in ter ior wall and ceil ing f inish. Foamed plastics (see A-6-5.2.4) are prohibited.

(c) Curtains, drapes and decorations shall comply with 31-1.4.

(d)* Acoustical and decorative material including, but not limited to, cotton, hay, paper, straw, moss, sp l i t bamboo, and wood chips shall be Flame-retardant treated to the satisfaction of the authority having jur isd ic t ion. Materials that cannot be treated for Flame retardancy shall not be used.

(e) Exhibit booths that are mult i level, consist Of multiple rooms with ceil ings, or are over 225 sq f t (20.9 sq m) with ceil ings, shall be protected by automatic sprinklers in buildings so protected.

Exception: Vehicles, boats, and similar exhibited products having over tO0 sq f t (9.3 s~ m) of roofed area shall be provided with smoke detectors acceptable to the authority having jur isdict ion.

(F) Open Flame devices within exhibit booths shall comply with 31-2.3.

(g) Cooking and Food warming devices in exhibit booths shall comply with 31-2.4 and the following:

I. Gas Fired devices shall be installed in accordance with 7-1.1.

2. Devices shall be isolated From the public by at least 4 f t (122 cm) or a barrier between the device and the public.

3. Devices shall be limited to 288 sq in. (.19 sq m) of cooking Surface area.

4. Devices shall be placed on noncombustible surface materials.

5. Devices used for cooking shall be sepaFated from each other by a minimum distance of 2 Ft (61 cm).

6. Devices shall be kept a minimum of 2 f t (Gl cm) from any combustible materials.

7. Single well cooking equipment using combustible o i ls or solids shall have l ids available for immediate use. Mult i-vat cooking equipment using combustible o i ls or solids shall comply with 7-2.3.

8. A 20 BC f i r e extinguisher shall be provided within the booth for each device or an approved automatic extinguishing system shall be provided.

(h) Combustible materials within exhibit booths shall be limited to a one day supply. Storage of combustible materials behind the booth is prohibited (See 9-4.4.2 and 31-2,6.2).

( i ) Plans, in a form acceptable to the authority having jur isdict ion, shall be submitted to the authority having jur isd ic t ion For approval prior to the move in of any exhibit or trade show. The plan shall show a l l details of the proposed exhibit or show. NO exhibit or trade show shall occupy any exhibit hall without approved plans.

9 4.4.4 Vehicles. Vehicles within an exhibit hall shall comply with the following:

(a) All fuel tank openings shall be locked and sealed in an approved manner to prevent the escape of vapors. Fuel tanks shall be not more than 3/4 nor less than I/8 Full.

(b) At least one battery cable shall be removed From each set of batteries.

(c) Fueling or defueling of vehicles shall be prohibited.

(d) Vehicles shall not be moved during show hours.

9-~.#.S Compressed flammable gases, Flammable or combustible liquids, hazardous chemicals or materials, Class I I or greater lasers, blasting agents and explosives shall be prohibited within exhibit halls.

Exception: The authority having jur isdict ion may permit the limited use of any of the above items under special circumstances.

9-4.5 Special Provisions for the Handicapped. (Reserved)

9-4.6 Special Provisions For Amusement Buildings. IReserved)

9-4.7 Operating Features. (See Chapter 31.)

SECTION 9-5 BUILDING SERVICES

9-5.I U t i l i t i e s shall comply with the provisions of Section 7-I.

9-5.2 Heating, vent i lat ing, and a i r conditioning equipment shall comply with the provisions of Section 7-2.

9-5.3 Elevators, dumbwaiters, and vert ical conveyors shall comply with the provisions of Section 7-4.

9-5.4 Rubbish chutes, incinerators, and laundry chutes shall comply with the provisions of Section 7-5.

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CHAPTER 8

A-8-I.2.1 Depending upon the character of construction and the hazard of the occupancy, this w i l l require some physical separation by walls of appropriate Fire resistance, protection of the other occupancy by automatic sprinklers, or other appropriate measures. Where the building is of f i re - res is t i ve construction and the hazard of the other occupancy is low or ordinary, as in a school or hotel, no separation may be necessary.

