Technical Committee on
Sprinkler System Installation Criteria
MEMORANDUM
DATE:
May 21, 2014
TO:
Principal and Alternate Members of the Technical Committee on Sprinkler System
Installation Criteria
FROM:
Matt Klaus, Principal Fire Protection Engineer/NFPA Staff Liaison
SUBJECT:
AUT-SSI AGENDA PACKAGE – A2015 Second Draft Meeting
________________________________________________________________________
Enclosed is the agenda for the Second Draft meeting for NFPA 13, Standard for the Installation
of Sprinkler Systems. NFPA 13 has entered the Annual 2015 revision cycle and will produce a
2016 Edition. It is imperative that you review the attached public comments in advance, with your
ideas and substantiations for your views. If you have alternate suggestions for text changes, please
come prepared with the words and respective substantiation.
For administrative questions, please feel free to contact Elena Carroll at (617) 984-7952.
For technical questions, please feel free to contact Matt Klaus at (617) 984-7448. You can
also reach either of us via e-mail at ECarroll@nfpa.org or MKlaus@nfpa.org. We look forward to
meeting everyone in Del Mar, CA at the San Diego Marriott Del Mar.
Table of Contents
Part 1 - Meeting Agenda
Part 2 - Committee Address List
Part 3 – New Process Worksheets
Part 4 – A2015 First Draft Meeting Minutes
Part 5 - A2015 Key Dates
Part 6- SSI Public Comments
PART 1 –
MEETING AGENDA
Technical Committee on
Sprinkler System Installation Criteria
Second Draft Meeting
June 23-25, 2014
San Diego Marriott Del Mar
11966 El Camino Real
San Diego, CA 92130
AGENDA
Monday June 23, 2104
Call to Order – 8:00 AM
Introductions of Members and Staff
Review and Approval of A2015 First Draft Meeting Minutes
Review of A2015 Revision Cycle and Meeting Schedule
Review of Distributed Material and Workload
b. Overview of Public Comments
c. Overview of Potential Committee Second Revisions
6. Task Group Reports (order subject to change)
a. Metric Task Group
b. Pipe Venting Task Group
c. Compatibility Task Group
d. Cloud Ceiling Task Group
e. Galvanized Pipe Task Group (Keeping)
f. Chapter 1-3 Task Group Report (Lowrey)
g. Chapter 6 & 7 Task Group Report (Smith)
h. Chapter 8a Task Group Report (Caputo)
i. Chapter 8b Task Group Report (Bilbo)
j. Chapter 25 Task Group Report (Meehan)
7. Review Public Comments
1.
2.
3.
4.
5.
Tuesday, June 23, 2013
8. Reconvene 8:00AM (Time Subject to Change)
9. Continue Task Group Reports/Review Public Comments/Generate Second Revisions
Wednesday, June 25, 2013
10. Reconvene 8:00AM (Time Subject to Change)
11. Continue Task Group Reports/Review Public Comments/Generate Second Revisions
12. Adjournment TBD
PART 2 –
COMMITTEE ADDRESS LIST
05/19/2014
Matthew J. Klaus
AUT-SSI
Address List No Phone
Sprinkler System Installation Criteria
Automatic Sprinkler Systems
Joe W. Noble
Chair
Noble Consulting Services, LLC
6345 South Jones Blvd., #100
Las Vegas, NV 89130
International Fire Marshals Association
E 10/10/1997 Roland A. Asp
AUT-SSI Principal
National Fire Sprinkler Association, Inc.
40 Jon Barrett Road
Patterson, NY 12563-2164
National Fire Sprinkler Association
Design Technician
Hamid R. Bahadori
Principal
Hughes Associates, Inc.
725 Primera Boulevard, Suite 215
Lake Mary, FL 32746
Alternate: Mark Hopkins
SE 4/17/1998 Weston C. Baker, Jr.
AUT-SSI Principal
FM Global
1151 Boston Providence Turnpike
PO Box 9102
Norwood, MA 02062-9102
Alternate: David B. Fuller
Cecil Bilbo, Jr.
Principal
Academy of Fire Sprinkler Technology, Inc.
301 North Neil Street, Suite 426
Champaign, IL 61820
SE 7/26/2007 Pat D. Brock
AUT-SSI Principal
Oklahoma State University
Fire Protection & Safety Technology
1424 West Liberty Avenue
Stillwater, OK 74075
Alternate: Floyd Luinstra
M 07/29/2013
AUT-SSI
I 9/30/2004
AUT-SSI
SE 8/5/2009
AUT-SSI
Phillip A. Brown
Principal
American Fire Sprinkler Association, Inc.
12750 Merit Drive, Suite 350
Dallas, TX 75251
American Fire Sprinkler Association
Installer/Maintainer
Alternate: Jim Johnston
IM 10/10/1997 Robert G. Caputo
AUT-SSI Principal
Fire & Life Safety America
Consolidated Fireprotection, Inc.
657 Cantara Lane
Vista, CA 92081
Alternate: Steven J. Scandaliato
SE 1/16/1998
AUT-SSI
Ralph D. Gerdes
Principal
Ralph Gerdes Consultants, LLC
5510 South East Street, Suite E
Indianapolis, IN 46227
American Institute of Architects
SE 10/10/1997 Donald G. Goosman
AUT-SSI Principal
The RJA Group, Inc.
Rolf Jensen & Associates, Inc.
600 West Fulton Street, Suite 500
Chicago, IL 60661-1241
Alternate: Belynda Miranda
SE 11/2/2006
AUT-SSI
Luke Hilton
Principal
Liberty Mutual Property
13830 Ballantyne Corporate Place, Suite 525
Charlotte, NC 20277-2711
Alternate: Glenn E. Thompson
I 1/18/2001 Brian Hoening
AUT-SSI Principal
Globe Fire Sprinkler Corporation
4077 Air Park Drive
Standish, MI 48658
National Fire Sprinkler Association
Manufacturer
Alternate: Scott T. Franson
M 10/18/2011
AUT-SSI
1
05/19/2014
Matthew J. Klaus
AUT-SSI
Address List No Phone
Sprinkler System Installation Criteria
Automatic Sprinkler Systems
Elwin G. Joyce, II
Principal
Eastern Kentucky University
2148 Alexandria Drive
Lexington, KY 40504
NFPA Industrial Fire Protection Section
U 10/10/1997 Larry Keeping
AUT-SSI Principal
Professional Loss Control
3413 Wolfedale Road, Suite 6
Mississauga, ON L5C 1V8 Canada
John Kelly
Principal
Washington DC Fire & EMS Department
Office of the Fire Marshal
719 Opus Avenue
Capitol Heights, MD 20743
E 08/09/2012 Charles W. Ketner
L 1/10/2008
AUT-SSI Principal
AUT-SSI
National Automatic Sprinkler Fitters LU 669
Joint Apprenticeship & Training Committee
7050 Oakland Mills Road
Columbia, MD 20732
United Assn. of Journeymen & Apprentices of the
Plumbing & Pipe Fitting Industry
Alternate: Michael A. Rothmier
SE 10/10/1997
AUT-SSI
George E. Laverick
Principal
UL LLC
333 Pfingsten Road
Northbrook, IL 60062-2096
Alternate: Kerry M. Bell
RT 10/10/1997 Kenneth W. Linder
AUT-SSI Principal
Swiss Re
2 Waterside Crossing, Suite 200
Windsor, CT 06095
Alternate: Todd A. Dillon
David O. Lowrey
Principal
City of Boulder Fire Rescue
1805 33rd Street
Boulder, CO 80301
E 08/09/2012 Rodney A. McPhee
AUT-SSI Principal
Canadian Wood Council
99 Bank Street, Suite 400
Ottawa, ON K1P 6B9 Canada
U 10/10/1997
AUT-SSI
Michael F. Meehan
Principal
VSC Fire & Security
1417 Miller Store Road, Suite C
Virginia Beach, VA 23455
American Fire Sprinkler Association
Design
Alternate: Russell B. Leavitt
IM 1/16/1998 David S. Mowrer
AUT-SSI Principal
Babcock & Wilcox Technical Services, LLC
Y-12 National Security Complex
PO Box 2009, MS-8107
Oak Ridge, TN 37831-8107
Alternate: Austin L. Smith
U 10/10/1997
AUT-SSI
Thomas A. Noble
Principal
City of Henderson, Building & Fire Safety
240 Water Street
PO Box 95050
Henderson, NV 89009-5050
E 8/5/2009 Janak B. Patel
AUT-SSI Principal
Savannah River Nuclear Solutions
3704 Clark Crossing
Martinez, GA 30907
I 1/1/1984
AUT-SSI
U 8/5/2009
AUT-SSI
2
05/19/2014
Matthew J. Klaus
AUT-SSI
Address List No Phone
Sprinkler System Installation Criteria
Automatic Sprinkler Systems
Peter T. Schwab
Principal
Wayne Automatic Fire Sprinklers, Inc.
222 Capitol Court
Ocoee, FL 34761-3033
William B. Smith
Principal
Code Consultants, Inc.
2043 Woodland Parkway, Suite 300
St. Louis, MO 63146-4235
Alternate: David J. Burkhart
IM 3/15/2007 LeJay Slocum
AUT-SSI Principal
Aon Fire Protection Engineering
7230 McGinnis Ferry Road, Suite 200
Suwanee, GA 30024
Alternate: Steven M. Tomlin
SE 10/27/2005 Paul A. Statt
AUT-SSI Principal
Eastman Kodak Company
41 Monaco Drive
Rochester, NY 14624
Zeljko Sucevic
IM 08/09/2012
AUT-SSI
Principal
Vipond Fire Protection
6380 Vipond Drive
Mississauga, ON L6M 3C1 Canada
Canadian Automatic Sprinkler Association
Alternate: Matthew Osburn
Terry L. Victor
Principal
Tyco/SimplexGrinnell
705 Digital Drive, Suite N
Linthicum, MD 21090
Alternate: James E. Golinveaux
Lynn K. Underwood
Principal
Axis US Property
303 West Madison Street, Suite 500
Chicago, IL 60606
Alternate: Adam Seghi
M 10/3/2002 Robert Vincent
AUT-SSI Principal
Shambaugh & Son, L.P.
7614 Opportunity Drive
Fort Wayne, IN 46825-3363
National Fire Sprinkler Association
Contractor
Alternate: James A. Charrette
I 7/20/2000
AUT-SSI
U 1/10/2008
AUT-SSI
I 10/1/1997
AUT-SSI
IM 4/3/2003
AUT-SSI
Daniel P. Wake
Principal
Victaulic Company
4901 Kesslersville Road
PO Box 31
Easton, PA 18040-6714
Alternate: Peter W. Thomas
M 08/09/2012 Kerry M. Bell
AUT-SSI Alternate
UL LLC
333 Pfingsten Road
Northbrook, IL 60062-2096
Principal: George E. Laverick
David J. Burkhart
Alternate
Code Consultants, Inc.
2043 Woodland Parkway, Suite 300
St. Louis, MO 63146-4235
Principal: William B. Smith
SE 03/07/2013 James A. Charrette
IM 7/26/2007
AUT-SSI Alternate
AUT-SSI
Allan Automatic Sprinkler Corp. of So. California
3233 Enterprise Street
Brea, CA 92821
National Fire Sprinkler Association
Contractor
Principal: Robert Vincent
RT 4/15/2004
AUT-SSI
3
05/19/2014
Matthew J. Klaus
AUT-SSI
Address List No Phone
Sprinkler System Installation Criteria
Automatic Sprinkler Systems
Todd A. Dillon
Alternate
XL Global Asset Protection Services
1620 Winton Avenue
Lakewood, OH 44107
Principal: Kenneth W. Linder
I 7/16/2003 Scott T. Franson
AUT-SSI Alternate
The Viking Corporation
210 North Industrial Park Road
Hastings, MI 49058
National Fire Sprinkler Association
Manufacturer
Principal: Brian Hoening
M 10/29/2012
AUT-SSI
David B. Fuller
Alternate
FM Global
1151 Boston Providence Turnpike
PO Box 9102
Norwood, MA 02062-9102
Principal: Weston C. Baker, Jr.
I 7/26/2007 James E. Golinveaux
AUT-SSI Alternate
Tyco Fire Protection Products
1467 Elmwood Avenue
Cranston, RI 02910
Principal: Terry L. Victor
M 10/10/1997
AUT-SSI
Mark Hopkins
Alternate
Hughes Associates, Inc.
3610 Commerce Drive, Suite 817
Baltimore, MD 21227-1652
Principal: Hamid R. Bahadori
SE 3/4/2008 Jim Johnston
AUT-SSI Alternate
Inland Fire Protection
1100 Ahtanum Road
Yakima, WA 98903
American Fire Sprinkler Association
Installer/Maintainer
Principal: Phillip A. Brown
IM 03/07/2013
AUT-SSI
Russell B. Leavitt
Alternate
Telgian Corporation
2615 South Industrial Park Avenue
Tempe, AZ 85282-1821
American Fire Sprinkler Association
Design
Principal: Michael F. Meehan
IM 8/9/2011 Floyd Luinstra
AUT-SSI Alternate
Oklahoma State University
499 Cordell South
Stillwater, OK 74078
Principal: Pat D. Brock
SE 10/29/2012
AUT-SSI
Belynda Miranda
Alternate
The RJA Group, Inc.
Rolf Jensen & Associates, Inc.
12150 Monument Drive, Suite 815
Fairfax, VA 22033
Principal: Donald G. Goosman
SE 10/20/2010 Matthew Osburn
AUT-SSI Alternate
Canadian Automatic Sprinkler Association
335 Renfrew Drive, Suite 302
Markham, ON L3R 9S9 Canada
Principal: Zeljko Sucevic
IM 10/27/2005
AUT-SSI
4
05/19/2014
Matthew J. Klaus
AUT-SSI
Address List No Phone
Sprinkler System Installation Criteria
Automatic Sprinkler Systems
Michael A. Rothmier
L 1/16/1998
Alternate
AUT-SSI
UA Joint Apprenticeship Committee LU 669
1315 Berrytree Drive
Sugarland, TX 77479
United Assn. of Journeymen & Apprentices of the
Plumbing & Pipe Fitting Industry
Principal: Charles W. Ketner
Adam Seghi
Alternate
Coda Risk Analysis
9624 Vista View Drive
Austin, TX 78750
Principal: Lynn K. Underwood
Peter W. Thomas
Alternate
Victaulic Company
4901 Kesslersville Road
Easton, PA 18040-6714
Principal: Daniel P. Wake
Steven M. Tomlin
Alternate
Aon/Schirmer Engineering Corporation
335 Renfrew Drive, Suite 101
Markham, ON L3R 9S9 Canada
Principal: LeJay Slocum
Matthew J. Klaus
Staff Liaison
National Fire Protection Association
1 Batterymarch Park
Quincy, MA 02169-7471
Steven J. Scandaliato
Alternate
SDG, LLC
5961 North Mona Lisa Road
Tucson, AZ 85741
Principal: Robert G. Caputo
SE 10/03/2002
AUT-SSI
I 10/29/2012 Austin L. Smith
AUT-SSI Alternate
Babcock & Wilcox Y-12, LLC
PO Box 2009, MS 8107
Oak Ridge, TN 37831-8107
Principal: David S. Mowrer
U 3/1/2011
AUT-SSI
M 07/29/2013 Glenn E. Thompson
AUT-SSI Alternate
Liberty Mutual National Accounts Property
2959 Bighorn Drive
Corona, CA 92881-8770
Principal: Luke Hilton
I 10/27/2009 Barry M. Lee
AUT-SSI Nonvoting Member
Tyco International
16 Payten Street
Kogarah Bay, NSW 2217 Australia
I 10/27/2005
AUT-SSI
M 10/10/1997
AUT-SSI
12/16/2010
AUT-SSI
5
PART 3 –
NEW PROCESS WORKSHEETS
NEW PROCESS ACTIONS AND MOTIONS
Possible Action #1: Accept Public Comment (exactly as it is)
Action Required
Sample motion
Create a Second Revision
I move to create a Second Revision using PC #
______.
Possible action #2: Reject but see (revise submitted text)
Action Required
Sample motion
Step 1
Create a Second Revision based on a
Public Comment
I move to create a Second Revision based on PC
# _____with the following changes to the text . .
.
Step 2
If the revision is related to multiple PCs,
respond to all of them together using the
cart function
I move to create a Second Revision based on PC
# ____and incorporating PC #s _____with the
following changes to the text . . .
Possible action #3: Reject (no change to the standard)
Action Required
Sample motion
Generate a statement (substantiation)
I move to reject PC # ____ with the following
substantiation . . .
Possible Action #4: Reject but hold (new material)
Action Required
Sample motion
Reject Public Comment for this cycle, but
save for next revision cycle
I move to reject PC # ____ but hold it for
consideration during the First Draft meeting next
cycle.
PART 4 –
A2015 FIRST DRAFT MEETING
MINUTES
TC on Sprinkler System Installation Criteria
First Draft Meeting
Union Station Hotel
Nashville, Tennessee
August 20-22, 2013
Attendees:
See attached list of attendees.
1. Joe Noble (TC Chair) called the meeting to order at 8:00 am and began
introductions.
2. The A2012 ROC minutes were approved.
3. Matt Klaus gave the staff report and a presentation on the meeting procedures.
4. Joe Noble discussed the logistics for the meeting and the order of the task group
reporting.
5. The committee processed the public input that was included in the meeting
agenda. See the First Draft Report for the official actions on the public input and
the First Revisions created by the TC.
6. New Business: The TC discussed several topics that will be studied by task
groups prior to the Second Draft Meeting. These topics and assignments are as
follows:
i) Pipe Venting Task Group - The NFPA 13 CC has asked that this task group
look at the concept of “ganged venting” and whether or not the FD language
supports or prohibits this concept.
Will Smith – TG Leader
Lejay Slocum
Karl Wiegand
Dave Lowrey
Roland Asp
Dave Fuller
Mark Hopkins
ii) Galvanized Pipe Task Group – This task group will review the FD of NFPA
13 2016 ed. to make sure that all of the references to galvanized pipe are
consistent throughout.
Larry Keeping – TG Leader
Les Easter
Mark Hopkins
Will Smith
Dave Fuller
Russ Leavitt
iii) Cloud Ceiling Task Group – The Cloud Ceiling Task Group will meet via
telephone conference prior to the SD meeting to discuss revisions to the
proposed language regarding cloud ceilings and the associated definitions.
Dave Fuller – TG Leader
Robert Caput
Cecil Bilbo
Steve Scandaliato
Dave Lowrey
Roland Asp
Karl Wiegand
iv) The individual chapter task groups will also need to meet prior to the SD
meetings. This can be done over the phone or meeting space will be made
available on the day before the SSI SD meeting begins.
7. The Second Draft meeting is scheduled for Summer 2014 at a date and location to
be determined.