A-8-I.2.4 Exception Example: An assembly room for the inmates of a detention occupancy w i l l not normally be subjected to simultaneous occupancy.

A-8-l.3 Definit ions.

Platform. I t is not intended to prohibit the use of a curtain as a valance to screen or hide the e lect r ic conduit, l ighting track or similar Fixtures.

This is not intended to prohibit the use of curtains such as are used to obscure the back wall of the stage, curtain between the auditorium and the stage (grand or house curtain) and no more than four leg drops nor the use of a valance to screen l ight panels, plumbing and similar equipment from view.

Smoke-Protected Assembly Seating. An assembly area wherein the roof is not less than 15 f t above the highest cross aisle or seat row, and having smoke-actuated venting f a c i l i t i e s within that part of the roof suf f ic ient to maintain the level of smoke at least 6 f t above the highest seating or walking level, is considered ~:o be smoke-protected assembly seating.

The Following definit ions may be useful to the enforcer of the Code although the terms are not used within the Code.

Accessory Rooms. The accessory rooms are dressing rooms, property master's work and storage rooms, the carpenter's room~ and similar rooms necessary For legitimate sta~e operations.

Batten. In general a flown metal pipe or shape on which l ights or scenery are Fastened. While existing theater stages may s t i l l have wooden bars, they should not be used in new construction.

Scrim. Finely woven Fabric that can be translucent or opaque depending upon how i t is used.

Theater in the Round. An acting area in the middle of a room with the audience s i t t ing a l l around i t .

A-8-1.7.1 Suggested occupant load Factors For components of large airport terminal buildings are given, however the authority having jur isdict ion may elect to use di f ferent occupant load Factors provided exi t requirements herein are satisf ied.

AIRPORT TERNINAL SQUARE FOOT (GROSS)

Concourse 1 O0 Waiting Areas 15 Baggage Claim 20 Baggage Handling 300 Other (See table in appendix

A - 5 - 3 . 1 . 2 )

A-8-1.7.1(a) Seating."

This includes so-called "Festival

A-8-2.3.2 Tables 8-2.3.2(a) and 8-2.3.2.(b) are based on a l inear relationship between number of seats and nominal Flow time, with a minimum of 200 seconds (3.3 minutes) For 2,000 seats plus l second For every additional 50 seats up to 25,000. Beyond 25,000 total seats, the nominal flow time is limited to 660 seconds ( I f minutes). Nominal Flow time refers to the Flow time for the most-able group of patrons; some less-famil iar, less-able groups might take longer to pass a point in the egress System. (Although three or more digits are noted in the tables, the resulting calculations should be assumed to provide only two signif icant Figures of precision.)

A l i f e safety evaluation is a written review dealing with the adequacy of l i f e safety Features re lat ive to f i r e , storm, collapse, crowd behavior, and other related safety considerations. Thls review should be done by an approved person acceptable to the authority having jur isdict ion. Such an evaluation includes, for example, a documented case that shows products of combustion in a l l conceivable f i r e scenarios w i l l not s igni f icant ly endanger occupants using means of egress in the Fac i l i ty (because of f i r e detection, automatic suppression, smoke control, large volume space, management procedures, etc.). Moreover, means of egress facilities plus Facility management capabilities should be adequate to cope with scenarios where certain egress routes are blocked For some reason.

In addition to making rea l i s t i c assumptions about the capabil i t ies of persons in the Fac i l i t y (e.g., an assembled crowd including many disabled persons or persons unfamiliar with the Fac i l i t y ) the l i f e safety evaluation should include a Factor of safety of at least 2.0 in a l l calculations relating hazard development time and required egress time the combination of Flow time and other time needed to detect and assess an emergency condition, i n i t i a te egress, move along the egress routes, etc. This takes into account the poss ib i l i ty that half of the egress routes may not be used (or usable) in certain situations.

An example calculation may help describe the use of Table 8-2.3.2(b).