8. Meeting adjourned at 5:00 pm on August 22.
Attendees
Principals:
Joe Noble, Chair
Roland Asp
Weston Baker
Cecil Bilbo
Pat Brock
Robert Caputo
Donald Goosman
Luke Hilton
Brian Hoening
Elwin Joyce
Larry Keeping
Kenneth Linder
David Lowrey
Rodney McPhee
Michael Meehan
Thomas Noble
Peter Schwab
LeJay Slocum
William Smith
Zelijko Sucevic
Terry Victor
Daniel Wake
Alternates:
James Charrette
Scott Franson
David Fuller
Mark Hopkins
Russell Leavitt
Floyd Luinstra
Steven Scandaliato
Adam Seghi
Matthew Klaus, NFPA Staff Liaison
Guests:
Audrey Goldstein
Jon Hart
David Royse
Les Easter
John Eicheland
Karl Wiegand
Peter Thomas
PART 5 –
A2015 KEY DATES
2015 ANNUAL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at www.nfpa.org/document # (i.e. www.nfpa.org/101) and click on the Next Edition tab.
Process Stage Public Input Stage (First Draft) Comment Stage (Second Draft) Dates for TC Dates for
TC with CC Public Input Closing Date* Final Date for TC First Draft Meeting Posting of First Draft and TC Ballot Final date for Receipt of TC First Draft ballot Final date for Receipt of TC First Draft ballot ‐ recirc Posting of First Draft for CC Meeting Final date for CC First Draft Meeting Posting of First Draft and CC Ballot Final date for Receipt of CC First Draft ballot Final date for Receipt of CC First Draft ballot ‐ recirc Post First Draft Report for Public Comment 7/8/2013 12/13/2013 1/31/2014 7/21/2014 2/28/2014 3/7/2014 7/8/2013 9/13/2013 10/25/2013 11/15/2013 11/22/2013 11/29/2013 1/10/2014 1/31/2014 2/21/2014 2/28/2014 3/7/2014 Public Comment Closing Date for Paper Submittal* Public Comment Closing Date for Online Submittal (e‐PC)* Final Date to Publish Notice of Consent Documents (Standards that received no Comments) Appeal Closing Date for Consent Standards (Standards that received no Comments) Final date for TC Second Draft Meeting Posting of Second Draft and TC Ballot Final date for Receipt of TC Second Draft ballot Final date for receipt of TC Second Draft ballot ‐ recirc Posting of Second Draft for CC Meeting Final date for CC Second Draft Meeting Posting of Second Draft for CC Ballot Final date for Receipt of CC Second Draft ballot Final date for Receipt of CC Second Draft ballot ‐ recirc Post Second Draft Report for NITMAM Review 4/11/2014 5/16/2014 5/30/2014 4/11/2014 5/16/2014 5/30/2014 6/13/2014 6/13/2014 10/31/2014 12/12/2014 1/2/2015 1/9/2015 1/16/2015 7/25/2014 9/5/2014 9/26/2014 10/3/2014 10/10/2014 11/21/2014 12/12/2014 1/2/2015 1/9/2015 1/16/2015 3/6/2015 5/1/2015 3/6/2015 5/1/2015 5/16/2015 5/26/2015 5/16/2015 5/26/2015 6/22‐25/2016 6/22‐25/2016 7/15/2015 8/20/2015 7/15/2015 8/20/2015 Process Step Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date Preparation Posting of Certified Amending Motions (CAMs) and Consent Standards (& Issuance) Appeal Closing Date for Consent Standards SC Issuance Date for Consent Standards Tech Session Association Meeting for Standards with CAMs Appeals and Appeal Closing Date for Standards with CAMs Issuance SC Issuance Date for Standards with CAMs Approved___ October 18, 2011 _ Revised__March 7, 2013_____________ PART 6 –
PUBLIC COMMENTS
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Public Comment No. 188-NFPA 13-2014 [ Section No. 1.6 ]
1.6 Units and Symbols.
1.6.1 Units.
1.6.1.1
Metric units of measurement in this standard shall be in accordance with the modernized metric system
known as the International System of Units (SI).
1.6.1.2
Two units (liter and bar), outside of but recognized by SI, are commonly used in international fire
protection.
1.6.1.3
These units with conversion factors shall be used as listed in Table 1.6.1.3 .
Table 1.6.1.3 Conversion Factors
Name of Unit
Unit Symbol
liter
L
millimeter per minute
mm/min
Conversion Factor
1 gal = 3.785 L
2
1 gpm/ft = 40.746 mm/min =
40.746 (L/min)/m
3
2
3
cubic decimeter
dm
pascal
Pa
1 psi = 6894.757 Pa
bar
bar
1 psi = 0.0689 bar
bar
bar
5
1 bar = 10 Pa
1 gal = 3.785 dm
Note: For additional conversions and information, see ASTM SI 10, Standard for Use of the International
System of Units (SI): The Modern Metric System.
1.6.1.4
If a value for measurement as given in this standard is followed by an equivalent value in other units, the
first stated shall be regarded as the requirement.
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1.6.2 Hydraulic Symbols.
The standard abbreviations in Table 1.6.2 shall be used on the hydraulic calculation form discussed in
Chapter 23.
Table 1.6.2 Hydraulic Symbols
Symbol or
Abbreviation
Item
p
Pressure in psi
gpm
U.S. gallons per minute
q
Flow increment in gpm to be added at a specific location
Q
Summation of flow in gpm at a specific location
P
t
Total pressure in psi at a point in a pipe
P
f
Pressure loss due to friction between points indicated in location column
P
e
Pressure due to elevation difference between indicated points. This can be a plus
value or a minus value. If minus, the (-) shall be used; if plus, no sign is needed.
P
v
Velocity pressure in psi at a point in a pipe
P
n
Normal pressure in psi at a point in a pipe
E
90-degree ell
EE
45-degree ell
Lt.E
Long-turn elbow
Cr
Cross
T
Tee-flow turned 90 degrees
GV
Gate valve
BV
Butterfly (wafer) check valve
Del V
Deluge valve
ALV
Alarm valve
DPV
Dry pipe valve
CV
Swing check valve
WCV
Butterfly (wafer) check valve
St
Strainer
psi
Pounds per square inch
v
Velocity of water in pipe in feet per second
K
K-factor
C-factor
Friction loss coefficient
Statement of Problem and Substantiation for Public Comment
CC NOTE: The following CC Note No. 1 appeared in the First Draft Report.
The 2016 edition is moving to a soft conversion approach for metric conversions. The "metric conversion task
group" must look at section 1.6 and provide guidance to the users on the conversion rules and how the
conversions are being made. The metric conversion task group must review the entire first draft and provide the
metric conversion for each of the values in the standard (including tables and figures). Since soft conversions are
being used, the hard conversion table in section 1.6 should be removed so that it does not provide confusion
allowing people start mix and match soft and hard conversions. The methodology used for making the conversions
should be added to the annex, with examples.
Related Item
Correlating Committee Note No. 1-NFPA 13-2013 [Section No. 1.6]
Submitter Information Verification
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Submitter Full Name: CC on AUT-AAC
Organization:
CC on Automatic Sprinkler Systems
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Apr 29 13:43:05 EDT 2014
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Public Comment No. 149-NFPA 13-2014 [ Section No. 2.3.4 ]
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2.3.4 ASTM Publications.
ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.
ANSI/ASTM A 53, Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and
Seamless, 2001.
ASTM A 106, Standard Specification for Seamless Carbon Steel Pipe for High Temperature Service, 2008.
ASTM A 135, Standard Specification for Electric-Resistance-Welded Steel Pipe, 2001.
ASTM A 153A/153M, Standard Specification for Zinc Coating (Hot Dip) on Iron and Steel Hardware, 2004.
ASTM A 234, Standard Specification for Piping Fittings of Wrought-Carbon Steel and Alloy Steel for
Moderate and High Temperature Service, 2001.
ASTM A 795, Standard Specification for Black and Hot-Dipped Zinc-Coated (Galvanized) Welded and
Seamless Steel Pipe for Fire Protection Use, 2000.
ASTM B 16.15, Cast Bronze Threaded Fittings, 1985.
ASTM B 32, Standard Specification for Solder Metal, 2000.
ASTM B 43, Specification for Seamless Red Brass Pipe, 2009.
ASTM B 75, Standard Specification for Seamless Copper Tube, 1999.
ASTM B 88, Standard Specification for Seamless Copper Water Tube, 1999.
ASTM B 251, Standard Specification for General Requirements for Wrought Seamless Copper and
Copper-Alloy Tube, 1997.
ASTM B 446, Standard Specification for Nickel-Chromium-Molybdenum-Columbium Alloy (UNSN 06625)
and Nickel-Chromium-Molybdenum-Silicon Alloy (UNSN 06219) Rod and Bar, 2000.
ASTM B 813, Standard Specification for Liquid and Paste Fluxes for Soldering Applications of Copper and
Copper-Alloy Tube, 2000.
ASTM B 828, Standard Practice for Making Capillary Joints by Soldering of Copper and Copper Alloy Tube
and Fittings, 2000.
ASTM C 635, Standard Specification for the Manufacture, Performance, and Testing of Metal Suspension
Systems for Acoustical Tile and Lay-In Panel Ceilings, 2012.
ASTM C 636, Standard Practice for Installation of Metal Ceiling Suspension Systems for Acoustical Tile
and Lay-In Panels, 2008.
ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2010 2014 .
ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials, 2010 2012a .
ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750°C,
1999 2012 .
ASTM F 437, Standard Specification for Threaded Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe
Fittings, Schedule 80, 1999.
ASTM F 438, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe
Fittings, Schedule 40, 2001.
ASTM F 439, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe
Fittings, Schedule 80, 2001.
ASTM F 442, Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe (SDR-PR),
2009.
ASTM F 1121, Standard Specification for International Shore Connections for Marine Fire Applications,
1998.
ASTM SI 10, Standard for Use of the International System of Units (SI): The Modern Metric System, 1997.
Statement of Problem and Substantiation for Public Comment
standards date updates - the public input related to this was not found but the ASTM fire standards are out of date
Related Item
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Public Input No. 1-NFPA 13-2013 [Section No. 11.3.1.1]
Submitter Information Verification
Submitter Full Name: Marcelo Hirschler
Organization:
GBH International
Street Address:
City:
State:
Zip:
Submittal Date:
Sun Apr 27 16:27:02 EDT 2014
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Public Comment No. 271-NFPA 13-2014 [ Section No. 2.3.4 ]
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2.3.4 ASTM Publications.
ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.
ANSI/ASTM A 53/A 53M , Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated,
Welded and Seamless, 2001 2012 .
ASTM A 106/A106M , Standard Specification for Seamless Carbon Steel Pipe for High Temperature
Service, 2008 2013 .
ASTM A 135/A 135M , Standard Specification for Electric-Resistance-Welded Steel Pipe,
2001 2009(2014) .
ASTM A 153A/153M, Standard Specification for Zinc Coating (Hot Dip) on Iron and Steel Hardware,
2004 2009 .
ASTM A 234/A234M , Standard Specification for Piping Fittings of Wrought-Carbon Steel and Alloy Steel
for Moderate and High Temperature Service, 2001 2013e1 .
ASTM A 795/A 795M , Standard Specification for Black and Hot-Dipped Zinc-Coated (Galvanized) Welded
and Seamless Steel Pipe for Fire Protection Use, 2000 201300 .
ASTM B 16.15, Cast Bronze Threaded Fittings, 1985.
ASTM B 32, Standard Specification for Solder Metal, 2000 2008 .
ASTM B 43, Specification for Seamless Red Brass Pipe, 2009.
ASTM B 75, Standard Specification for Seamless Copper Tube, 1999 2011 .
ASTM B 88, Standard Specification for Seamless Copper Water Tube, 1999 2009 .
ASTM B 251, Standard Specification for General Requirements for Wrought Seamless Copper and
Copper-Alloy Tube, 1997 2010 .
ASTM B 446, Standard Specification for Nickel-Chromium-Molybdenum-Columbium Alloy (UNSN 06625)
and Nickel-Chromium-Molybdenum-Silicon Alloy (UNSN 06219) Rod and Bar, 2000 2003(2008)e1 .
ASTM B 813, Standard Specification for Liquid and Paste Fluxes for Soldering Applications of Copper and
Copper-Alloy Tube, 2000 2010 .
ASTM B 828, Standard Practice for Making Capillary Joints by Soldering of Copper and Copper Alloy Tube
and Fittings, 2000 02(2010) .
ASTM C 635, Standard Specification for the Manufacture, Performance, and Testing of Metal Suspension
Systems for Acoustical Tile and Lay-In Panel Ceilings, 2012 2013a12 .
ASTM C 636, Standard Practice for Installation of Metal Ceiling Suspension Systems for Acoustical Tile
and Lay-In Panels, 2008 2013 .
ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2010 2014 .
ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials, 2010 2012a .
ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750°C,
1999 2012 .
ASTM F 437, Standard Specification for Threaded Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe
Fittings, Schedule 80, 1999 2009 .
ASTM F 438, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe
Fittings, Schedule 40, 2001 2009 .
ASTM F 439, Standard Specification for Socket-Type Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe
Fittings, Schedule 80, 2001 2013 .
ASTM F 442/F 442M , Standard Specification for Chlorinated Poly (Vinyl Chloride) (CPVC) Plastic Pipe
(SDR-PR), 2009 2013e1 .
ASTM F 1121, Standard Specification for International Shore Connections for Marine Fire Applications,
1998 87(2010) .
ASTM SI 10, Standard for Use of the International System of Units (SI): The Modern Metric System,
1997 2010 .
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Statement of Problem and Substantiation for Public Comment
Updating year dates
Related Item
First Revision No. 271-NFPA 13-2013 [Section No. 6.4]
Submitter Information Verification
Submitter Full Name: Steve Mawn
Organization:
ASTM International
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 15 14:33:09 EDT 2014
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Public Comment No. 371-NFPA 13-2014 [ New Section after 3.3.6 ]
3.3.6.2 Small Openings. Openings in the ceiling or construction features of a concealed
space that allow limited amounts of heat to enter the concealed space. Small openings
with any dimension greater than 4 feet may not have a least dimension greater than 8
inches. Small openings may not have a combined total area of more than 20% of the
ceiling, construction feature, or plane used to determine the boundaries of the concealed
space.
A.3.3.6.2 A return air diffuser may be 4 feet by 2 feet and meet the definition of a small
opening. A linear diffuser may be longer than 4 feet but is then limited to 8 inches in
width (or least dimension). Spaces between ceiling panels of architectural features that
create a concealed space must meet the same criteria.
Statement of Problem and Substantiation for Public Comment
Cloud Ceiling Task Group language.
Related Item
Committee Input No. 166-NFPA 13-2013 [Global Input]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Academy of Fire Sprinkler Tech
Street Address:
City:
State:
Zip:
Submittal Date:
Tue May 20 14:54:53 EDT 2014
Copyright Assignment
I, Cecil Bilbo, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full
rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and
Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication
of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I
am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment.
By checking this box I affirm that I am Cecil Bilbo, and I agree to be legally bound by the above Copyright
Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am
creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a
handwritten signature
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Public Comment No. 365-NFPA 13-2014 [ New Section after 3.3.7 ]
3.3.6.1 Concealed Space. An area of or space within a building that is not accessible for storage
purposes and is not normally occupied by people but could be entered occasionally for brief
periods. The space shall be considered a concealed space even with small openings as defined in
3.3.6.2.
A.3.3.6.1 The concealed space most commonly referred to in this context is the space above a
ceiling.
This definition should not be limited to these spaces. Concealed spaces can be found inside
buildings between rooms and between ceilings and floors. They can also be found outside
buildings in eaves and overhangs.
Statement of Problem and Substantiation for Public Comment
The space of 1” should not be part of the definition and this language has been discussed by the Cloud Ceiling
Task Group.
Related Item
First Revision No. 76-NFPA 13-2013 [New Section after 3.3.6]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Academy of Fire Sprinkler Tech
Street Address:
City:
State:
Zip:
Submittal Date:
Mon May 19 11:13:27 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 116-NFPA 13-2014 [ Section No. 3.3.7 ]
3.3.7 Concealed Space.
That portion (s) of a building behind walls, over suspended ceilings, in pipe chases and attics, and whose
size might normally range from 1 in. (44.45 mm) stud spaces and up to 8 ft (2.44 m) interstitial floor truss
spaces and that might contain combustible materials such as building structural members, thermal and/or
electrical insulation, and ducting.
Statement of Problem and Substantiation for Public Comment
The current definition could be misinterpreted to limit attic spaces to 8'-0" max.
Related Item
First Revision No. 76-NFPA 13-2013 [New Section after 3.3.6]
Submitter Information Verification
Submitter Full Name: Peter Schwab
Organization:
Wayne Automatic Fire Sprinkler
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 18 09:56:12 EDT 2014
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Public Comment No. 133-NFPA 13-2014 [ Section No. 3.3.7 ]
Reconsider and do not accept the proposed definition. Delete the proposed Section 3.3.7
Concealed Space.
That portion (s) of a building behind walls, over suspended ceilings, in pipe chases and attics, and whose
size might normally range from 1 in. (44.45 mm) stud spaces to 8 ft (2.44 m) interstitial truss spaces and
that might contain combustible materials such as building structural members, thermal and/or electrical
insulation, and ducting.
in its entirety:
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_3-3-7.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
A definition for a concealed space should not contain dimensions or construction features, for example, many attic
spaces can be higher than 8 ft to the peak. Those same AHJ's who did not consider an attic to be a concealed
space could just as easily say that a 10 ft interstitial space would not be a concealed space either.
Related Item
Public Input No. 136-NFPA 13-2013 [New Section after 3.3.6]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 13:46:50 EDT 2014
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Public Comment No. 267-NFPA 13-2014 [ Section No. 3.3.7 ]
3.3.7 Concealed Space.
That portion (s) of a building behind walls, over suspended ceilings, in pipe chases and attics, and whose
size might normally range from 1 in. (44.45 mm) stud spaces to 8 ft (2.44 m) interstitial truss spaces and
that might contain combustible materials such as building structural members, thermal and/or electrical
insulation, and ducting.
Statement of Problem and Substantiation for Public Comment
NFPA's Building Code Development Committee (BCDC) suggests to delete the new definition in Section 3.3.7,
from FR 76. The definition adds confusion to the AHJ. This standard has worked well without the definition. As
the negatie comment by Mr. Meehan points out, the standard already specifies where omissions are allowed. The
definition as proposed introduces a laundry list that is limiting. The definition also introduces dimensions that are
limiting. Ultimately, this is less useful to the AHJ in applying the omissions in Section 8.15.1.2. Section 3.1
indicates that terms not defined shall use their ordinarily accepted meaning, which suffices. Note that NFPA 96
only uses the term “concealed spaces” once, and its application is for lighting units on commercial cooking hoods.
This is a very narrow scope for the application of this definition. This definition does not seem to be applicable for
sprinkler requirements.
Related Item
First Revision No. 76-NFPA 13-2013 [New Section after 3.3.6]
Submitter Information Verification
Submitter Full Name: Jim Muir
Organization:
Building Safety Division, Clark County Washington
Affilliation:
NFPA's Building Code Development Committee (BCDC)
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 15 11:58:12 EDT 2014
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Public Comment No. 338-NFPA 13-2014 [ Section No. 3.3.7 ]
3.3.7 Concealed Space.
That portion (s) of a building behind walls, over suspended ceilings, in pipe chases and attics, and whose
size might normally range from 1 in. (44.45 mm) stud spaces to 8 ft (2.44 m) interstitial truss spaces and
that might contain combustible materials such as building structural members, thermal and/or electrical
insulation, and ducting
An area with limited or no access, not intended for building occupant use or storage, that is enclosed on all
sides with 4% of the area of one side allowed to be open .
Statement of Problem and Substantiation for Public Comment
There are three concerns with the proposed language:
1) The language is unenforceable. It talks about the fact that the height of the space "might" be in a certain range
and that certain things "might" be in the space. We should not be using such language in a definition.
2) The definition is too focused on the space above a drop ceiling and not the hundreds of other concealed spaces
in a building such as the vertical spaces within wall stud cavities, crawl spaces, attics, soffits, etc.
3) There is no mention of the space being surrounded in order to be considered "concealed". The space is being
defined as "concealed" if it is above a drop ceiling. What about non-continuous drop ceilings? Those spaces
would be considered concealed, which is not the intent of the standard.
Our proposed definition solves these problems by forcing the space to be surrounded in order to be considered
"concealed". The 4% opening limitation comes from the statement in section 8.15.1.2.1.1 that allows "small
openings such as those used as return air for a plenum. Such openings tend to be 2 ft x 2 ft in a ceiling grid and
tend to occur about every 100 sq ft, which puts them at about 4% of the area of one side of the concealed space.
Related Item
First Revision No. 76-NFPA 13-2013 [New Section after 3.3.6]
Submitter Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 14:20:22 EDT 2014
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Public Comment No. 269-NFPA 13-2014 [ Section No. 3.4.1 [Excluding any
Sub-Sections] ]
A wet pipe system using automatic sprinklers that contains a liquid solution to prevent freezing of the
system, intended to discharge the solution upon sprinkler operation, followed immediately by water from a
water supply .
Statement of Problem and Substantiation for Public Comment
The statement "followed by water"is redundant should be deleted.
Related Item
Public Input No. 56-NFPA 13-2013 [Section No. A.23.3.2]
Submitter Information Verification
Submitter Full Name: Phillip Brown
Organization:
American Fire Sprinkler Associ
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 15 13:11:58 EDT 2014
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Public Comment No. 237-NFPA 13-2014 [ Section No. 3.5.13 ]
3.5.13 System Riser.
The aboveground horizontal or vertical pipe between the water supply and the mains (cross or feed) that
contains a control valve (either directly or within its supply pipe), pressure gauge,main drain, and a
waterflow alarm device.
Statement of Problem and Substantiation for Public Comment
Editorial change
Related Item
Public Input No. 487-NFPA 13-2013 [Section No. 3.3.22]
Submitter Information Verification
Submitter Full Name: Phillip Brown
Organization:
American Fire Sprinkler Associ
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 09 12:19:48 EDT 2014
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Public Comment No. 344-NFPA 13-2014 [ New Section after 6.1.1.6 ]
Pre-Engineered Systems.
Where listed pre-engineered systems are installed, they shall be installed within the limitations that have been
established by the testing laboratories.
Statement of Problem and Substantiation for Public Comment
Currently NFPA 13D allows pre-engineered systems to be installed as an acceptable alternative. Under the
definition of pre-engineered, the systems must have been successfully tested to the appropriate hazard. Allowing
alternate systems and new technologies through sections 1.4 and 1.6 of this standard, requires engineering proof
that the alternative is equal or better protection than what is in the standard. Often obtaining engineering support
or approval can be difficult and expensive. This would open it up to being approved under standard review from
an engineer or authority having jurisdiction. I also believe that this is also a correlating issue from 13D.
Related Item
Public Input No. 441-NFPA 13-2013 [Section No. 6.1.1.6]
Submitter Information Verification
Submitter Full Name: Daniel Wake
Organization:
Victaulic Company
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 14:34:49 EDT 2014
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Public Comment No. 136-NFPA 13-2014 [ Section No. 6.2.1.1 ]
6.2.1. 1 * 1
When a sprinkler is removed from a fitting or welded outlet, it shall not be reinstalled except as permitted
by 6 . 2.1.1.1.
6.2.1.1.1 *
Dry sprinklers shall be permitted to be reinstalled where they are not removed by applying torque at the
point where the sprinkler is attached to the barrel.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_6-2-1-1.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
The idea of removing a sprinkler and thinking that it won't be damaged is a fallacy. There are more ways to
damage a sprinkler than by torque. Handling and storage is the critical issue. The need for caps and straps on
new sprinklers came from damage during the handling of sprinklers from right out of the manufactures cartons, so
it is not possible to assure similar damage won't occur to a dry pendent sprinkler that is removed from its installed
location. See the images below as examples:
See uploaded file for Figures
Related Item
First Revision No. 66-NFPA 13-2013 [Section No. 6.2.1.1]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 13:56:42 EDT 2014
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Public Comment No. 352-NFPA 13-2014 [ New Section after 6.3.2 ]
(NEW SECTION 6.3.2 ) Electric Resistance Welding. Horizontal pipe that is joined by welds
with electric resistance methods shall be installed with the seam at the top of the pipe.
Type your content here ...
Additional Proposed Changes
File Name
Description Ap
To support
Mr. King's
original
proposal, a
13-30_NFPA_13_FMDS0200_University_of_Michigan_David_King_data_from_Factory_Mutual_for_6.3.2-5.pdf Data Sheet
from FM
Global is
attached
herewith.
Statement of Problem and Substantiation for Public Comment
Please accept Mr. King's original proposal. See supporting documentation. Alternatively, it could be installed as
part of an Annex.
Related Item
Public Input No. 556-NFPA 13-2013 [Sections 6.3.2, 6.3.3]
Submitter Information Verification
Submitter Full Name: Michael Anthony
Organization:
University of Michigan
Affilliation:
University of Michigan
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 15:40:46 EDT 2014
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Public Comment No. 190-NFPA 13-2014 [ Section No. 6.3.7 ]
6.3.7* Nonmetallic Pipe.
Nonmetallic pipe in accordance with Table 6.3.1.1 shall be investigated for suitability in automatic
sprinkler installations and listed for this service.
6.3.7.1
Listed nonmetallic pipe shall be installed in accordance with its listing limitations, including installation
instructions.
6.3.7.1.1
Manufacturer's installation instructions shall include its listing limitations.
6.3.7.2
When nonmetallic pipe is used in systems utilizing steel piping internally coated with corrosion inhibitors,
the steel pipe coating shall be listed for compatibility with the nonmetallic pipe materials.
6.3.7.3
When nonmetallic pipe is used in systems utilizing steel pipe that is not internally coated with corrosion
inhibitors, no additional evaluations shall be required.
6.3.7.4*
When nonmetallic pipe is used in systems utilizing steel pipe, cutting oils and lubricants used for
fabrication of the steel piping shall be compatible with the nonmetallic pipe materials in accordance with
6.1.1.6.
6.3.7.5
Fire-stopping materials intended for use on nonmetallic piping penetrations shall be compatible with the
nonmetallic pipe materials in accordance with 6.1.1.6.
6.3.7.6
Nonmetallic pipe listed for light hazard occupancies shall be permitted to be installed in ordinary hazard
2
2
rooms of otherwise light hazard occupancies where the room does not exceed 400 ft (37 m ).
6.3.7.7
Nonmetallic pipe shall not be listed for portions of an occupancy classification.
6.3.7.8* Listed Pipe and Tubing.
6.3.7.8.1
Other types of pipe or tube investigated for suitability in automatic sprinkler installations and listed for this
service, including but not limited to CPVC and steel, and differing from that provided in Table 6.3.1.1 shall
be permitted where installed in accordance with their listing limitations, including installation instructions.
6.3.7.8.2
Pipe or tube listed for light hazard occupancies shall be permitted to be installed in ordinary hazard rooms
2
2
of otherwise light hazard occupancies where the room does not exceed 400 ft (37 m ).
6.3.7.8.2.1
Pipe or tube installed in accordance with 6.3.7.8.2 shall be permitted to be installed exposed, in
accordance with the listing.
6.3.7.8.3
Pipe or tube shall not be listed for portions of an occupancy classification.
6.3.7.8.4
Bending of listed pipe and tubing shall be permitted as allowed by the listing.
6.3.7.9 Pipe and Tube Bending.
6.3.7.9.1
Bending of Schedule 10 steel pipe, or any steel pipe of wall thickness equal to or greater than Schedule 10
and Types K and L copper tube, shall be permitted when bends are made with no kinks, ripples,
distortions, or reductions in diameter or any noticeable deviations from round.
6.3.7.9.2
For Schedule 40 and copper tubing, the minimum radius of a bend shall be six pipe diameters for pipe
sizes 2 in. (50 mm) and smaller and five pipe diameters for pipe sizes 21⁄2 in. (65 mm) and larger.
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6.3.7.9.3
For all other steel pipe, the minimum radius of a bend shall be 12 pipe diameters for all sizes.
6.3.7.9.4
Bending of listed pipe and tubing shall be permitted as allowed by the listing.
6.3.7.10 Pipe and Tube Identification.
6.3.7.10.1*
All pipe, including specially listed pipe allowed by 6.3.7.8, shall be marked along its length by the
manufacturer in such a way as to properly identify the type of pipe.
6.3.7.10.2
The marking shall be visible on every piece of pipe over 2 ft (610 mm) long.
6.3.7.10.3
Pipe identification shall include the manufacturer's name, model designation, or schedule.
Statement of Problem and Substantiation for Public Comment
CC NOTE: The following CC Note No. 3 appeared in the First Draft Report as First Revision No. 270.
The non-metallic pipe compatibility task group needs to review NFPA 13 and 13R to resolve the differences
between these standards. This is a material issue that needs to be consistent in both standards.
Related Item
First Revision No. 270-NFPA 13-2013 [Section No. 6.3.7]
Submitter Information Verification
Submitter Full Name: CC on AUT-AAC
Organization:
CC on Automatic Sprinkler Systems
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Apr 29 13:53:16 EDT 2014
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Public Comment No. 240-NFPA 13-2014 [ Section No. 6.3.7.6 ]
6.3.7.6
Nonmetallic pipe listed for light hazard occupancies shall be permitted to be installed exposed in ordinary
2
2
hazard rooms of otherwise light hazard occupancies where the room does not exceed 400 ft (37 m ).
Statement of Problem and Substantiation for Public Comment
Clarification needs to be made that nonmetallic pipe can be ran exposed.
Related Item
Public Input No. 233-NFPA 13-2013 [Section No. 6.1.1.2]
Submitter Information Verification
Submitter Full Name: Phillip Brown
Organization:
American Fire Sprinkler Associ
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 09 12:56:51 EDT 2014
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Public Comment No. 11-NFPA 13-2014 [ New Section after 6.4.8 ]
Add new Annex.
Consideration of compatibility should be provided when connecting dissimilar materials, like brass
extension fittings and copper piping systems.
Statement of Problem and Substantiation for Public Comment
Certain brass alloys have been known to corrodes from dezincification—a phenomenon where zinc is dissolved
out of brass. This is more common in stagnant water systems connected to a copper piping network.
Dezincification can cause leakage or failures in the fitting.
Related Item
First Revision No. 60-NFPA 13-2013 [New Section after 6.4.7.4]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 11 14:21:37 EDT 2014
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Public Comment No. 117-NFPA 13-2014 [ Section No. 6.4.8 ]
6.4.8 Extension Fitting.
6.4.8.1
The outlet diameter of the extension fitting shall be equal to the inlet diameter of the sprinkler.
6.4.8.2
A single extension fitting up to a maximum of 2 in. (50 mm) in length shall be permitted to be installed with
a sprinkler.
6.4.8.2.1
The extension fitting shall be Extension fittings longer than 2 in. (50 mm) shall be listed.
6.4.8.2.1.1
Extension fittings longer than 2 in (50 mm) shall be included in the hydraulic calculations.
6.4.8.2. 1. 2
The requirement of 6.4.8.2.1.1 shall not apply where the sprinkler is listed for use with the extension
nipple.
Statement of Problem and Substantiation for Public Comment
Testing has been performed on sprinkler extensions and it has been proven that up to 2" extensions do not impact
the K Factor of the attached sprinkler beyond the ranges found in Table 6.2.3.1. Greater than 2" in length should
be listed and included in the hydraulic calculations.
Related Item
First Revision No. 60-NFPA 13-2013 [New Section after 6.4.7.4]
Submitter Information Verification
Submitter Full Name: Peter Schwab
Organization:
Wayne Automatic Fire Sprinkler
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 18 11:02:43 EDT 2014
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Public Comment No. 366-NFPA 13-2014 [ Section No. 6.4.8.1 ]
6.4.8.1
The outlet diameter of the extension fitting shall be equal to or greater than the inlet diameter of the
sprinkler.
Statement of Problem and Substantiation for Public Comment
None given.
Related Item
First Revision No. 60-NFPA 13-2013 [New Section after 6.4.7.4]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Academy of Fire Sprinkler Tech
Street Address:
City:
State:
Zip:
Submittal Date:
Mon May 19 12:31:59 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 12-NFPA 13-2014 [ Section No. 6.4.8.2.1 ]
6.4.8.2.1
The extension fitting shall not be included in the hydraulic calculations.
Statement of Problem and Substantiation for Public Comment
NFPA 13 23.4.4.7.1 (9) allows the friction loss for the fitting directly connected to a sprinkler to be excluded from
the hydraulic calculation. The fitting (tee, 90 or deducing coupling) that the extension fittings piece is attached
should be included. If an extension fitting is added after hydraulic calculations have been performed, calculations
should be redone adding in the friction loss at each tee, 90, or reducing coupling that was originally omitted.
Related Item
First Revision No. 60-NFPA 13-2013 [New Section after 6.4.7.4]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 11 14:25:18 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 137-NFPA 13-2014 [ Sections 6.4.8.2.1, 6.4.8.2.2 ]
Sections 6.4.8.2.1, 6.4.8.2.2
6.4.8.2.1
The extension fitting shall be included in the hydraulic calculations.
6.4.8.2.2
The requirement of 6.4.8.2.1 shall not apply where the sprinkler is listed for use with the extension nipple.
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_6-4-8-2-1.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The requirement for hydraulic calculations is not necessary or practical. It is not needed because as per
23.4.4.7.1(9), friction loss can be excluded for the fitting directly connected to the sprinkler. It is not practical
because no equivalent lengths have been provided for extension fittings. Also, these devices are often been
referred to as "cheaters" because they are usually employed on site, as a stop gap, to make up for a short pipe
length or other site condition, that was not contemplated during the design stages, when the hydraulic calculations
were prepared.
Related Item
First Revision No. 60-NFPA 13-2013 [New Section after 6.4.7.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:01:21 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 268-NFPA 13-2014 [ Section No. 6.6.3 ]
6.6.3 Drain Valves and , Test Valves and Vent Valves .
Drain valves and , test valves shall and vent valves shall be approved.
6.6.3.1 Automatic air vents shall be listed.
Statement of Problem and Substantiation for Public Comment
The Technical Committee says that trapped air doesn’t affect the operation of the system. NFPA’s Building Code
Development Committee (BCDC) disagrees. Operation of a sprinkler system would seem to mean more than just
will it hold water or will the water flow through it. Problems experienced even during non-operational periods seem
to have a negative impact on the system. The problems listed in the substantiation for Public Input #241 seem to
be problems that would affect operation.
Related Item
Public Input No. 241-NFPA 13-2013 [Section No. 6.7.3]
Submitter Information Verification
Submitter Full Name: Jim Muir
Organization:
Building Safety Division, Clark County Washington
Affilliation:
NFPA's Building Code Development Committee (BCDC)
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 15 12:11:42 EDT 2014
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Public Comment No. 114-NFPA 13-2014 [ New Section after 6.7.3 ]
6.7.4 Fire department connections shall have an approved method to deter unauthorized removal
of the FDC.
Statement of Problem and Substantiation for Public Comment
NFPA 13 is a design and installation standard and as such does address the security, protection, and assurance
that the various components of required sprinkler systems will function properly when needed. This is seen in
various sections including:
•
Section 6.2.8 “Sprinklers subject to mechanical injury shall be protected with listed guards”,
•
Section 6.7.2 requiring approved plugs and caps to protect fire department connections from blockage and
debris,
•
Section 6.2.6.4.1 “Sprinklers protecting spray areas and mixing rooms in resin application areas shall be
protected against overspray residue so that they will operate in the event of fire”.
In order to assure that fire department connections are present and operate properly in the event of fire they must
be protected from theft or any unauthorized removal. Since the FDC is located outside of the protected structure
they are more susceptible to theft than any other component. Theft of FDC’s has and is occurring nationwide and
many times goes undetected until a fire when the fire department discovers they cannot pump into the system.
This new section 6.7.4 would allow the AHJ to approve different methods of deterring unauthorized removal of the
FDC ranging from the use of locking methods to warning signage.
Related Item
Public Input No. 108-NFPA 13-2013 [New Section after 6.8.3]
Submitter Information Verification
Submitter Full Name: Bill Galloway
Organization:
Southern Regional Fire Code De
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Apr 17 12:50:48 EDT 2014
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Public Comment No. 118-NFPA 13-2014 [ Section No. 7.1.5 ]
7.1.5 Air Venting.
A single, air vent with a connection shall be provided on each wet pipe system utilizing black or galvanized
steel pipe as a means for venting.
Statement of Problem and Substantiation for Public Comment
There is no guidance on where this vent is to be installed, The purpose of venting is to reduce corrosion. Not all
areas have shown issues with corrosion. The use of vents should be prescribed by the Engineer of Record or as
required by the owner.
Related Item
First Revision No. 278-NFPA 13-2013 [New Section after 7.1.4]
Submitter Information Verification
Submitter Full Name: Peter Schwab
Organization:
Wayne Automatic Fire Sprinkler
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 18 11:34:19 EDT 2014
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Public Comment No. 138-NFPA 13-2014 [ Section No. 7.1.5 ]
7.1.5 Air Venting.
A single, air vent with a connection connection conforming to 8.16.6 shall be provided on each wet pipe
system utilizing black or galvanized steel pipe as a means for venting. (See A.8.16.4.2.2).
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_7-1-5.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
Revised for clarity – as it has currently been proposed, the term “air vent with a connection” does not describe the
intent sufficiently. The reference to A.8.16.4.2.2 was added to direct the users of the standard to the place in the
Annex where the purpose of the air vent is explained.
Related Item
First Revision No. 278-NFPA 13-2013 [New Section after 7.1.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:02:42 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 216-NFPA 13-2014 [ Section No. 7.1.5 ]
7.1.5 Air Venting.
A single, air vent with a connection shall be provided on each wet pipe system utilizing black or galvanized
steel pipe as a means for venting.