Within an arena providing Smoke-Protected Assembly Seating and having a total of 12,500 seats: for capacity purposes only, what should be the clear width of an aisle s ta i r , with 8-in. r isers and with a center handrail, providing means of egress for 340 seats? Interpolating between the width (0.13 and 0.096) respectively For 10,000 and 15,000 seat Fac i l i t ies , the required sta i r width, in inches, per seat served is 0.113 AB where A is 1.2 and B is 1.0. The aisle s ta i r width, For capacity purposes, is the product of 340 (0.113) ( I .2) ( l .0) or 46.1 in. In this case a minlmum width cr i ter ion of 48 in. (see 8-2.5.6.7) w i l l govern i ts width. Previous editions of the Code credlted this aisle s ta i r with a capacity of only 150 persons.

A-8-2.5,4.2 The system known as "continental seating" has one pair of egress doors provided For every Five rows and located close to the ends of the rows. In previous editions of the Code, such egress doors were required to provide a minimum clear width of 66 in. (168 cm) discharging into a foyer, lobby, or to the exterior of the building. This continental seating arrangement can result in egress Flow times that are approximately one-half as long as those resulting where side aisles lead to more remote doors ( i . e . , with nominal Flow times of approximately I00 seconds rather than 200 seconds). Such superior egress flow time performance may be desirable in some situations; however, special attention should be given either to a comparably good egress capacity For other parts of the egress system or to suf f ic ient space to accommodate queuing outside the seating space.

389

A-8-2.5.4.7 Figure A-8-2.5.4.7 i l lus t ra tes the requirements of 8-2.5.4.7.

~" ~ 10 ft (3 0 m) Max f

o

Amsle 36 nn (91 crn) Mm

Figure A B-2.5.4.7

A-8-2.5.4.8 F~gure A-8-2.5.4.8 i l lus t ra tes the requirements of 8-2.5.4.8.

t_I

~ [ ~ - - 20 ft (6 1 m) Max

( m

1__ 54 in. (137cm)

36 ran. (91cm)

i •

) - - Aisle or Extt

A-8 2.5.5 Tablet-arm chairs having a stored position have not been shown to require special regulation. Where an assembly occupancy is designed for dual purpose as instructional Space and public purposes, management should require that the tablet arm be placed in the stored position when instruction is not the primary Function.

A-8-2.5.6.8

Aisle 36 in (91 cm) Min Aisle 55 in. (14,0 cm) Min

Figure A-8-2.S.6.8(a)

Figure A-8-2.5.G.8(b) (shown on next page) i l lus t ra tes the aisle requirements For a banquet type arrangement. A reasonable space should be provided between tables For waitress or waiter access, otherwise the tables w i l l gradually be pushed into the aisle width. This diagram i l lus t ra tes aisle requirements only and would not be used to increase occupant load or approve layout, as i t does not i l l us t ra te rea l i s t i c layouts For servicing.

F i g u r e A - 8 - 2 . 5 . 4 . 8

390

A-8-2.S.6.9(a) Where nonuniformities occur due to construction tolerances, they should not exceed 3/16 in. (O.S cm) between adjacent treads.

A-8-2.5.6.9(b) Tread depth is more important to s ta i r safety than is r iser height. Therefore, in cases where seating area gradient is less than 5 in I i , i t is recommended that the tread dimension be increased beyond ]] in. (27.9 cm) rather than reducing the r iser height. Where seating area gradient exceeds 8 in I I , i t is recommended that the r iser height be increased while maintaining a tread depth of at least II in. (27.9 cm).

A-8-2.S.6.9(e) Nonuniformities arising From construction tolerances should not exceed 3/}6 in. (0.5 cm) in adjacert r isers.

(A) A Small Aisle Would Normally Be Provided for Waiter/Waitress Access.

(B) No Aisle Requirement When Travel ~ 10 ff

(C) Distance Between Table MUM Be ~ Required Aisle Width Plus 19 in. for Chairs on One or 38 in. for Chairs on Both Sides

(D) Aisle Must Be Sized in Accordance with 5-3.2 But Not Less Than 36 in.

Conversion: i in. = 2.54 cm.

Figure A-8-2.5.6.8(b)

A-8-2.5.6.9(g) Certain tread covering materials such as plush carpets, often used in theaters, produce an inherently well-marked tread nosing under most l ight conditions. On the other hand, concrete treads (with nosings having a sharp edge), especially under outdoor l ight conditions, are d i f f i c u l t to discriminate and therefore require an applied marking stripe. Slip resistance of such marking stripes should be similar to the rest of the treads and no tripping hazard should be created.

A-8-3.2.3.3(d) I t is not the intent of this provision to require a smoke barrier that meets the requirements of Section G-3.

A-8-3.5.l Exception No. 2 A school gymnasium with egress independent of and separated from the school would be included in this exception as would a function hall attached to a church with a similar egress arrangement.

391

A-8-4.4,3(d) The authority having jur isdict ion may use the Field flame test contained in NFPA 701, Standard Methods of Fire Tests For Flame-Resistant Textiles and Fi lms, as one method o f d e t e r m i n i n g f lame re ta rdancy .

A-8-4.5 Unless accommodations are speci f ica l ly provided for the handicapped, the placement of handicapped persons may endanger the proper use of exits by others by blocking aisles and exits. Reference is made to ANSI A117.1, American Standard Specifications for Making Buildings and Fac i l i t ies Accessible to and Usable by the Physically Handicapped (see Appendix B).

A-8-4.6.2 I t is the intent of the Committee to provide a suppression system that w i l l act quickly to provide for l i f e safety of the occupants.

A 8-4.6.4.¢ Consideration should be given to the provision of directional exi t marking on or adjacent to the f loor .

CHAPTER 9

A-9-1.2.1 Depending upon the character of construction and the hazard of the occupancy, this w i l l require some physical separation by walls of appropriate Fire resistance, protection of the other occupancy by automatic sprinklers, or other appropriate measures. Where the building is of f i r e - res i s t i ve construction and the hazard of the other occupancy is low or ordinary, as in a school or hotel, no separation may be necessary.

A-9-1.2.4 Exceptlon Example: An assembly room for the inmates of a detention occupancy will not normally be subjected to simultaneous occupancy.

A-9-1.3 DeFinltions.

Platform. It is not intended to prohibit the use of a curtain as a valance to screen or hide the electric conduit, lighting track or simllar flxtures.

This is not intended to prohibit the use of curtains such as are used to obscure the back wall of the stage, curtaln between the auditorium and the stage (grand or house curtain) and no more than four leg drops nor the use of a valance to screen llght panels, plumbing and similar equipment From vlew.

Smoke-Protected Assembly Seating. An assembly area wherein the roof Is not less than 15 Ft above the highest cross aisle or seat row, and having smoke actuated venting Fac i l i t ies w~thin that part of the roof suf f ic ient to maintain the level of smoke at least 6 Ft above the highest seating or walking level, is considered to be smoke protected assembly seating.

The following defini t ions may be useful to the enforcer of the Code although the terms are not used within the Code.

Accessory Rooms. The accessory rooms are dressing rooms, p r o p e r t y m a s t e r ' s work and s to rage rooms, the carpenter's room and similar rooms necessary for legitimate stage operations.

Batten. In general a flown metal pipe or shape on which l ights or scenery are fastened. While existing theater stages may s t i l l have wooden bars, they should not be used in new construction.

Scrim. Finely woven Fabric that can be translucent or opaque depending upon how i t is used.

Theater in the Round. An acting area in the middle of a room with the audience s i t t ing a l l around i t .

A-9 -1 .7 .1 Suggested occupant load factors For components of large airport terminal buildings are given, however the authority having jur isd ic t ion may elect to use di f ferent occupant load factors provided exi t requirements herein are satisf ied.

AIRPORT TERMINAL SQUARE FOOT (GROSS)

Concourse 100 Waiting Areas 15 Baggage Claim 20 Baggage Handling 300 Other (See table in appendix

A-5-3.1.2)

A-9-1.7.1(a) This includes so-called "Festival Seating."