Statement of Problem and Substantiation for Public Comment
This new section requiring air venting may cause unintended consequences. Some air in the sprinkler system is a
positive thing. It acts as a cushion to pressure surges. Air is compressible, water is not. The more air we take out
of sprinkler systems, the more problems we are going to have with pressure changes blowing apart systems,
pegging gages, and causing other damage. Air acts as a cushion to deal with transient pressure surges. As we
remove more air out of the sprinkler systems, we will have bigger problems with pressure and water hammer.
Additional comments have been made to remove language for air venting from section 8.16.6, and 25.6.2. The
Annex note A.8.16.4.2.2 (2013 edition) is to be preserved as it contains valuable information when air venting is
deemed to be warranted.
Related Item
First Revision No. 278-NFPA 13-2013 [New Section after 7.1.4]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Wed May 07 09:58:54 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 367-NFPA 13-2014 [ Section No. 7.1.5 ]
7.1.5 Air Venting.
A single, air vent with a connection shall be provided on each wet pipe system utilizing black or galvanized
steel pipe as a means for venting.
Statement of Problem and Substantiation for Public Comment
All systems should not require air venting.
Related Item
First Revision No. 278-NFPA 13-2013 [New Section after 7.1.4]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Academy of Fire Sprinkler Tech
Street Address:
City:
State:
Zip:
Submittal Date:
Mon May 19 12:39:54 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 354-NFPA 13-2014 [ Section No. 7.2.5.4.2 ]
7.2.5.4.2 Low Differential Dry Pipe Valve.
Protection against accumulation of water above the clapper shall be provided for low differential dry pipe
valves in accordance with 7.2.5.4.3 .
Statement of Problem and Substantiation for Public Comment
This requirement does not make sense. It takes less water pressure to lift the clapper with a water column in a low
differential DPV than one with a higher differential. Any valve that is subject to a water column should have high
level protection.
Related Item
Public Input No. 235-NFPA 13-2013 [Section No. 7.2.5.4.3]
Submitter Information Verification
Submitter Full Name: Peter Thomas
Organization:
Victaulic Company
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 15:56:54 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 359-NFPA 13-2014 [ Section No. 7.2.5.4.2 ]
7.2.5.4.2 Low Differential Dry Pipe Valve.
Protection against accumulation of water above the clapper shall be provided for low differential dry pipe
valves in accordance with 7.2.5.4.3 .
Statement of Problem and Substantiation for Public Comment
A water column should be prevented for any type of dry valve. Paragraph 7.2.5.4.1 adequately covers the intent.
What is the definition of a low differential valve? It is not found in the definitions so why have a section referring to
something that is not defined.
Related Item
Public Input No. 433-NFPA 13-2013 [Section No. 7.2.5.4.2]
Submitter Information Verification
Submitter Full Name: Daniel Wake
Organization:
Victaulic Company
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 16:46:03 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 119-NFPA 13-2014 [ Section No. 7.2.6.6.3.1 ]
7.2.6.6.3.1
Each dry pipe system shall have an air a dedicated air maintenance device.
Statement of Problem and Substantiation for Public Comment
Changed the language to further clarify that each dry pipe valve/system needs to have its own dedicated AMD.
Related Item
First Revision No. 62-NFPA 13-2013 [Section No. 7.2.6.6.3]
Submitter Information Verification
Submitter Full Name: Peter Schwab
Organization:
Wayne Automatic Fire Sprinkler
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 18 13:04:34 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 139-NFPA 13-2014 [ Section No. 7.6.3.4 ]
Reconsider the proposal and return Figure 7.6.3.4 to that of the 2013 edition of NFPA 13.
7.6.3.4
A listed 1⁄2 in. (12 mm) relief valve shall be permitted in lieu of the expansion chamber required in 7.6.3.3,
and as illustrated in Figure 7.6.3.4 , provided the antifreeze system volume does not exceed 40 gal (151 L).
Figure 7.6.3.4 Arrangement of Supply Piping with Relief Valve and Backflow Device.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_7-6-3-4.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
The additional indicating control valve is not needed for this antifreeze loop configuration. In Figure 7.6.3.3 the
control valve is needed to avoid the mixing of water and antifreeze solution during a forward flow test, because the
piping is basically all on the same plane. In Figure 7.6.3.4 however, the loop separates the (lighter) water from the
(heavier) antifreeze solution, so the backflow preventer and the test valve do not need to be isolated from the
downstream piping. Also, the additional flow test valve is not needed. The antifreeze loop has a test valve “A” at
the water/antifreeze interface that can be sized and utilized for the purpose.
Related Item
First Revision No. 63-NFPA 13-2013 [Section No. 7.6.3.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
5/19/2014 1:50 PM
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Public Comment No. 225-NFPA 13-2014 [ Section No. 8.2.4.1 ]
8.2.4.1 *
Multistory buildings exceeding two stories in height shall be provided with a floor control valve, check valve,
main drain valve, and flow switch for isolation, control, and annunciation of water flow on flow for each
floor level.
Statement of Problem and Substantiation for Public Comment
This proposed change of "on each floor level" to "for each floor level" would allow the required floor control valve
assemblies to be located on a level remote from the level being served. It is, at times, more practical to locate all
sprinkler equipment in a central location such as a riser room or another area remote from the floor being served.
This comment will not change the requirement that all floors in multistory building be equipped with a floor control
valve but facilitate ease of installation and of inspection, test and maintenance of the systems.
Related Item
First Revision No. 153-NFPA 13-2013 [Section No. 8.16.1.5]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 08 09:02:21 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 226-NFPA 13-2014 [ New Section after 8.2.4.3 ]
8.2.4.4
The requirements of 8.2.4 shall not apply to dry systems.
Statement of Problem and Substantiation for Public Comment
The requirements for floor control valve assemblies on each floor of a multi-level structure were intended for wet
systems only but as the new language does not limit them to wet pipe systems only, they need to be applied to all
systems, both wet and dry. This new section requires a floor control assembly (control valve, check valve, and
drain) and a flow switch at each level (with an exception for certain small buildings ). This will make it difficult to
protect unheated structures such as parking garages with a single dry-pipe valve and then separate control and
check valves downstream.
Section 7.2.3.9 of NFPA 13 prohibits the use of check valves from being used to subdivide a dry-pipe system
unless the check valves are in a heated enclosure. This would make it difficult for a single dry-pipe valve to serve
a system arranged in accordance with 8.16.1.5. It would also be difficult to meet the requirement of 8.2.4 (8.16.1.5
in 2013 edition) for a flow switch on each level if you only had one dry-pipe valve. Paddle-type flow switches are
not allowed on dry-pipe systems and It is unclear if a pressure switch can be used on a pipe that is not a part of
the trim on a dry-pipe valve.
Section 8.2.4.3 (8.16.1.5.3 in the 2013 edition of NFPA 13) does provide an exception that lets you ignore the rules
regarding the separate floor control assemblies and flow switches on each floor if the whole parking garage is less
than 52,000 sq ft (assuming an ordinary hazard design). With six stories, you would have to average 8,667 sq ft
per floor, which is only enough space to park about 30 cars, so that’s a pretty small parking garage.
As stated, I believe these requirements were not intended to be applied to dry systems and language needs to be
added to the standard to specifically exempt them from the floor control valve requirements of section 8.2.4.
Related Public Comments for This Document
Related Comment
Public Comment No. 225-NFPA 13-2014 [Section No. 8.2.4.1]
Relationship
Charging requirement
Related Item
First Revision No. 153-NFPA 13-2013 [Section No. 8.16.1.5]
Public Input No. 317-NFPA 13-2013 [Section No. 8.16.1.5]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 08 09:22:21 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 232-NFPA 13-2014 [ Section No. 8.4.3 ]
8.4.3 Extended Coverage Spray Sprinklers.
Extended coverage sprinklers shall only be installed as follows:
(1) In unobstructed construction consisting of flat, smooth ceilings with a slope not exceeding a pitch of 1
in 6 (a rise of 2 units in a run of 12 units, a roof slope of 16.7 percent)
(2) In unobstructed or noncombustible obstructed construction, where specifically listed for such use
(3) Within trusses or bar joists having web members not greater than 1 in. (25.4 mm) maximum dimension
or where trusses are spaced greater than 7 1⁄2 ft (2.3 m) on center and where the ceiling slope does
not exceed a pitch of 1 in 6 (a rise of 2 units in a run of 12 units, a roof slope of 16.7 percent)
(4) Extended coverage upright and pendent sprinklers installed under smooth, flat ceilings that have
slopes not exceeding a pitch of 1 in 3 (a rise of 4 units in a run of 12 units, a roof slope of 33.3
percent), where specifically listed for such use
(5) Extended coverage sidewall sprinklers installed in accordance with 8.9.4.2.2 in slopes exceeding a
ceiling pitch of 2 in 12
(6) In each bay of obstructed construction consisting of solid structural members that extend below the
deflector of the sprinkler
(7) Extended coverage sprinklers installed to protect areas below a single overhead door(s)
Statement of Problem and Substantiation for Public Comment
clarify that that this is a "spray" sprinkler.
Related Item
Public Input No. 209-NFPA 13-2013 [Section No. 8.4.1.1]
Submitter Information Verification
Submitter Full Name: Phillip Brown
Organization:
American Fire Sprinkler Associ
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 08 17:02:12 EDT 2014
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Public Comment No. 81-NFPA 13-2014 [ New Section after 8.4.7.1 ]
8.4.7.1.1 CMSA sprinklers shall not be permitted to protect storage on solid shelf racks unless the solid
shelves are protected in accordance with 16.1.6 or 17.1.5 as applicable to the type of storage.
Statement of Problem and Substantiation for Public Comment
The redundancy task group agrees with this comment.
The issue of CMSA and solid shelves is being cleaned up in the storage chapters. It is necessary that this section
has this text. The text mimics that from 8.4.6.1.1 on ESFR.
Related Item
First Revision No. 208-NFPA 13-2013 [New Section after 16.2.2.1]
Submitter Information Verification
Submitter Full Name: Roland Huggins
Organization:
American Fire Sprinkler Association
Street Address:
City:
State:
Zip:
Submittal Date:
Thu Mar 27 13:49:32 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 140-NFPA 13-2014 [ New Section after 8.5.5.3.1.2 ]
Copy the new 8.6.5.3.6 to create a new 8.5.5.3.1.2, to read as follows:
8.5.5.3.1.2 The deflector of automatic sprinklers installed under fixed obstructions shall be
positioned no more than 12 in. (300 mm) below the bottom of the obstruction.
Renumber the remainder of Section 8.5.5.3.1 accordingly.
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-5-5-3-1-2.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The new text of 8.6.5.3.6 was added to clarify the proper location for sprinklers below obstructions such as wide
ducts and open grate flooring. The same text should be added into Section 8.5.5.3.1, which deals with the same
types of issues.
Related Item
First Revision No. 107-NFPA 13-2013 [New Section after 8.6.5.3.5]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:13:39 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 368-NFPA 13-2014 [ Section No. 8.5.5.3.1.3 ]
8.5.5.3.1.3
Sprinklers shall not be required under noncombustible obstructions over 4 ft (1.2 m) wide where the bottom
of the obstruction is 24 in. (620 mm) or less above the floor or deck.
Statement of Problem and Substantiation for Public Comment
24 inches is far too restrictive. Tables can be up to 36” from the floor and do not require sprinkler beneath.
Related Item
First Revision No. 90-NFPA 13-2013 [New Section after 8.5.5.3.1.1]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Academy of Fire Sprinkler Tech
Street Address:
City:
State:
Zip:
Submittal Date:
Mon May 19 13:09:12 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 13-NFPA 13-2014 [ Section No. 8.5.5.3.3.1 ]
8.5.5.3.3.1
Quick-response spray Spray sprinklers shall be permitted to be utilized under overhead doors.
Statement of Problem and Substantiation for Public Comment
There are situations wherestandard response sprinklers should be permited beneath overhead doors.
Related Item
First Revision No. 91-NFPA 13-2013 [New Section after 8.5.5.3.2]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 11 15:00:25 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 266-NFPA 13-2014 [ New Section after 8.5.5.4 ]
8.5.5.4.1
In closets and compartments enclosed by walls and a door, including those housing mechanical
equipment, that are smaller than 400 ft3 (11.3 m3), pendent, upright and sidewall residential
sprinklers shall be permitted to be installed within 18 inches of the ceiling to avoid obstructions
near the ceiling.
Additional Proposed Changes
File Name
Description
Computer_Modeling_of_Closet.pdf
Computer modeling of residential sprinklers in closets
Approved
Statement of Problem and Substantiation for Public Comment
Small closets, especially those housing mechanical equipment, frequently contain obstructions that make it difficult
to place sprinklers within 12 inches of the ceiling. Allowing residential sprinklers to be located further down would
allow adequate sprinkler protection of these small closets while avoiding ceiling level obstructions such as ducts
and pipes.
Based upon CFAST Computer Fire Model, an analysis was performed comparing the performance of sprinklers
located 6 inches down from a ceiling in a small room to the performance of sprinklers 18 inches down from the
ceiling in an even smaller closet. Based upon this analysis it appears that residential sprinklers 18 inches down
from the ceiling in a closet up to 400 ft3 react to a fire at least as quickly as residential sprinklers 6 inches down
from a ceiling in a small room. Using equivalency concepts, residential sprinklers could be allowed to be installed
within 18 inches of the ceiling in small closets. This analysis is included in this public comment. This same
comment has been submitted for NFPA 13R and NFPA 13D.
Related Item
First Revision No. 91-NFPA 13-2013 [New Section after 8.5.5.3.2]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 15 10:16:56 EDT 2014
5/19/2014 1:50 PM
Computer Modeling of Closet with
Residential Sprinkler 18 Inches from Ceiling
This analysis uses the CFAST Computer Fire Model to compare the performance of sprinklers 6
inches down from the ceiling in a small room to the performance of sprinklers 18 inches down
from the ceiling in an even smaller closet.
Baseline Room:
 15 ft x 15 ft x 8 ft
 3 sprinkler locations (see Figure 1)
o Sprinkler 1 – 4 ft from south and west walls
o Sprinkler 2 – Centered between east and west walls, 4 ft from south wall
o Sprinkler 3 – 4 inches from south and east walls
 All sprinklers 6 inches from ceiling
 All sprinklers RTI = 50 (metric units)
Closet:
 7 ft x 7 ft x 8 ft (392 ft3)
 3 sprinkler locations (see Figure 2)
o Sprinkler 1 – 2 ft from south and west walls
o Sprinkler 2 – Centered between east and west walls, 2 ft from south wall
o Sprinkler 3 – 4 inches from south and east walls
 All sprinklers 18 inches down from ceiling
 All sprinklers RTI = 50 (metric units)
Fire:
 Fairly slow growing fire
 Center of the room/closet
 See Figure 3
1
1
2
2
3
3
Figure 1 – Baseline Room
Figure 2 – Closet 392 ft3
Figure 3 – Heat Release Rate for Fire
(Note that the first 600 seconds are the only
important parts of the heat release due to sprinkler activation time)
Results
The following table compares the activation time of the sprinklers in the small room to that of
the sprinklers in the even smaller closet:
Sprinkler
1
2
3
Activation Time in Activation Time
Small Room
in Closet
(Figure 1)
(Figure 2)
510 seconds
500 seconds
530 seconds
500 seconds
510 seconds
500 seconds
Conclusions
Given this fire location and these three sprinkler locations, it would appear that residential
sprinklers 18 inches down from the ceiling in a closet up to 400 ft3 react to a fire at least as
quickly as residential sprinklers 6 inches down from a ceiling in a small room. Using
equivalency concepts, residential sprinklers could be allowed to be installed within 18 inches of
the ceiling in small closets.
Prior to making any final determination, other combinations of fire size, fire location, and
sprinkler location should be analyzed in the same manner.
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Public Comment No. 343-NFPA 13-2014 [ Section No. 8.5.7.3 ]
8.5.7.3
2
2
A sprinkler installed directly beneath a skylight not exceeding 32 ft (3 m ) shall measure the distance to
the ceiling to the highest horizontal plane of in the ceiling skylight and not to the top of the skylight.
Statement of Problem and Substantiation for Public Comment
“The plane of the ceiling” will be interpreted as the lower ceiling elevation under the skylight, which will stop people
from being able to actually put the sprinkler up into the skylight. We don’t want that sort of misinterpretation, so we
are suggesting this change.
Related Item
First Revision No. 93-NFPA 13-2013 [New Section after 8.5.7.2]
Submitter Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 14:34:39 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 14-NFPA 13-2014 [ New Section after 8.6.4.1.4.3 ]
A.8.6.4.1.4.3
Attic width and sprinkler spacing should be measured from the point of intersection between the
bottom of the top cord of the roof joist or truss and the top of the ceiling joist or non-combustible
insulation. [See Fig. X.]
<Insert Figure>
Additional Proposed Changes
File Name
Description
Slope_intesection.png
Slope Intersection
Approved
Statement of Problem and Substantiation for Public Comment
The original submitter seeks to reduce the requirements on the sprinklers at the eaves, which would otherwise
require three closely spaced branchlines to provide protection for a small attic. Clarification that sprinkler spacing
and positioning can be made to non-combustible insulation could effectively reduce the width to the point where a
single sprinkler at the ridge provides adequate protection.
Related Item
Public Input No. 16-NFPA 13-2013 [Section No. 8.6.4.1.4]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 11 16:12:48 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 15-NFPA 13-2014 [ Section No. 8.6.4.1.4.5 ]
8.6.4.1.4.5 *
8.6.4.1.4.5* The requirements of 8.6.4.1.4. 3 or 8.6. 4 .1.4.4 shall not apply to sprinklers installed at the
corner of the eave of a hip type roof where located under the eave spaced in accordance with 8.6.3.2.3 or
spaced on the slope plane not less than 5 ft (1.52 m) from the intersection of the upper and lower truss
chords or the wood rafters and ceiling joists.
A.8.4.1.4.5* See Figure
Additional Proposed Changes
File Name
Description
Hip.png
A.8.6.4.1.4.5
Eave_Location.doc
Change and Substantiation
Approved
Statement of Problem and Substantiation for Public Comment
Sprinkler protection at the eave continues to be problematic. There are currently two schools of thought: space to
the eave (as if it were a wall and baffle between sprinklers) or position under the eave and protect opposing panes
(in apparent violation of 8.6.4.2.1).
< Fig 1>
Option 1
<Fig 2>
Option 2
From a fire protection standpoint, locating sprinklers on the eave protecting two planes, while aligning the sprinkler
deflector with the pitch of the eave is the better option. The real question then, is just how far off the eave should
we position our first sprinkler. In this case 8.6.3.2.3 can provide us with a lot of flexibility [See Option 3] and give
the designer additional flexibility while providing better fire protection, which seems to meet the submitter’s intent.