A - 9 - 1 . 7 . 2 E x i s t i n g a u d i t o r i u m and arena s t r u c t u r e s might not be designed For the added occupant load beyond the fixed seating. The authority having jur isdict ion should consider ex i t access and aisles before granting additional occupant load such as Festival seating, movable seating, etc. on the auditorium or arena Floor area.

A - 9 - 2 . 3 . 2 Tables 9 - 2 . 3 . 2 ( a } and 9 - 2 . 3 . 2 ( b ) are based on a l i n e a r r e l a t i o n s h i p between number o f seats and nominal Flow t ime, w i t h a mlnimum o f 200 seconds (3 .3 minutes) For 2,000 seats p lus I second f o r every a d d i t i o n a l 50 seats up to 25,000. Beyond 25,000 t o t a l seats , the nominal f l o w t ime is l i m i t e d to 660 seconds ( I I minutes). Nominal flow time refers to the Flow time for the most-able group of Patrons; some less-Familiar, less-able groups might take longer to pass a point in the egress system. (Although three or more digits are noted in the tables, the resulting calculations should be assumed to provide only two signif icant Figures of precision.)

A l i f e safety evaluation is a wrltten review dealing with the adequacy of l i f e safety features relat ive to f i r e , s torm, c o l l a p s e , crowd behav io r , and o the r r e l a t e d sa fe t y c o n s l d e r a t i o n s . This rev iew should be done by an approved person accep tab le to the a u t h o r i t y hav ing j u r i s d i c t i o n . Such an e v a l u a t i o n i nc l udes , f o r example, a documented case tha t shows products o f combust ion in a l l conce i vab le f i r e scenar ios w i l l not s i g n i f i c a n t l y endanger occupants us ing means o f egress in the f a c i l i t y (because of f i r e d e t e c t i o n , au tomat lc suppress ion , smoke c o n t r o l , l a rge -vo lume space, management procedures, etc.) . Moreover, means of egress Faci l i t ies plus Fac i l i ty management capabil i t ies should be adequate to cope with scenarios where certain egress routes are blocked For some reason.

In a d d i t i o n to making r e a l i s t i c assumptions about the capabil i t ies of persons in the f a c i l i t y (e.g., an assembled crowd including many disabled persons or persons unfamiliar with the f a c i l i t y ) the l i f e safety e v a l u a t i o n should i nc l ude a Fac to r o f s a f e t y o f a t l e a s t 2.0 in a l l c a l c u l a t i o n s r e l a t i n g hazard development t ime and r e q u i r e d egress t ime - the comb ina t ion o f Flow t ime and o t h e r t ime needed to de tec t and assess an emergency eond i t i on~ i n i t i a t e egress, move along the egress rou tes , e t c . Th is takes i n t o account the p o s s i b i l i t y t h a t h a l f o f the egress rou tes may not be used (o r usab le ) in c e r t a i n s i t u a t i o n s .

An example calculation may help describe the use of Table 9 2.3.2(b).

Wi th in an arena p r o v i d i n g Smoke Pro tec ted Assembly Seat ing and having a t o t a l o f 12,500 sea ts : f o r c a p a c i t y purposes on ly , what should be the c l e a r w id th of an aisle s ta i r , with 8-inch risers and with a center handrail, providing means of egress For 340 seats? Interpolating between the width (0.13 and 0.096)

392

respectively for" I0,000 and 15,000 seat f a c i l i t i e s , the required s ta i r width, in inches, per seat served is O.ll3 AB where A is 1.2 and 8 is 1.0. The aisle s ta i r width, for capacity purposes, is the product of 340 (O.ll3) (1.2) ('I.0) or 46.1 in. In this case a minimum width cr i te r ion o£ 48 in. (see 9-2.5.6.7) w i l l govern i ts width. Previous editions of the Code credited this aisle s ta i r with a capacity of only 1 5 0 persons.

A-9-2.5.4.2 The system known as "continental seating" has one pair of egress doors provided for every f ive rows and located close to the ends o f the rows. In previous editions of the Code, such egress doors were required to provide a minimum clear width of 66 in. (168 cm) discharging into a foyer, lobby, or to the exter ior of the building, This continental seating arrangement can result in egress flow times that are approximately one-half as long as those resulting where side aisles lead to more remote doors ( i . e , , with nominal flow time's of approximately tO0 seconds rather than 200 seconds). Such superior egress flow time performance may be desirable in some situations; however, special attention should be given either to a comparably good egress capacity for other parts of the egress system or to suf f ic ient space to accommodate queuing outside the seating space.

A-9-2.5.4.7 Figure A-9-2.5.4.7 i l lus t ra tes the requirements of 9-2.5.4.7.

A=sle 36 fn. (91 crn) Min

,,,=1----- 10 ft (3 0 m) Max .1.-

Figure A-9-2.5.4.7

A-9-2.5.4.8 Figure A-g-2.5.4.B i l lus t ra tes the requirements of 9-2.5.4.8.

~ 20 ft (6.1 m) Max i

L1 54 In. (137cm)

36 in~ 191cm)

-fl - - Aisle or Exit

Figure A-9-2.5.4.8

A-g-2.5.5 Tablet-arm chairs having a stored posltion have not been shown to require special regulation, Where an assembly occupancy is designed For dual purpose as instructional space and public purposes, management should require that the tablet arm be placed in the stored position when instruction is not the primary function.

A-9-Z.5.6.8

Aisle 36 in, (91 cm) Min Atsle 55 =n (140 cm) Mm

Figure A-9-2.S.G.8(a)

Figure A-g-2.S.G.8(b) (shown on next page) i l lus t ra tes the aisle requirements For a banquet type arrangement. A reasonable Space should be provided between tables For waitress or waiter access, otherwise the tables w i l l gradually be pushed into the aisle width. This diagram i l lus t ra tes aisle requirements only and would not be used to increase occupant load or approve layout, as i t does not i11ustrate rea l i s t i c layouts for servicing.

393

(A) A Small Aisle Would Normally Be Provided for Waiter/Waitress Access.

(B) No Aisle Requirement When Travel _< 10 ft

(C) Distance Between Table Must Be :> Required Aisle Width Plus 19 in. for Chairs on One or 38 in. for Chairs on Both Sides

(D) Aisle Must Be Sized in Accordance with 5-3.2 But Not Less Than 36 in.

Conversion: ] in. = 2,54 cm.

Figure A-9-2.5.6.8(b)

A-9-2.5.6.9(a) Completely uniform tread dimensions are preferred over aisle s ta i r designs where tread depths alternate between re la t i ve ly small intermediate treads between seating platforms and re la t ive ly larger treads at seating platforms. A larger tread, level with the seating platform, is not needed to f ac i l i t a t e easy access to and egress From a row of seating. I f this arrangement is used i t is important to provide a better than minimum tread depth For the intermediate tread, hence 13 in. (33.0 cm) is specified. Where nonuniFormities occur due to construction tolerance, they should not exceed 3/IG in. (0.5 cm) between adjacent treads.

A-9-2.S.6.9(b) Tread depth is more important to s ta i r safety than is r iser height. Therefore, in cases where seating area gradient As less than 5 in I I , i t is recommended that the tread dimension be increased beyond l l i n . ( 2 7 . 9 cm) r a t h e r t han r e d u c i n g t he r i s e r height. Where seating area gradient exceeds 8 in 11, i t As recommended that the r iser height be increased while maintaining a tread depth of at least 11 in. (27.9 cm).

A-9-2.5.6.9(e) Nonuniformlties arising from construction tolerances should not exceed 3/16 in. (0.5 cm) in adjacent r isers.

A-9-2.5.6.9(g) Certain tread covering materials such as plush carpets, often used in theaters, produce an inherently well-marked tread nosing under most l ight conditions. On the other hand, concrete treads (with nosings having a sharp edge), especially under outdoor l ight conditions, are d i f f i c u l t to discriminate and therefore require an applied marking stripe. Slip resistance of such marking stripes should be similar to the rest of the treads and no tripping hazard should be created.