<Fig 3>
Option 3
Related Item
First Revision No. 102-NFPA 13-2013 [New Section after 8.6.4.1.4.4]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 11 17:51:02 EDT 2014
5/19/2014 1:50 PM
8.6.4.1.4.5* The requirements of 8.6.4.1.4.3 or 8.6.4.1.4.4 shall not apply to sprinklers installed at the
corner of the eave of a hip type roof where located under the eave spaced in accordance with 8.6.3.2.3
or spaced on the slope plane not less than 5 ft (1.52 m) from the intersection of the upper and lower
truss chords or the wood rafters and ceiling joists.
Annex: See Figure
Substantiation:
Sprinkler protection at the eave continues to be problematic. There are currently two schools of
thought: space to the eave (as if it were a wall and baffle between sprinklers) or position under the eave
and protect opposing panes (in apparent violation of 8.6.4.2.1).
Option 1
Option 2
From a fire protection standpoint, locating sprinklers on the eave protecting two planes, while aligning
the sprinkler deflector with the pitch of the eave is the better option. The real question then, is just how
far off the eave should we position our first sprinkler.
In this case 8.6.3.2.3 can provide us with a lot of flexibility [See Option 3] and give the designer
additional flexibility while providing better fire protection, which seems to meet the submitter’s intent.
Option 3
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Public Comment No. 273-NFPA 13-2014 [ Section No. 8.6.4.1.4.6 ]
8.6.4.1.4.6
The special requirements of 8.6.2.2.1 and 8.6.4.1.4shall not apply when the exposed combustible
sheathing in the roof or ceiling space are noncombustible, limited-combustibled, or constructed of pressure
impregnated fire retardant–treated wood as defined by NFPA 703.
Statement of Problem and Substantiation for Public Comment
The requirements of this section apply when the sheathing is combustible and supported by wood joists or wood
truss construction. This is a clarification to indicate that the exception also applies when the sheathing is
noncombustible or limited combustible. The IBC also allows spray foam insulation (provided it meets fire test
requirements) to be applied and covered with intumescent paint. This covers the combustible sheathing.
Related Item
First Revision No. 104-NFPA 13-2013 [Section No. 8.6.4.1.4.5]
Submitter Information Verification
Submitter Full Name: Thomas Wellen
Organization:
American Fire Sprinkler Associ
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 15 16:04:30 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 274-NFPA 13-2014 [ Section No. 8.6.4.1.4.6 ]
8.6.4.1.4.6 1 (renumber remaining sections)
The special requirements of 8.6.2.2.1 and 8.6.4.1.4shall not apply when the exposed combustible
sheathing in the roof or ceiling space are constructed of pressure impregnated fire retardant–treated wood
as defined by NFPA 703.
Statement of Problem and Substantiation for Public Comment
Editorial - Exceptions should be located right after the base requirement. If left as is, the user doesn’t see there is
an exception to these requirements until the very end. This should be right up front before other criteria is
specified.
Related Item
First Revision No. 104-NFPA 13-2013 [Section No. 8.6.4.1.4.5]
Submitter Information Verification
Submitter Full Name: Thomas Wellen
Organization:
American Fire Sprinkler Associ
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 15 16:13:58 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 16-NFPA 13-2014 [ Section No. 8.6.4.2.1 ]
8.6.4.2.1
Unless the requirements of 8.6.4.2.2 or 8.6.4.2.3 are met, deflectors of sprinklers shall be aligned parallel
to ceilings, roofs, eaves, or the incline of stairs.
Statement of Problem and Substantiation for Public Comment
This change clarifies that spray sprinklers are permissible under the eave, not just the slope plane.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 15-NFPA 13-2014 [Section No. 8.6.4.1.4.5]
Related Item
First Revision No. 102-NFPA 13-2013 [New Section after 8.6.4.1.4.4]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Mar 11 18:02:08 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 243-NFPA 13-2014 [ Section No. 8.6.5.2.1.3 ]
8.6.5.2.1.3 *
Minimum Distance from Obstructions.
(A)
Unless the requirements of 8.6.5.2.1.4 through 8.6.5.2.1.9 are met, sprinklers shall be positioned away
from obstructions a minimum distance of three times the maximum dimension of the obstruction (e.g.,
structural members, pipe, columns, and fixtures)
.
(B)
The maximum clear distance required shall be 24 in. (609 mm) in
, in accordance with Figure 8.6.5.2.1.3 .
(
B).
Figure 8.6.5.2.1.3(B) Minimum Distance from Obstruction (SSU/SSP).
A) The maximum clear distance required from obstructions in the horizontal orientation (e.g. light fixtures
and truss chords), shall be 24 in. (609 mm).
(B) The maximum clear distance shall not be applied to obstructions in the vertical orientation (e.g.
columns).
Additional Proposed Changes
File Name
Description
8.6.5.2.1.3.pdf
New Figure 8.6.5.2.1.3
Approved
Statement of Problem and Substantiation for Public Comment
Recent fire testing has shown that there is an issue with the maximum clear distance of 24 inch allowed by the
"three times rule". This testing has shown that when this maximum clear distance allowance is used to located
sprinklers from large obstructions, the fire may not be controlled. As this testing was limited to vertical columns
and based upon the concerns of the committee, this public comment is limited to obstructions in the vertical
orientation. (test report was submitted at First Draft meeting)
This proposed change does not change the base three times rule or four times rule but will remove the maximum
clear distance to obstructions in the vertical orientation such as columns. This proposed change would only
become applicable when applying this rule to large vertical obstructions in excess of 8 inches (or 9 inches for the
four times rule). The three times or four times rule may be applied to these large columns without the utilizing the
maximum clear distance allowance. For example, for a ten inch column, the sprinkler would need to be located a
minimum distance of 30 inches from the column when applying the three times rule or 40 inches for the four times
rule. Note that a new figure was added to replace existing figure.
Related Item
Public Input No. 331-NFPA 13-2013 [Sections 8.6.5.2.1.3(A), 8.6.5.2.1.3(B)]
5/19/2014 1:50 PM
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Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Mon May 12 11:00:20 EDT 2014
5/19/2014 1:50 PM
Ceiling
Open web steel
or wood truss
D
A
C
C
A
Plan View of Column
(Obstruction in Vertical Orientation)
A
3C or 3D
(Use dimension C or D, whichever is greater)
D
Elevation View of Truss
(Obstruction in Horizontal Orientation)
A
3C or 3D
A 24 in, (610 mm)
(Use dimension C or D, whichever is greater)
FIGURE 8.6.5.2.1.3 Minimum Distance from Obstruction (SSU/SSP)
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Public Comment No. 141-NFPA 13-2014 [ Section No. 8.6.5.3.7 ]
8.6.5.3.7
Sprinklers installed under round ducts shall be of the intermediate level/rack storage type or otherwise
shielded from the discharge of overhead sprinklers.
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-6-5-3-7.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The substantiation offered with this proposal was that surface tension will cause the water to cling to the outside
surface of the duct, but this is not correct. Water discharging on the top of a round duct will only flow to the equator
and will fall down from there. That is the reason that in NFPA 15 Section 7.4.2.4 says that spherical or horizontal
cylindrical surfaces below the vessel equator shall not be considered wettable from rundown.
If surface tension could hold the water until it rolled to the bottom of round ducts there would be no need to
position sprinklers below.
Related Item
First Revision No. 108-NFPA 13-2013 [New Section after 8.6.5.3.5]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:15:09 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 254-NFPA 13-2014 [ Section No. 8.7.5.2.1.3 ]
8.7.5.2.1.3 *
Unless the requirements of 8.7.5.2.1.4 or 8.7.5.2.1.5 are met, sprinklers shall be positioned away from
obstructions a minimum distance of three times the maximum dimension of the obstruction (e.g., truss webs
and chords, pipe, columns, and fixtures). The maximum clear distance required shall be 24 in. (610 mm)
and shall be positioned in , in accordance with Figure 8.7.5.2.1.3 where obstructions are present .
Figure 8.7.5.2.1.3 Minimum Distance from Obstruction (Standard Sidewall Spray Sprinkler).
(A) The maximum clear distance required to obstructions in the horizontal orientation (e.g., light fixtures
and truss chords) shall be 24 in. (610 mm).
(B) The maximum clear distance shall not be applied to obstructions in the vertical orientation (e.g.
columns).
Additional Proposed Changes
File Name
Description
8.7.5.2.1.3.pdf
New Figure 8.7.5.2.1.3
Approved
Statement of Problem and Substantiation for Public Comment
Recent fire testing has shown that there is an issue with the maximum clear distance of 24 inch allowed by the
"three times rule". This testing has shown that when this maximum clear distance allowance is used to located
sprinklers from large obstructions, the fire may not be controlled. As this testing was limited to vertical columns
and based upon the concerns of the committee, this public comment is limited to obstructions in the vertical
orientation. (test report was submitted at First Draft meeting)
This proposed change does not change the base three times rule or four times rule but will remove the maximum
clear distance to obstructions in the vertical orientation such as columns. This proposed change would only
become applicable when applying this rule to large vertical obstructions in excess of 8 inches (or 9 inches for the
four times rule). The three times or four times rule may be applied to these large columns without the utilizing the
maximum clear distance allowance. For example, for a ten inch column, the sprinkler would need to be located a
minimum distance of 30 inches from the column when applying the three times rule or 40 inches for the four times
rule. Note that a new figure was added to replace existing figure.
Related Public Comments for This Document
Related Comment
Public Comment No. 243-NFPA 13-2014 [Section No. 8.6.5.2.1.3]
Relationship
same concept
Related Item
5/19/2014 1:50 PM
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Public Input No. 335-NFPA 13-2013 [Section No. 8.7.5.2.1.3]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Tue May 13 12:04:05 EDT 2014
5/19/2014 1:50 PM
Ceiling
D
A
C
C
A
D
Wall
Wall
Plan View of Column
(Obstruction in Vertical Orientation)
Elevation View of Pipe Conduit or Light Fixture
(Obstruction in Horizontal Orientation)
A
3C or 3D
(Use dimension C or D, whichever is greater)
A
3C or 3D
A 24 in, (610 mm)
(Use dimension C or D, whichever is greater)
FIGURE 8.7.5.2.1.3 Minimum Distance from Obstruction (Standard Sidewall Spray Sprinkler)
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Public Comment No. 255-NFPA 13-2014 [ Section No. 8.8.5.2.1.3 ]
8.8.5.2.1.3 *
Unless the requirements of 8.8.5.2.1.4 through 8.8.5.2.1.8 are met, sprinklers shall be positioned away
from obstructions a minimum distance of four times the maximum dimension of the obstruction (e.g., truss
webs and chords, pipe, columns, and fixtures). The maximum clear distance required shall be 36 in. (914
mm) in , in accordance with Figure 8.8.5.2.1.3 .
Figure 8.8.5.2.1.3 Minimum Distance from Obstruction (Extended Coverage Upright and Pendent
Spray Sprinklers).
(A) The maximum clear distance required to obsructions in the horizontal orientation (e.g., light fixtures
and truss chords) shall be 36 in. (914 mm).
(B) The maximum clear distance shall not be applied to obstructions in the vertical orientation (e.g.
columns).
Additional Proposed Changes
File Name
Description
8.8.5.2.1.3.pdf
New Figure 8.8.5.2.1.3
Approved
Statement of Problem and Substantiation for Public Comment
Recent fire testing has shown that there is an issue with the maximum clear distance of 24 inch allowed by the
"three times rule". This testing has shown that when this maximum clear distance allowance is used to located
sprinklers from large obstructions, the fire may not be controlled. As this testing was limited to vertical columns and
based upon the concerns of the committee, this public comment is limited to obstructions in the vertical
orientation. (test report was submitted at First Draft meeting)
This proposed change does not change the base three times rule or four times rule but will remove the maximum
clear distance to obstructions in the vertical orientation such as columns. This proposed change would only
become applicable when applying this rule to large vertical obstructions in excess of 8 inches (or 9 inches for the
four times rule). The three times or four times rule may be applied to these large columns without the utilizing the
maximum clear distance allowance. For example, for a ten inch column, the sprinkler would need to be located a
minimum distance of 30 inches from the column when applying the three times rule or 40 inches for the four times
rule. Note that a new figure was added to replace existing figure.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 254-NFPA 13-2014 [Section No. 8.7.5.2.1.3]
same concept
Public Comment No. 243-NFPA 13-2014 [Section No. 8.6.5.2.1.3]
same concept
5/19/2014 1:50 PM
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Related Item
Public Input No. 337-NFPA 13-2013 [Section No. 8.8.5.2.1.3]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Tue May 13 13:32:57 EDT 2014
5/19/2014 1:50 PM
Ceiling
Open web steel
or wood truss
D
A
C
C
A
Plan View of Column
(Obstruction in Vertical Orientation)
A
4C or 4D
(Use dimension C or D, whichever is greater)
D
Elevation View of Truss
(Obstruction in Horizontal Orientation)
A
4C or 4D
A 36 in, (914 mm)
(Use dimension C or D, whichever is greater)
FIGURE 8.8.5.2.1.3 Minimum Distance from Obstruction (Extended
Coverage Upright and Pendent Spray Sprinkler)
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Public Comment No. 142-NFPA 13-2014 [ Section No. 8.8.5.3.6 ]
8.8.5.3.6
Sprinklers installed under round ducts shall be of the intermediate level/rack storage type or otherwise
shielded from the discharge of overhead sprinklers.
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-8-5-3-6.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The substantiation offered with this proposal was that surface tension will cause the water to cling to the outside
surface of the duct, but this is not correct. Water discharging on the top of a round duct will only flow to the equator
and will fall down from there. That is the reason that in NFPA 15 Section 7.4.2.4 says that spherical or horizontal
cylindrical surfaces below the vessel equator shall not be considered wettable from rundown.
If surface tension could hold the water until it rolled to the bottom of round ducts there would be no need to
position sprinklers below.
Related Item
First Revision No. 117-NFPA 13-2013 [New Section after 8.8.5.3.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:16:30 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 143-NFPA 13-2014 [ Section No. 8.9.5.2.1.3 ]
Reconsider the proposal and return the text of 8.9.5.2.1.3 and 8.9.5.2.1.4 to that of the 2013 edition of
NFPA 13. Also restore Figure 8.9.5.2.1.4.
8.9.5.2.1.3 *
Unless the requirements of 8.9.5.2.1.4 through 8.9.5.2.1.5 are met, sprinklers shall be positioned away
from obstructions a minimum distance of four times the maximum dimension of the obstruction (e.g., truss
webs and chords, pipe, columns, and fixtures)in accordance with Figure 8.9.5.2.1.3 .
Figure 8.9.5.2.1.3 Minimum Distance from Obstruction (Extended Coverage Sidewall).
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-9-5-2-1-3.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The recent testing may have raised some issues concerning shadowed areas behind large building columns, but
the "Four Times Rule" has more applications than that - as with the light fixture illustrated on the right side of
Figure 8.9.5.2.1.3, where the 36 inch limit is still be a viable proposition. As currently proposed, a 2 ft wide fixture
would need to be 8 ft from a sprinkler. There is no field evidence of any problems with obstructions that would
support this drastic alteration. More consideration of this issue is needed, before any final decisions can be
reached.
Related Item
First Revision No. 122-NFPA 13-2013 [Sections 8.9.5.2.1.3, 8.9.5.2.1.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:17:55 EDT 2014
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Public Comment No. 256-NFPA 13-2014 [ Section No. 8.9.5.2.1.3 ]
8.9.5.2.1.3 *
Unless the requirements of 8.9.5.2.1.4 through 8.9.5.2.1.5 are met, sprinklers shall be positioned away
from obstructions a minimum distance of four times the maximum dimension of the obstruction (e.g., truss
webs and chords, pipe, columns, and fixtures) in accordance with Figure 8.9.5.2.1.3 .
Figure 8.9.5.2.1.3 Minimum Distance from Obstruction (Extended Coverage Sidewall).
(A) The maximum clear distance required to obstructions in the horizontal orientation (e.g., light fixtures
and truss chords), shall be 36 in. (914 mm).
(B) The maximum clear distance shall not be applied to obstructions in the vertical orientation (e.g.,
columns).
Additional Proposed Changes
File Name
Description
8.9.5.2.1.4.pdf
New Figure 8.9.5.2.1.4
Approved
Statement of Problem and Substantiation for Public Comment
Recent fire testing has shown that there is an issue with the maximum clear distance of 24 inch allowed by the
"three times rule". This testing has shown that when this maximum clear distance allowance is used to located
sprinklers from large obstructions, the fire may not be controlled. As this testing was limited to vertical columns and
based upon the concerns of the committee, this public comment is limited to obstructions in the vertical
orientation. (test report was submitted at First Draft meeting)
This proposed change does not change the base three times rule or four times rule but will remove the maximum
clear distance to obstructions in the vertical orientation such as columns. This proposed change would only
become applicable when applying this rule to large vertical obstructions in excess of 8 inches (or 9 inches for the
four times rule). The three times or four times rule may be applied to these large columns without the utilizing the
maximum clear distance allowance. For example, for a ten inch column, the sprinkler would need to be located a
minimum distance of 30 inches from the column when applying the three times rule or 40 inches for the four times
rule. Note that a new figure was added to replace existing figure.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 255-NFPA 13-2014 [Section No. 8.8.5.2.1.3]
same concept
Public Comment No. 254-NFPA 13-2014 [Section No. 8.7.5.2.1.3]
same concept
Public Comment No. 243-NFPA 13-2014 [Section No. 8.6.5.2.1.3]
same concept
Related Item
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Public Input No. 339-NFPA 13-2013 [Sections 8.9.5.2.1.3, 8.9.5.2.1.4]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Tue May 13 13:39:31 EDT 2014
5/19/2014 1:50 PM
Ceiling
D
A
C
C
A
D
Wall
Wall
Plan View of Column
(Obstruction in Vertical Orientation)
A
4C or 4D
(Use dimension C or D, whichever is greater)
Elevation View of Pipe Conduit or Light Fixture
(Obstruction in Horizontal Orientation)
A
4C or 4D
A 36 in, (914 mm)
(Use dimension C or D, whichever is greater)
FIGURE 8.9.5.2.1.4 Minimum Distance from Obstruction (Extended Coverage Sidewall)
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Public Comment No. 257-NFPA 13-2014 [ Section No. 8.10.6.2.1.3 ]
8.10.6.2.1.3 *
Unless the requirements of 8.10.6.2.1.4 through 8.10.6.2.1.8 are met, sprinklers shall be positioned away
from obstructions a minimum distance of four times the maximum dimension of the obstruction (e.g., truss
webs and chords, pipe, columns, and fixtures). The maximum clear distance required shall be 36 in. (914
mm) in accordance with , in accordance with Figure 8.10.6.2.1.3 .
Figure 8.10.6.2.1.3 Minimum Distance from Obstruction (Residential Upright and Pendent Spray
Sprinklers).
(A) The maximum clear distance required to obstructions in the horizontal orientation (e.g., light fixture
and truss chords), shall be 36 in. (914 mm).
(B) The maximum clear distance shall not be applied to obstructions in the vertical orientation (e.g.,
Columns).