A-9-3.2.3.3(d) I t is not the intent of this provision to require a smoke barr ier that meets the requirements o£ Section 6-3.

A-9-4.4.3.(d) The authority having jur isd ic t ion may use the f ie ld flame test contained in NFPA 701, Standard Methods of Fire Tess For Flame-Resistant Textiles and Films, as one method o£ determining flame retardancy.

394

PART I I

(Log #SS) 101M- I - (T i t l e ) : Accept in Principle SUBMITTERi John M. Watts, J r . , Fire Safety Inst i tute COMMENT ON PROPOSAL NO.: IOIH-I RECOMMENDATION: Change t i t l e to:

"Rating Schedule Approach to Life Safety". SUBSTANTIATION: The term "Systems Approaches" is incorrect. This material does meet the systems c r i t e r i a of the NFPA Technical Committee on Systems Concepts For Fi~-e Protection in Structures. The material is nei':her systematic nor systemic, and the fabricated numbers have no established validation or ver i f i ca t ion. I t should not be labled as "Systems Approaches". COMMITTEE ACTIOFF: Accept in Principle.

Change t i t l e of NFPA I01M to "Alternative Approaches to Life Safety". COMMITTEE COMMENT: The Committee Action replaces the term "Systems Approaches", to which the Commenter is opposed, and such action should sat isfy the Con~nenter's intent.

(Log #194) lOin- 2 - (Entire Manual): Reject SUBMITTER: Jonas L. Morehart, National Institutes of Health COMMENT ON PROPOSAL NO.: I01M-I RECOMMENDATION: Delete the concept of a separate manual for systems approaches and continue the practice of placing the appendix material within the Code. SUBSTANTIATION: I f Code users do not purchase the manual, the syz,tems approaches w i l l not be used as readily, and the entire process w i l l be slowed. I f a "I01H" were included with the purchase of a Life Safety Code, the problem would be a 10t better. COMMITTEE ACTION: Reject. COMMITTEE COMMENT: Separate documents wi l l allow future edition:; of NFPA 101 and NFPA 101M to be processed on d-~ff'erent revision cycles to allow updating of NFPA loin FSES's once revisions to requirements o¢: NFPA lOl have been voted by the Association.

(Log #195) IOIM 3 - (Chapters 3, 4, and 6): Accept in Principle SUBHITTER: Jonas L. Morehart, National Insti tutes of Health ~OMMENT ON PROPOSAL NO.: I01M-I RECOMMENDATION: Revise 12-1.1.1.1 Exception; not A - 1 2 . 1 . 1 . 1 . 1

Revise 13 -1 .1 .1 .1 Excep t i on ; not A - 1 3 - 1 . 1 . 1 . 1 Revise 14-I.I.2 Exception No. 2; not A-14-1.1.2 Revise IS- l . l .2 Exception No. 2; not A- IS- l . l .2 Revise 21-2.2.1 Exception; not A-21-2.2.1 Revise 21-3.2.1 Exception; not A-21-3.1.3.1 (does not

exi St ) Revise 21-4.2.1 Exception; not A-21-4.2.1.

~VBSTANTIATION: The body of the Code needs to reference loin, not Appendix A. The existing Appendix A notes should remain. COMMITTEE ACTION: Accept in Principle.

NO action required. COMMITTEE COMMENT: The numbering used in the proposal for NFPA lOIH (TCR pages 494 and 495) refers to the numbering For the 1988 edition of NFPA lOl per TCR proposed actions. Thus, the references to appendix items are correct, given the relocation of Code verbiage for the 1988 edition.

(Log #196) loin- 4 - (Chapter 5): Accept SUBHITTER: Jonas L. Horehart, National Insti tutes of Health COMMENT~. PROPOSAL NO.: I01M-1 RECOMMENDATION: Change to read:

Revise "A-21-1.3 Evacuation Capability" . . . SUBSTANTIATION: There are two Appendix A notes for 21-I.3. COMMITTEE ACTION: Accept.

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