Additional Proposed Changes
File Name
Description
8.10.6.2.1.3.pdf
New Figure 8.10.6.2.1.3
Approved
Statement of Problem and Substantiation for Public Comment
Recent fire testing has shown that there is an issue with the maximum clear distance of 24 inch allowed by the
"three times rule". This testing has shown that when this maximum clear distance allowance is used to located
sprinklers from large obstructions, the fire may not be controlled. As this testing was limited to vertical columns and
based upon the concerns of the committee, this public comment is limited to obstructions in the vertical orientation.
(test report was submitted at First Draft meeting)
This proposed change does not change the base three times rule (or four times rule) but will remove the maximum
clear distance to obstructions in the vertical orientation such as columns. This proposed change would only
become applicable when applying this rule to large vertical obstructions in excess of 8 inches (or 9 inches for the
four times rule). The three times or four times rule may be applied to these large columns without the utilizing the
maximum clear distance allowance. For example, for a ten inch column, the sprinkler would need to be located a
minimum distance of 30 inches from the column when applying the three times rule or 40 inches for the four times
rule. Note that a new figure was added to replace existing figure.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 256-NFPA 13-2014 [Section No. 8.9.5.2.1.3]
Public Comment No. 255-NFPA 13-2014 [Section No. 8.8.5.2.1.3]
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Public Comment No. 254-NFPA 13-2014 [Section No. 8.7.5.2.1.3]
Public Comment No. 243-NFPA 13-2014 [Section No. 8.6.5.2.1.3]
Related Item
Public Input No. 340-NFPA 13-2013 [Section No. 8.10.6.2.1.3]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Tue May 13 13:51:33 EDT 2014
5/19/2014 1:50 PM
Ceiling
Open web steel
or wood truss
D
A
C
C
A
Plan View of Column
(Obstruction in Vertical Orientation)
A
4C or 4D
(Use dimension C or D, whichever is greater)
D
Elevation View of Truss
(Obstruction in Horizontal Orientation)
A
4C or 4D
A 36 in, (914 mm)
(Use dimension C or D, whichever is greater)
FIGURE 8.10.6.2.1.3 Minimum Distance from Obstruction (Residential
Upright and Pendent Spray Sprinkler)
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Public Comment No. 293-NFPA 13-2014 [ Sections 8.10.7.2.1.3, 8.10.7.2.1.4 ]
Sections 8.10.7.2.1.3, 8.10.7.2.1.4
8.10.7.2.1.3 *
Unless the requirements of 8.10.7.2.1.4 through 8.10.7.2.1.7 are met, sprinklers shall be positioned away
from obstructions a minimum distance of four times the maximum dimension of the obstruction(e .g., truss
webs and chords, pipe, columns, and fixtures). .
(A)
The
The maximum clear distance required from obstructions in the horizontal orientation,(e.g. light fixtures
and truss chords), shall be 36 in. (
914
609 mm)
from the sprinkler
.
(B) The maximum clear distance shall not be applied to obstructions in the vertical orientation (e.g.
, truss webs and chords, pipe,
columns
, and fixtures
).
8.10.7.2.1.4
Sidewall sprinklers shall be positioned in accordance with Figure 8.10.7.2.1.4 when obstructions are
present.
Figure 8.10.7.2.1.4 Minimum Distance from Obstruction (Residential Sidewall Sprinklers).
Additional Proposed Changes
File Name
Description
8.10.7.2.1.4.pdf
New figure 8.10.7.2.1.4
Approved
Statement of Problem and Substantiation for Public Comment
Recent fire testing has shown that there is an issue with the maximum clear distance of 24 inch allowed by the
"three times rule". This testing has shown that when this maximum clear distance allowance is used to located
sprinklers from large obstructions, the fire may not be controlled. As this testing was limited to vertical columns and
based upon the concerns of the committee, this public comment is limited to obstructions in the vertical orientation.
(test report was submitted at First Draft meeting)
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This proposed change does not change the base three times rule or four times rule but will remove the maximum
clear distance to obstructions in the vertical orientation such as columns. This proposed change would only
become applicable when applying this rule to large vertical obstructions in excess of 8 inches (or 9 inches for the
four times rule). The three times or four times rule may be applied to these large columns without the utilizing the
maximum clear distance allowance. For example, for a ten inch column, the sprinkler would need to be located a
minimum distance of 30 inches from the column when applying the three times rule or 40 inches for the four times
rule. Note that a new figure was added to replace existing figure.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 257-NFPA 13-2014 [Section No. 8.10.6.2.1.3]
same concept
Public Comment No. 256-NFPA 13-2014 [Section No. 8.9.5.2.1.3]
same concept
Public Comment No. 255-NFPA 13-2014 [Section No. 8.8.5.2.1.3]
same concept
Public Comment No. 254-NFPA 13-2014 [Section No. 8.7.5.2.1.3]
same concept
Public Comment No. 243-NFPA 13-2014 [Section No. 8.6.5.2.1.3]
same concept
Related Item
Public Input No. 341-NFPA 13-2013 [Sections 8.10.7.2.1.3, 8.10.7.2.1.4]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 09:46:53 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 144-NFPA 13-2014 [ Section No. 8.10.7.3.6 ]
8.10.7.3.6
Sprinklers installed under round ducts shall be shielded from the discharge of overhead sprinklers.
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-10-7-3-6.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The substantiation offered with this proposal was that surface tension will cause the water to cling to the outside
surface of the duct, but this is not correct. Water discharging on the top of a round duct will only flow to the equator
and will fall down from there. That is the reason that in NFPA 15 Section 7.4.2.4 says that spherical or horizontal
cylindrical surfaces below the vessel equator shall not be considered wettable from rundown.
If surface tension could hold the water until it rolled to the bottom of round ducts there would be no need to
position sprinklers below.
Related Item
First Revision No. 128-NFPA 13-2013 [New Section after 8.10.7.3.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:19:22 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 145-NFPA 13-2014 [ Section No. 8.11.2.2.2 ]
8.11.2.2.2
2
2
In any case, the maximum area of coverage of any sprinkler shall not exceed 130 ft (12.9 1 m ).
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-11-2-2-2.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The Committee Statement appears to be in agreement with the submitter, but the change was not incorporated
into the First Draft Report, so the error has not yet been corrected. The metric equivalent of 130 ft² (130 x 0.3048²
= 12.08) should be shown as 12.1 m².
Related Item
First Revision No. 272-NFPA 13-2013 [Sections A.6.3.7, A.6.3.7.2, A.6.3.7.3]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:20:34 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 132-NFPA 13-2014 [ Section No. 8.15.5 ]
8.15.5.3
8.15.5 Elevator Hoistways
and
, Machine Rooms
.
, Machinery Spaces, Control Rooms, and Control Spaces
8.15.5.1
*
Sidewall spray sprinklers shall be installed at the bottom of each elevator hoistway not more than 2 ft (0.61
m) above the floor of the pit.
8.15.5.2
The sprinkler required at the bottom of the elevator hoistway by 8.15.5.1 shall not be required for
enclosed, noncombustible elevator shafts that do not contain combustible hydraulic fluids.
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Automatic fire sprinklers shall not be required to be installed in elevator machine rooms,
elevator machinery spaces, elevator control rooms, or elevator control spaces,
or hoistways
of traction elevators installed in accordance with the applicable provisions in NFPA 101 , or the
applicable building code, where all of the following conditions are met:
(1) The elevator machine room, machinery space, control room
, control
(1) or control space,
or hoistway
(1)
of traction elevator is dedicated to elevator equipment only.
(2) The elevator machine room,
machine room,
(1)
machinery space, control room
, control
(1) or control space,
or hoistway
(1)
of traction
elevators are
(1) elevator is protected by smoke detectors, or other automatic fire detection, installed in
accordance with NFPA 72 .
(2) The elevator machine room, machinery space, control room
, control
(1) or control space,
or hoistway
(1)
of traction
elevators
(1) elevator is separated from the remainder of the building by walls and floor/ceiling or
roof/ceiling assemblies having a fire resistance rating of not less than that specified by the
applicable building code.
(2) No materials unrelated to elevator equipment are permitted to be stored in elevator
machine
rooms
(1) room , machinery
spaces
(1) space , control
rooms, control spaces, or hoistways
(1) room or control space, of traction
elevators
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(1) elevator .
(2)
The elevator machinery is not of the hydraulic type.
8.15.5.
4
2*
Automatic sprinklers in elevator machine
rooms or
room, machinery space, control room, control space, or at the tops of elevator hoistways ,
shall be of ordinary- or intermediate-temperature rating.
8.15.5.
5
3*
Upright, pendent, or sidewall spray sprinklers shall be installed at the top of elevator hoistways.
8.15.5.
6
4
The sprinkler required at the top of the elevator hoistway by 8.15.5.
5
3 shall not be required where the hoistway for passenger elevators is noncombustible or
limited-combustible and the car enclosure materials meet the requirements of ASME A17.1,
Safety Code for Elevators and Escalators .
8.15.5.
7 Combustible Suspension in Elevators.
4.1
Upright, pendent, or sidewall spray sprinklers shall be installed at the top of traction freight
elevator hoistways.
8.15.5.4.2
Upright, pendent, or sidewall spray sprinklers shall be installed at the top of hydraulic freight
elevator hoistways.
8.15.5.5
Hoistways
8.15.5.
Combustible Suspension Means and Combustible Elevator Equipmet in Elevator
7
5 .1
Sprinklers shall be installed at the top and bottom of elevator hoistways where the elevators
utilize combustible suspension means such as noncircular elastomeric-coated or polyurethanecoated steel belts or where the hoisting machine, elevator motor, elevator controller, or other
combustible elevator equipment is installed inside the elevator hoistway .
8.15.5.
7
5 .2
The
sprinklers in the elevator hoistway
sprinklers required at the top and bottom of the elevator hoistway by 8.15.5.5.1 shall not be
required when the suspension means provide not less than an FT-1 rating when tested to the
vertical burn test requirements of UL 62, Flexible Cords and Cables , and UL 1581, Reference
Standard for Electrical Wires, Cables, and Flexible Cords , and the top of the elevator
hoistawy is protected by smoke detectors, or other automatic fire detection, installed in
accordance with NFPA 72 .
.
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Statement of Problem and Substantiation for Public Comment
I had originally submitted PI's 153-156 regarding sprinkler protection for elevators' associated spaces.
The committee response was:
"Response Message: The technical committee agrees that this is an issue and the standard needs to further
address this concept. At this time the technical committee has not agreed upon a revision to the standard,
however this concept will be looked at by a task group prior to the Second Draft meeting. The task group needs to
review other standards and identify potential conflicts. The submitter is encouraged to send any additional
information during the comment stage."
I would like the task group to contact me, if possible, so I could better explain my proposal:
The additional information I would like the committee to consider is:
1) Current requirements in ASME A17.1-2013 and NFPA 72-2013 triggered by pit sprinklers
2) Conduct or perform risk analysis and/or obtain empirical data on pit sprinklers activation due to hydraulic liquids
fires in hydraulic elevator pits.
Since now NFPA 72-2013 includes specific requirements for fire alarm initiating devices in the pit triggered by the
presence of pit sprinkler - this creates an enforcement problems:
Providing a pit FAID connected to the building’s FA system or a dedicated function FA system for elevator recall,
especially where this FAID is required to be accessible from outside the hoistway, is a very costly requirement
(both for the initial installation and for ongoing service and maintenace). Since NFPA 72-2013 is now repeating the
ASME A17.1 requirement for a FAID (or waterflow switch) installation in elevator pits having sprinklers, this new
NFPA 72 requirement is causing a major enforcement problem for AHJs for the following reason:
Anytime a FA system upgrade, or a FA system replacement is performed in existing buildings having existing
elevators, the current NFPA 72-2013 code requirements apply to the upgraded/replaced FA system. In many
cases I see as an AHJ, reviewing FA permit plans and system designs, the existing elevator is provided with an
existing pit sprinkler, but without an associated pit FAID generating Phase I recall. Now, the FA designers who are
basing their system design on NFPA 72-2013 are adding pit FAIDs with associated Phase I recall, to their design
plans and sequence of operations, since this is the current applicable FA code.
This creates a major problem since many of the existing elevators are not even capable of Phase I recall
operation. In my jurisdiction, we are not enforcing this ASME A17.1 (and now NFPA 72-2013) requirement for
existing elevators even if they are capable of Phase I recall, but it takes me a great deal of time, as an AHJ, to
explain to FA designers why this specific code section is not enforced.
Of course I am aware that this is an NFPA 72-2013 new requirement but it is based on the existing ASME A17.1
requirement for having pit FAIDs. If the wording “excluding the pit” will be added to item C per my proposal - this
will eliminate the NFPA 72-2013 requirement which is based on ASME A17.1 and will prevent a great deal of
confusion to both FA system designers and Fire AHJs.
Also, Per ASME A17.1-2013 -2.8.3.3.4 - The pit sprinkler generates the requirement for NEMA 250 protection for
elevator equipment and wiring within 48" of the pit floor for new hydraulic elevators and for existing elevators,
anytime the existing elevator is being upgraded or modernized or altered, and there is an existing pit sprinkler.
This is a very costly requirement generated only by the presence of pit sprinkler required by NFPA 13.
My main concern is that the pit sprinkler required by NFPA 13 - generates significant unnecessary and very costly
installation and maintenance requirements Both in ASME A17.1 -2013 and in NFPA 72-2013 - Where there is NO
proven risk. If this requirement was based on a risk analysis or empirical data or known cases - I would be able to
understand this requirement.
While I believe, that codes and means should be created and provided to increase life safety and to minimize
potential risks and hazards, I also think that the codes should be reasonable and be based on research, empirical
data, known cases, and probabilities of potential risks.
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The ASME A17.1-2013 Code requirements generated by the pit sprinklers:
2.27.3.2.1 In jurisdictions not enforcing the NBCC, smoke detectors or other automatic fire detectors in
environments not suitable for smoke detectors (fire alarm initiating devices) used to initiate Phase I Emergency
Recall Operation shall be installed in conformance with the requirements of NFPA 72, and shall be located
(a) at each elevator lobby served by the elevator
(b) in the associated elevator machine room, machinery space containing a motor controller or driving machine,
control space, or control room
(c) in the elevator hoistway, when sprinklers are located in those hoistways,
AND
2.8.3.3.4 In jurisdictions not enforcing the NBCC, when sprinklers are installed not more than 600 mm (24 in.)
above the pit floor, 2.8.3.3.4(a) and (b) apply to elevator electrical equipment and wiring in the hoistway located
less than 1 200 mm (48 in.) above the pit floor,exceptearthquake protectivedevicesconform- ing to 8.4.10.1.2(d);
and on the exterior of the car at the point where the car platform sill and the lowest landing hoistway door sill are in
vertical alignment. (a) Elevator electrical equipment shall be weather- proof (Type 4 as specified in NEMA 250). (b)
Elevator wiring, except traveling cables, shall be identified for use in wet locations in accordance with the
requirements in NFPA 70.
The NFPA 72-2013 code requirements generated by the pit sprinkler are:
21.3.3 Unless otherwise required by the authority having jurisdiction,
only the elevator lobby, elevator hoistway, and elevator machine room smoke detectors, or other automatic fire
detection as permitted by 21.3.9, shall be used to recall elevators for fire fighters’ service.
Exception: A waterflow switch shall be permitted to initiate elevator
recall upon activation of a sprinkler installed at the bottom of the elevator hoistway (the elevator pit), provided the
waterflow switch and pit sprinkler are installed on a separately valved sprinkler line dedicated solely for protecting
the elevator pit, and the waterflow switch is provided without time-delay capability.
21.3.7* When sprinklers are installed in elevator pits, automatic
fire detection shall be installed to initiate elevator recall in accordance with 2.27.3.2.1(c) of ANSI/ASME
A.17.1/CSA B44, Safety Code for Elevators and Escalators, and the following shall apply:
(1) Where sprinklers are located above the lowest level of recall, the fire detection device shall be located at the
top of
the hoistway.
(2) Where sprinklers are located in the bottom of the hoistway
(the pit), fire detection device(s) shall be installed in the pit in accordance with Chapter 17.
(3) Outputs to the elevator controller(s) shall comply with
21.3.14.
Related Item
Public Input No. 153-NFPA 13-2013 [Section No. 8.15.5]
Public Input No. 154-NFPA 13-2013 [Section No. A.8.15.5.1]
Public Input No. 155-NFPA 13-2013 [Section No. A.8.15.5.4]
Public Input No. 156-NFPA 13-2013 [Section No. A.8.15.5.5]
Submitter Information Verification
Submitter Full Name: Sagiv Weiss-Ishai
Organization:
San Francisco Fire Department
Affilliation:
Fire Protection Engineer
Street Address:
City:
State:
Zip:
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Public Comment No. 191-NFPA 13-2014 [ Section No. 8.15.8.2 ]
8.15.8.2* Closets and Pantries.
Sprinklers are not required in clothes closets, linen closets, and pantries within dwelling units in hotels and
2
2
motels where the area of the space does not exceed 24 ft (2.2 m ), the least dimension does not exceed
3 ft (0.9 m), and the walls and ceilings are surfaced with noncombustible or limited-combustible materials.
Statement of Problem and Substantiation for Public Comment
CC NOTE: The following CC Note No. 19 appeared in the First Draft Report as Global First Revision No. 145.
The TC should review the need for identifying a maximum least dimension since it does not change the size of the
closet where sprinklers can be omitted. The fire doesn't know whether the closet 2x12 or 4x6. The requirement for
a maximum 3' least dimension was removed from NFPA 13R at the First Draft Meeting.
Related Item
First Revision No. 145-NFPA 13-2013 [New Section after 8.15.1.6.1]
Submitter Information Verification
Submitter Full Name: CC on AUT-AAC
Organization:
CC on Automatic Sprinkler Systems
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Apr 29 13:59:24 EDT 2014
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Public Comment No. 345-NFPA 13-2014 [ New Section after 8.15.11.2 ]
8.15.11.3
Hoods or shields installed to protect important electrical equipment from sprinkler discharge shall be
noncombustible.
Statement of Problem and Substantiation for Public Comment
This used to be section 8.15.11.2 in the 2013 and previous editions. It was removed by FR 150, which does not
show up in the First Draft Report, but this action was taken by the committee.
We believe that the section needs to be returned. The committee was in error in its substantiation. We do not
want the public to have to put all of their electrical equipment into very expensive waterproof NEMA enclosures
just because there is a sprinkler in the room. This will cause significant backlash with people wanting to remove
the sprinklers to save money, which is contrary to the goal of NFPA 13.
This section is necessary to NFPA 13 because it establishes the concept that we don't add to the combustibility of
the building with the sprinkler system. The rule needs to be in NFPA 13, not NFPA 70. There is already a rule in
NFPA 70 regarding the protection of electrical equipment from direct water spray due to pipe or other devices
carrying water that might break and allow water to spray in an electrical room. NFPA 70 does not state that the
shield be noncombustible because many of these water pipes have nothing to do with fire protection and a
combustible shield is permitted.
But NFPA 13 is concerned with fire protection. We don't want a fire growing underneath a combustible object that
is preventing the water from getting to the fire.
It was wrong of the committee to tell people that they need to put all energized electrical equipment in waterproof
NEMA enclosures. This statement will enflame a significant number of building owners, electricians, architects
and engineers.
There is no reason for NFPA 13 to contain any other guidance on the shields. There are no minimum construction
requirements. There are not minimum attachment requirements. We just want something to keep the water
spray from the sprinkler from getting directly on the electrical equipment. It is a minor concession that has helped
to keep the peace between the electrical industry and the sprinkler industry.
Related Item
First Revision No. 150-NFPA 13-2013 [Section No. 8.15.11.2]
Submitter Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 14:42:48 EDT 2014
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Public Comment No. 120-NFPA 13-2014 [ Section No. 8.15.11.2 ]
8.15.11.2
Sprinklers shall not be required in electrical equipment rooms where all of the following conditions are met:
(1) The room is dedicated to electrical equipment only.
(2) Only dry-type electrical equipment is used.
(3) Equipment is installed in a 2-hour fire-rated enclosure including protection for penetrations.
(4) No combustible storage No storage is permitted to be stored in the room.
Statement of Problem and Substantiation for Public Comment
Obviously non combustible storage will not burn. However, any storage should not be allowed as it may lead to
storage of combustibles.
Related Item
Public Input No. 11-NFPA 13-2013 [Section No. 8.15.11.2]
Submitter Information Verification
Submitter Full Name: Peter Schwab
Organization:
Wayne Automatic Fire Sprinkler
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 18 13:52:55 EDT 2014
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Public Comment No. 146-NFPA 13-2014 [ Section No. 8.15.11.2 ]
Reconsider and do not accept the proposal. Return the text of 8.15.11.2 to that of the 2013 edition of
NFPA 13, as follows:
8.15.11.2 Hoods or shields installed to protect important electrical equipment from sprinkler discharge
shall be noncombustible.
8.15.11.2
Sprinklers shall not be required in electrical equipment rooms where all of the following conditions are met:
(1) The room is dedicated to electrical equipment only.
(2) Only dry-type electrical equipment is used.
(3) Equipment is installed in a 2-hour fire-rated enclosure including protection for penetrations.
(4) No combustible storage is permitted to be stored in the room.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_8-15-11-2.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
This requirement should not be deleted unless it can be replaced with some other provision. Otherwise the
problems with putting sprinklers in electrical rooms will become worse than they are now. The Committee
Statement said that the electrical equipment should be installed in NEMA rated enclosures, but if something like
that isn't going to be put into the standard, then the current requirement to install hoods or shields should remain
as is.
Related Item
First Revision No. 150-NFPA 13-2013 [Section No. 8.15.11.2]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:22:11 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 330-NFPA 13-2014 [ Section No. 8.15.15 ]
8.15.15 Drop-Out Ceilings and Ceiling Materials .
8.15.15.1 *
Drop-out ceilings shall and ceiling materials shall be permitted to be installed beneath sprinklers where
ceilings are where the ceiling panels or ceiling materilas are listed for that service and are installed in
accordance with their listings.
8.15.15.2
Drop-out ceilings shall and ceiling materials shall not be installed below quick-response or extended
coverage sprinklers unless specifically listed for that application.
8.15.15.3
Drop-out ceilings shall and ceiling materials shall not be considered ceilings within the context of this
standard.
8.15.15.4 *
Piping installed above drop-out ceilings shall and ceiling materials shall not be considered concealed
piping.
8.15.15.5 *
Sprinklers shall not be installed beneath drop-out ceilings or ceiling materials .
Statement of Problem and Substantiation for Public Comment
A membrane product has been evaluated by UL using UL Subject 723S and is currently listed as being suitable for
being installed beneath sprinklers. This particulare membrane product contains seams that will fail during a fire
and as such, does not impact the ability of the water to reach the hazard being protected. The activation time for
the sprinklers was minimally impacted during the UL test. The UL test acceptance criteria addresses the impact
the product may have on the activation time of the sprinkler and the percent of material that needs to "drop out" so
as not to significantly impact the ability of the water to reach the hazard being protected.
The NFPA Technical Committee on Finishing Processes (NFPA 33) has recommended the acceptance of the
concept (involving membrane enclosures for indoor and outdoor spray applications) using the same criteria and
based upon feedback from an NFPA 13 task group. At the time this Public Comment was submitted, the ballot
results for the Second Draft Revision were not yet known. However, the vote during the Technical Committee
meeting was unanimous.
Recognition in the Standard for such listed products offers a solution that addresses those instances in which a
membrane needs to be installed between the sprinklers and the floor and potentially eliminating the use of other
methods that have historically been used and that are more likely to adversely impact the performance of the
sprinkler system.
Related Item
Committee Input No. 155-NFPA 13-2013 [Global Input]
Submitter Information Verification
Submitter Full Name: William Koffel
Organization:
Koffel Associates, Inc.
Affilliation:
Representing TuffWrap
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 13:21:04 EDT 2014
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Public Comment No. 19-NFPA 13-2014 [ New Section after 8.15.23 ]
Sprinkler-Protected Glazing.
Where sprinklers are used in combination with glazing as an alternative to a required fire-rated wall
or window assembly, the sprinkler-protected assembly shall comply with the following:
(1) Sprinklers shall be listed as specific application window sprinklers.
(2) Sprinklers shall be supplied by a wet-pipe system.
(3) Glazing shall be heat-strengthened or tempered and shall be fixed.
(4) Where the assembly is required to be protected from both sides, sprinklers shall be installed on
both sides of the glazing.
(5) The use of sprinkler-protected glazing shall be limited to non-load-bearing walls.
(6) The glazed wall assembly shall not have any horizontal members that would interfere with
uniform distribution of water over the surface of the glazing, and there shall be no obstructions
between sprinklers and glazing that would obstruct water distribution.
Annex
It is not the intent of this section to apply to sprinkler protection of glass atrium enclosures,
pedestrian walkways, which are permitted by NFPA 101, or model building codes to be protected
by standard spray sprinklers installed in accordance with the special provisions set forth in those
codes for atrium construction.
Statement of Problem and Substantiation for Public Comment
The proposed text and associated annex material was accepted by the residential committee for inclusion in NFPA
13R. The additional Annex material has been added to address the committees concerns.
Related Item
Public Input No. 585-NFPA 13-2013 [New Section after 8.15.23.3.1]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Wed Mar 12 11:09:09 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 372-NFPA 13-2014 [ New Section after 8.15.23 ]
8.15.23 Cloud Ceilings
8.15.23.1* Cloud Ceilings. Except as provided in 8.15.23.2 or 8.15.23.3, sprinkler
protection shall be required above and below cloud ceilings.
8.15.23.2* Sprinklers shall be permitted to be omitted from the above ceiling space when
the ceiling openings meet the definition of small openings per 3.3.6.2.
8.15.23.3 Concealed spaces formed by cloud ceilings installed below noncombustible
and limited combustible construction shall not require sprinkler protection.
8.15.23.4 A concealed space is formed above cloud ceilings when the ceiling panels are
adjacent to another ceiling panel in the same plane or a wall and the ceiling panels are
located such that the opening is not more than one inch for each foot of elevation
between the panel and the floor.
8.15.23.5 The space above cloud ceilings installed below noncombustible and limited
combustible construction shall be considered concealed where the ceiling panels are
more than 20 feet above the floor.
A.8.15.23.3 An opening in the ceiling may be located along a wall or may occur between
panels to give an architectural effect such as a floating ceiling. Fire modeling results
have shown that there will be heat loss to the space above the ceiling when the openings
are too large. The modeling results indicate that sprinklers should activate on the lower
ceiling level when the opening dimension is no greater than one inch per foot of elevation
above the floor. When an opening between ceiling panels, or a ceiling panel and a wall,
are any larger, the space above the ceiling panels should not be considered a concealed
space.
Figure A.8.15.23.3 - Examples of Cloud Ceiling Configurations
Statement of Problem and Substantiation for Public Comment
Cloud Ceiling Task Group language.
Related Item
Committee Input No. 166-NFPA 13-2013 [Global Input]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Street Address:
City:
State:
Zip:
Academy of Fire Sprinkler Tech
Submittal Date:
Tue May 20 14:57:14 EDT 2014
Copyright Assignment
I, Cecil Bilbo, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full
rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and
Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication
of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I
am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment.
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Page 2 of 2
By checking this box I affirm that I am Cecil Bilbo, and I agree to be legally bound by the above Copyright
Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am
creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a
handwritten signature
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Public Comment No. 121-NFPA 13-2014 [ Section No. 8.15.24.2 ]
8.15.24.2 Indoor Swimming Pools.
8.15.24.2.1
The area directly above indoor swimming pools shall not require sprinkler protection unless the
requirements of 8.15.24.2.2 apply.
8.15.24.2.2
The area above indoor swimming pools equipped with moveable hard covers that allow the area to be
used for athletic activities other than swimming and other water sports shall require sprinkler protection.
8.15.24.2.3
Sprinklers shall be installed in all areas adjacent to indoor swimming pools.
Statement of Problem and Substantiation for Public Comment
There are too many possibilities for the pool to be covered and the area used for another activity. Also, there could
be floors above the pool. It just makes sense to install the sprinklers.
Related Item
First Revision No. 132-NFPA 13-2013 [New Section after 8.15.23.3.1]
Submitter Information Verification
Submitter Full Name: Peter Schwab
Organization:
Wayne Automatic Fire Sprinkler
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 18 13:55:53 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 147-NFPA 13-2014 [ Section No. 8.15.24.2 ]
8.15.24.2 Indoor Swimming Pools.
8.15.24.2.1
The area directly above indoor swimming pools shall not require sprinkler protection unless the
requirements of 8.15.24.2.2 apply.
8.15.24.2.2
The area above indoor swimming pools equipped with moveable hard covers that allow the area to be
used for athletic activities other than swimming and other water sports shall require sprinkler protection.
Reconsider and do not accept the proposal. Delete the proposed Section 8.15.24.2
.3
Sprinklers shall be installed in all areas adjacent to indoor swimming pools.
in its entirety:
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-15-24-2.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
This exemption should not be added to the standard. Not all indoor swimming pools are vacant of occupancies. I
have seen wooden bridges spanning them, swim-up bars in the centre, couches and other combustibles
immediately at the perimeters etc. Additionally, many indoor swimming pools enclosures are of combustible
construction or have combustible finishes. Also, even if a pool is not originally fitted with a hard cover, one could
easily be added afterwards. Therefore, if a pool itself won't burn, the things that go in and around it most certainly
can, and sprinklers should be required.
Related Item
First Revision No. 132-NFPA 13-2013 [New Section after 8.15.23.3.1]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:23:35 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 224-NFPA 13-2014 [ Section No. 8.15.24.2 ]
8.15.24.2 Indoor Swimming Pools.
8.15.24.2.1
The area directly above indoor swimming pools shall not require sprinkler protection unless the
requirements of 8.15.24.2.2 apply.
8.15.24.2.2
The area above indoor swimming pools equipped with moveable hard covers that allow the area to be
used for athletic activities other than swimming and other water sports shall require sprinkler protection.
8.15.24.2.3
Sprinklers shall be installed in all areas adjacent to indoor swimming pools.
Statement of Problem and Substantiation for Public Comment
This public comment is to delete this entire section that allows the omission of sprinklers in indoor pools. It is not
consistent with the goals of NFPA 13 to allow such a large indoor areas to be unprotected with sprinklers. Such
areas can be quite large and while the pool and deck may be of noncombustible construction, indoor pool areas
commonly contain combustibles such as lounge chairs and accessory structures such as bars and cabanas.
Indoor pool areas are not always free of occupancy and even if the pool on its own won't burn, the combustible
items on the perimeter of the pool can burn. Additionally, although this section does read that if the pool is
equipped with a hard cover that would allow activities, then sprinklers would be required, such covers may be
retrofitted to the pool at a later date and leave this area unprotected. The area above indoor swimming pools
should be equipped with sprinkler protection and this general exception should not be in the standard.
Related Item
First Revision No. 132-NFPA 13-2013 [New Section after 8.15.23.3.1]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Thu May 08 08:38:35 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 369-NFPA 13-2014 [ Sections 8.15.24.2.1, 8.15.24.2.2, 8.15.24.2.3 ]
Sections 8.15.24.2.1, 8.15.24.2.2, 8.15.24.2.3
8.15.24.2.1
The area directly above indoor swimming pools shall not require sprinkler protection unless the
requirements of 8.15.24.2.2 apply.
8.15.24.2.2
The area above indoor swimming pools equipped with moveable hard covers that allow the area to be
used for athletic activities other than swimming and other water sports shall require sprinkler protection.
8.15.24.2.3
Sprinklers shall be installed in all areas adjacent to indoor swimming pools.
Statement of Problem and Substantiation for Public Comment
The Committee did not hear any data regarding this omission. There have been fires over pool areas and these
areas need to be protected.
Related Item
First Revision No. 132-NFPA 13-2013 [New Section after 8.15.23.3.1]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Academy of Fire Sprinkler Tech
Street Address:
City:
State:
Zip:
Submittal Date:
Mon May 19 13:10:55 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 148-NFPA 13-2014 [ Section No. 8.16.1.1.3.4 ]
Please reconsider and revise Section 8.16.1.1.3.4 , to read as follows:
8.16.1.1.3.4
Check valves shall be installed in a vertical (flow upwards) or horizontal position in accordance with their
listing.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_8-16-1-1-3-4.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
As noted in the Substantiation for PI 290, a common mistake in design and in installation is to install check valves
in a vertical “flow downwards” orientation. See the image below as an example:
See the uploaded file for the Figure
Fire protection check valves are not listed for this “flow downwards” orientation, but many designers and installers
do not seem to be aware of this and they do not routinely have or they do not check the listing criteria or
manufacturer’s literature for this type of detail. This leads to installation errors in the field.
Many such installation errors could be eliminated, simply by adding the two words “flow upwards” into the Section.
Related Item
Public Input No. 290-NFPA 13-2013 [Section No. 8.16.1.1.3.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 25 14:26:23 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 150-NFPA 13-2014 [ Section No. 8.16.1.5 ]
Reconsider the proposal and do not move the text concerning floor control valves to Section 8. 2.
Leave it as 8. 16.1.5 , as it currently is in the 2013 edition of NFPA 13.
8.16.1.5 *
In-Rack Sprinkler System Control Valves.
8.16.1.5.1
Unless the requirements of 8.16.1.5.2 or 8.16.1.5.3 are met, where sprinklers are installed in racks,
separate indicating control valves and drains shall be provided and arranged so that ceiling and in-rack
sprinklers can be controlled independently.
8.16.1.5.2
Installation of 20 or fewer in-rack sprinklers supplied by any one ceiling sprinkler system shall not require a
separate indicating control valve.
8.16.1.5.3
The separate indicating valves shall be permitted to be arranged as sectional control valves supplied from
the ceiling sprinkler system where in-rack sprinklers are required and the racks including the adjacent aisles
2
2
occupy 8000 ft (750 m ) or less of the area protected by the ceiling sprinklers.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_8-16-1-5.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
This information on Floor Control Assemblies should not be moved to Section 8.2 as proposed. The subject matter
of 8.2 is Area Limitations, so it is not appropriate to move the information there. The text is better suited to remain
as part of Section 8.16.1, where the subject matter is Control Valves.
Related Item
First Revision No. 153-NFPA 13-2013 [Section No. 8.16.1.5]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 08:35:40 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 151-NFPA 13-2014 [ Section No. 8.16.4.1.4.2 ]
Reconsider the proposal and return the text of 8.16.4.1.4.2
Heat tracing systems shall be supervised by one of the following methods:
Central station, proprietary, or remote station signaling service
Local signaling service that will cause a signal at a constantly attended location
to that of the 2013 edition of NFPA 13, as follows:
8.16.4.1.4.2
Electric supervision of the heat-tracing system shall provide positive confirmation that the circuit is
energized.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_8-16-4-1-4-2.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
This proposal is not appropriate for NFPA 13, which is provides the minimum requirements, such that the
waterflow alarm and the control valves do not require electrical supervision. The proposal for such severe
electrical supervision for heat tracing is therefore beyond what can be reasonably asked for. The existing
requirement to simply provide positive confirmation should stay in effect.
Related Item
First Revision No. 164-NFPA 13-2013 [Section No. 8.16.4.1.4.2]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 08:38:48 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 152-NFPA 13-2014 [ Section No. 8.16.6 ]
8.16.6 *
Air Venting.
The An vent shall be located near the highest a high point in the system to remove the majority of the air
allow air to be removed from the system by one of the following methods:
(1) Manual valve, minimum 1 ⁄2 in. size
(2) Automatic air vent
(3) Other approved means
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-16-6.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
This revision is suggested because a single air vent, even one located at the highest point of a system, cannot be
expected to expel "the majority" of air from the system. All that should be asked for is that air be removed. The
reference to A.8.16.4.2.2 was added to direct the users of the standard to the place in the Annex where the
purpose of the air vent is explained.
Related Item
First Revision No. 294-NFPA 13-2013 [New Section after 8.16.5]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 08:40:47 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 192-NFPA 13-2014 [ Section No. 8.16.6 ]
8.16.6* Air Venting.
The vent shall be located near the highest point in the system to remove the majority of the air by one of
the following methods:
(1) Manual valve, minimum 1 ⁄2 in. size
(2) Automatic air vent
(3) Other approved means
Statement of Problem and Substantiation for Public Comment
CC NOTE: The following CC Note No. 2 appeared in the First Draft Report as First Revision No. 294 and Global
First Revision No. 280.
The CC encourages the SSI TC to review the new venting language. The new venting requirements require the
vent to remove the “majority” of air. This language is unenforceable and may lead to a NITMAM eliminating what is
otherwise a concept that was looked at favorably by the TC. Furthermore, the TC should review the concept of
“ganged venting” to make sure that the proposed language adequately addresses this potential application.
Related Item
First Revision No. 294-NFPA 13-2013 [New Section after 8.16.5]
First Revision No. 280-NFPA 13-2013 [Section No. A.8.16.4.2.2]
Submitter Information Verification
Submitter Full Name: CC on AUT-AAC
Organization:
CC on Automatic Sprinkler Systems
Street Address:
City:
State:
Zip:
Submittal Date:
Tue Apr 29 14:08:02 EDT 2014
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Public Comment No. 217-NFPA 13-2014 [ Section No. 8.16.6 ]
8.16.6 *
Air Venting.
The vent shall be located near the highest point in the system to remove the majority of the air by one of
the following methods:
(1) Manual valve, minimum 1 ⁄ 2
in. size
(2) Automatic air vent
(3) Other approved means
Statement of Problem and Substantiation for Public Comment
This public comment seeks to delete this section. Additional comment to delete section 7.1.5 which required air
venting was also submitted with the substantiation that air venting may cause unintended consequences. Some air
in the sprinkler system is a positive thing. It acts as a cushion to pressure surges. Air is compressible, water is not.
The more air we take out of sprinkler systems, the more problems we are going to have with pressure changes
blowing apart systems, pegging gages, and causing other damage. Air acts as a cushion to deal with transient
pressure surges. As we remove more air out of the sprinkler systems, we will have bigger problems with pressure
and water hammer.
Additionally the language of this section, specifically "located near the highest point" and "majority of air" is
subjective and will cause will be difficult to enforce by AHJs and difficult to interpret by contractors.
Additional comments have been made to remove language for air venting from section 7.1.5 and 25.6.2. The
Annex note A.16.4.2.2 (2013 edition) is to be preserved as it contains valuable information when air venting is
deemed to be warranted.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 216-NFPA 13-2014 [Section No. 7.1.5]
Related Item
First Revision No. 280-NFPA 13-2013 [Section No. A.8.16.4.2.2]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Associ
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Wed May 07 10:15:38 EDT 2014
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Public Comment No. 350-NFPA 13-2014 [ Section No. 8.16.6 ]
8.16.6 *
Air Venting.
The vent required by section 7.1.5 shall be located near the highest point in the system to remove the
majority of the air by one of the following methods:
(1) Manual valve, minimum 1 ⁄2 in. size
(2) Automatic air vent
(3) Other approved means
Statement of Problem and Substantiation for Public Comment
The NFSA is not in favor of venting all wet pipe systems and we are submitting proposals to remove those
requirements. But in the event that they go forward, then need to be clarified.
Just saying “the vent” is not clear enough. This could easily be interpreted as a requirement for vents on all
sprinkler systems. We think that the intent was to limit the vents in this section to those required by section 7.1.5.
If so, this needs to be more clearly stated.
Related Item
First Revision No. 294-NFPA 13-2013 [New Section after 8.16.5]
Submitter Information Verification
Submitter Full Name: Kenneth Isman
Organization:
National Fire Sprinkler Association
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 14:54:40 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 153-NFPA 13-2014 [ Section No. 8.17.2.6.1 ]
Revise the text to more closely match that of Section 5.9.4.2 of NFPA 24, as follows:
8.17.2.6.1
The automatic drain valve shall be installed in a location that permits inspection and testing as required by
NFPA 25 and reduced the likelihood of freezing .
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-17-2-6-1.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
Co-ordination with 5.9.4.2 of NFPA 24. In the Committee Statement for FR-157 it was stated that the same
instruction for accessibility and freeze protection should be provided in NFPA 13, but the text about freeze
protection was not included in the First Draft Report.
Related Item
First Revision No. 157-NFPA 13-2013 [New Section after 8.17.2.5.1]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 08:43:09 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 154-NFPA 13-2014 [ Section No. 8.18 ]
8.18 Electrical Bonding and Grounding.
8.18.
1*
Fire sprinkler systems shall be permitted to be used for bonding in accordance with NFPA 70
1 In no case shall sprinkler system piping be used for the grounding of electrical systems .
8.18.2
Fire sprinkler systems shall not be used for grounding of electrical systems
* The requirement of 8.18.1 shall not preclude the bonding of the sprinkler system piping to the
lightning protection grounding system as required by NFPA 780 in those cases where lightning
protection is provided for the structure .
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-18.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
Editorial revision to co-ordinate the text with the similar provisions for grounding and bonding of NFPA 24.
A sprinkler system is not "used for" bonding, it is "bonded to". Therefore, I would suggest that the wording of NFPA
24 should be followed more closely.
Related Item
First Revision No. 152-NFPA 13-2013 [New Section after 8.17]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 08:45:26 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 213-NFPA 13-2014 [ Section No. 25.2.1.4 ]
25.2.1.4 *
Modifications to existing piping systems affecting 20 or fewer sprinklers shall not require testing in excess
of system working pressure.
Statement of Problem and Substantiation for Public Comment
This proposed change is to return this section to the language of the 2013 edition. There is no justification that
large modifications to existing systems should not be required to be tested for integrity with a 200 psi hydrostatic
test. The first revision would allow an modifications affecting an unlimited number of sprinklers and their
associated piping to be put into service without ensuring that this pipe is leak-free with a 200 psi hydrostatic test.
Such large modifications should be held to the same standard as new systems. The previous edition requirements
to isolate these large modifications and test at 200 psi is a reasonable measure and should remain as a
requirement of the standard.
Related Item
First Revision No. 286-NFPA 13-2013 [Section No. 25.2.1.4]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Wed May 07 08:48:52 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 370-NFPA 13-2014 [ Section No. 25.2.1.4 ]
25.2.1.4 *
Modifications to existing piping systems shall not require testing in excess of 20 psi above system working
pressure.
Statement of Problem and Substantiation for Public Comment
It is irresponsible to not require testing at some pressure above working pressure to ensure system integrity.
Related Item
First Revision No. 288-NFPA 13-2013 [Section No. 25.2.1.6]
Submitter Information Verification
Submitter Full Name: Cecil Bilbo
Organization:
Academy of Fire Sprinkler Tech
Street Address:
City:
State:
Zip:
Submittal Date:
Mon May 19 13:11:51 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 179-NFPA 13-2014 [ Sections 25.2.1.4, 25.2.1.5, 25.2.1.6 ]
Reconsider the proposals and return the text of 25.2.1.4 through 25.2.1.6 to that of the 2013 edition
of NFPA 13, as follows:
25.2.1.4 Modifications affecting 20 or fewer sprinklers shall not require testing in excess of system
working pressure.
25.2.1.5 Where addition or modification is made to an existing system affecting more than 20
sprinklers, the new portion shall be isolated and tested at not less than 200 psi (13.8 bar) for 2
hours.
25.2.1.6 Modifications that cannot be isolated, such as relocated drops, shall not require testing in
excess of system working pressure.
Sections 25.2.1.4, 25.2.1.5, 25.2.1.6
25.2.1.4 *
Modifications to existing piping systems shall not require testing in excess of system working pressure.
25.2.1.5
Where additions are made to an existing system, the new portion shall be isolated and tested at not less
than 200 psi (13.8 bar) for 2 hours.
25.2.1.6
Loss shall be determined by a drop in gauge pressure or visual leakage.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_25-2-1-4.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
The proposed revision should not be accepted. As it is now proposed, any new addition to a sprinkler system,
such as one sprinkler for a new washroom or two sprinklers for a new office will require a minimum 200 psi
hydrostatic test. Such small installations cannot be easily isolated; to do so would be an impractical and expensive
undertaking. No documentation has been offered as to why the exemption for 20 sprinklers is being deleted. This
will cause problems and undue expense in the field if this new wording is adopted.
Related Item
Public Input No. 247-NFPA 13-2013 [Section No. 25.2.1.4]
Public Input No. 248-NFPA 13-2013 [Section No. 25.2.1.5]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 09:49:32 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 215-NFPA 13-2014 [ New Section after 25.2.1.5 ]
25.2.1.6
Modifications that cannot be isolated, such as relocated drops, shall not require testing in excess of system
working pressure.
Statement of Problem and Substantiation for Public Comment
This public comment is to return to the language of section 25.2.1.6 from the 2013 edition of NFPA 13. This
section was deleted in the first draft report. As public comment #213 and #214 seek to return to the previous
edition language, this section is necessary to clarify that modifications such as relocated drops are not required to
be tested in excess of system working pressure.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 213-NFPA 13-2014 [Section No. 25.2.1.4]
Public Comment No. 214-NFPA 13-2014 [Section No. 25.2.1.5]
Related Item
First Revision No. 287-NFPA 13-2013 [Section No. 25.2.1.5]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Wed May 07 09:54:37 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 127-NFPA 13-2014 [ Section No. 25.2.1.5 ]
25.2.1.5
Where additions of more than 10 sprinklers are made to an existing system, the new portion shall be
isolated and tested at not less than 200 psi (13.8 bar) for 2 hours.
Statement of Problem and Substantiation for Public Comment
As written, iy I add a single sprinkler, I have to isolate it and test it at 200 PSI.
Related Item
First Revision No. 287-NFPA 13-2013 [Section No. 25.2.1.5]
Submitter Information Verification
Submitter Full Name: Peter Schwab
Organization:
Wayne Automatic Fire Sprinkler
Street Address:
City:
State:
Zip:
Submittal Date:
Fri Apr 18 15:42:03 EDT 2014
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Public Comment No. 18-NFPA 13-2014 [ Section No. 25.2.1.5 ]
25.2.1.5
Where additions are made to an existing system, the new portion shall be isolated and tested at not less
than 200 psi (13.8 bar) for 2 hours.
Statement of Problem and Substantiation for Public Comment
25.2.1.4 is in conflict with 25.2.1.5
Related Item
First Revision No. 286-NFPA 13-2013 [Section No. 25.2.1.4]
First Revision No. 287-NFPA 13-2013 [Section No. 25.2.1.5]
Submitter Information Verification
Submitter Full Name: Mark Fessenden
Organization:
Tyco Fire Protection Products
Street Address:
City:
State:
Zip:
Submittal Date:
Wed Mar 12 09:30:43 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 214-NFPA 13-2014 [ Section No. 25.2.1.5 ]
25.2.1.5
Where additions are addition or modification is made to an existing system affecting more than 20
sprinklers , the new portion shall be isolated and tested at not less than 200 psi (13.8 bar) for 2 hours.
Statement of Problem and Substantiation for Public Comment
This proposed change is to return this section to the language of the 2013 edition. There is no justification that
large modifications to existing systems should not be required to be tested for integrity with a 200 psi hydrostatic
test. The first revision would allow an modifications affecting an unlimited number of sprinklers and their
associated piping to be put into service without ensuring that this pipe is leak-free with a 200 psi hydrostatic test.
Such large modifications should be held to the same standard as new systems and additions to new systems. The
previous edition requirements to isolate these large modifications and test at 200 psi is a reasonable measure and
should remain as a requirement of the standard.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 213-NFPA 13-2014 [Section No. 25.2.1.4]
Related Item
Public Input No. 248-NFPA 13-2013 [Section No. 25.2.1.5]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
State:
Zip:
Submittal Date:
Wed May 07 09:29:53 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 260-NFPA 13-2014 [ New Section after 25.2.2 ]
Add new text:
25.2.2.3 Modifications affecting 20 or fewer sprinklers shall not require an air or nitrogen pressure leakage
test.
25.2.2.4 Where an addition or modification is made to an existing system affecting more than 20
sprinklers, the new portion shall be isolated and tested.
25.2.2.5 Modifications that cannot be isolated, such as relocated drops, shall not require an air or nitrogen
pressure leakage test.
Statement of Problem and Substantiation for Public Comment
The committee statement referring to the hydrostatic test makes no sense. My comment is addressing the air
leakage test. NFPA 25 allows air leakage for existing systems. New systems installed do not generally have a
problem with the air or gas leakage tests. The issue with air leakage occurs when an existing dry pipe or preaction
system is modified where the installing contractor of the modified portion of the system is now responsible for
repairing air or gas leaks in the entire system where modifications were not made. The piping at times is located in
concealed spaces that are not accessible. Contractors cannot get their piping modifications accepted since the
existing system cannot pass the NFPA 13 air or gas pressure leakage test.
Related Item
Public Input No. 485-NFPA 13-2013 [New Section after 25.2.2]
First Revision No. 286-NFPA 13-2013 [Section No. 25.2.1.4]
Submitter Information Verification
Submitter Full Name: Thomas Wellen
Organization:
American Fire Sprinkler Associ
Street Address:
City:
State:
Zip:
Submittal Date:
Wed May 14 11:02:03 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 218-NFPA 13-2014 [ Section No. 25.6.2 ]
25.6.2
The sign shall include the following information:
(1) Name and location of the facility protected
(2) Occupancy classification
(3) Commodity classification
(4) Presence of high-piled and/or rack storage
(5) Maximum height of storage planned
(6) Aisle width planned
(7) Encapsulation of pallet loads
(8) Presence of solid shelving
(9) Flow test data
(10) Presence of flammable/combustible liquids
(11) Presence of hazardous materials
(12) Presence of other special storage
(13) Location of venting valve
(14) Location of auxiliary drains and low point drains on dry pipe and preaction systems
(15) Original results of main drain flow test
(16) Original results of dry pipe and double interlock preaction valve test
(17) Name of installing contractor or designer
(18) Indication of presence and location of antifreeze or other auxiliary systems
(19) Where injection systems are installed to treat MIC or corrosion, the type of chemical, concentration of
the chemical, and where information can be found as to the proper disposal of the chemical
Statement of Problem and Substantiation for Public Comment
Public comments to remove the requirement for air venting has been submitted and if accepted, the general
information sign should not require the location of the air vent.
Related Public Comments for This Document
Related Comment
Relationship
Public Comment No. 217-NFPA 13-2014 [Section No. 8.16.6]
Related Item
First Revision No. 136-NFPA 13-2013 [Section No. 25.6.2]
Submitter Information Verification
Submitter Full Name: Roland Asp
Organization:
National Fire Sprinkler Association
Affilliation:
NFSA E&S Committee
Street Address:
City:
5/19/2014 1:50 PM
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State:
Zip:
Submittal Date:
Wed May 07 10:31:03 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 180-NFPA 13-2014 [ Section No. A.3.3.4 ]
A.3.3.4 Ceiling Pocket.
It is not the intent of this definition to be applied to structural and/or framing members otherwise used to
define obstructed or unobstructed construction. Ceiling pockets can be protected or unprotected. A ceiling
pocket where the upper ceiling is within the allowable vertical distance from the sprinkler deflector should
be considered a protected ceiling pocket. Buildings with protected ceiling pockets are permitted to use the
2
quick-response reduction of 11.2.3.2.3. Buildings with unprotected ceiling pockets greater than 32 ft (9.8
2
m ) are not allowed to use the quick-response reduction of 11.2.3.2.3 . An architectural ceiling feature that
consists of a bounded area of ceiling located at a higher elevation than the attached lower ceiling, and
where the depth of the pocket is greater than the allowable distance, a sprinkler deflector can be located
from the higher ceiling elevation.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_A-3-3-4.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
The proposed new sentence is obscure, the sentence structure is poor and it does not add any value to the
section, in fact it is contradictory. The Committee Statement says that the additional verbiage is to clarify that
where a sprinkler can be located in the lower ceiling and still meet the deflector distance rule; the upper ceiling
should not be considered a ceiling pocket. However, this is contrary to the actual 3.3.4 definition and to the 2nd
sentence of A.3.3.4, which says that a ceiling pocket where the upper ceiling is within the allowable vertical
distance from the sprinkler deflector should be considered a protected ceiling pocket.
Related Item
First Revision No. 75-NFPA 13-2013 [Section No. A.3.3.4]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 09:52:49 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 183-NFPA 13-2014 [ Sections A.6.2.1.1, A.6.2.1.1.1 ]
Sections A.6.2.1.1, A.6.2.1.1.1
A.6.2.1.1
Sprinklers should be permitted to be reinstalled when the sprinkler being removed from the system remains
attached to the original fitting or welded outlet, provided care has been taken to ensure the sprinkler has
not been damaged. Flexible hose connections are considered a fitting.
In new installations, where sprinklers are installed on pendent drop nipples or sidewall sprinklers prior to
final cut-back, protective caps and/or straps should remain in place until after the drop nipple has been cut
to fit to the final ceiling elevation.
A.6.2.1.1.1
Provided dry sprinklers are removed by utilizing a pipe wrench on the barrel, where permitted by the
manufacturer, they can be reinstalled. If a dry sprinkler is removed by utilizing the sprinkler wrench on the
boss of the sprinkler, the dry sprinkler should not be reinstalled.
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_A-6-2-1-1.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
The idea of removing a sprinkler and thinking that it won't be damaged is a fallacy. There are more ways to
damage a sprinkler than by torque. Handling and storage is the critical issue. The need for caps and straps on
new sprinklers came from damage during the handling of sprinklers from right out of the manufactures cartons, so
it is not possible to assure similar damage won't occur to a dry pendent sprinkler or to a sprinkler attached to a
drop nipple that is removed from its installed location. See the images below as examples:
See the uploaded file for Figures
Related Item
First Revision No. 67-NFPA 13-2013 [New Section after A.6.1.1]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 10:01:43 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 259-NFPA 13-2014 [ Section No. A.8.15.1.3 ]
A.8.15.1.3
Utilities and other building services can be located within the concealed spaces. There are many variables
that need to be taken into account when determing the density for any specific scenario. Most utilities and other
building services are sources of ignition and do not significantly add to fuel load where the light hazard
density can be applied.
Statement of Problem and Substantiation for Public Comment
AHJs are requiring an ordinary hazard density simply from the presence of an air handling unit or heater that is
located within a concealed space. The fuel loading is not significantly increased - it's just an ignition source.
Wording is needed that the light hazard density is sufficient for these scenarios. The only reason there is ordinary
hazard designs for most mechanical rooms is that the room can be used for storage. This is a concealed space
where no storage is permitted.
Related Item
First Revision No. 143-NFPA 13-2013 [New Section after A.8.15.1.2.17]
Public Input No. 513-NFPA 13-2013 [New Section after 8.15.1.3]
Submitter Information Verification
Submitter Full Name: Thomas Wellen
Organization:
American Fire Sprinkler Association
Street Address:
City:
State:
Zip:
Submittal Date:
Wed May 14 09:32:43 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 335-NFPA 13-2014 [ New Section after A.8.15.14 ]
A.8.15.15
A.8.15.15.1 There are ceiling panels and ceiling materials that have been investigated as a ceiling material
in accordance with UL Subject 723S, Outline of Investigation for Drop-Out Ceilings Installed Beneath
Automatic Sprinklers or as FM Class Number 4651, Plastic Suspended Ceiling Panels. Such ceiling
panels and ceiling materials are designed such that the activation of the sprinkler and the ability of the
sprinkler discharge to reach the hazard being protected are not adversely impacted.
Statement of Problem and Substantiation for Public Comment
This is a companion change to Public Comment 330 and provides the criteria by which drop out ceilings and
ceiling materials are to be listed.
Related Public Comments for This Document
Related Comment
Public Comment No. 330-NFPA 13-2014 [Section No.
8.15.15]
Relationship
Annex note associated with Public Comment
text.
Related Item
Committee Input No. 155-NFPA 13-2013 [Global Input]
Submitter Information Verification
Submitter Full Name: William Koffel
Organization:
Koffel Associates, Inc.
Affilliation:
Representing TuffWrap
Street Address:
City:
State:
Zip:
Submittal Date:
Fri May 16 13:49:29 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 184-NFPA 13-2014 [ Section No. A.8.16.2.4.2 ]
A.8.16.2.4.2
This is a very Sizing the main drain connection so that it can flow the sprinkler system demand flow rate
provides a practical means for performing the forward flow test of the backflow device as required by
8.17.4.5.1.
Additional Proposed Changes
File Name
LGK_NFPA_13-2013_Comment_A-8-16-2-4-2.pdf
Description Approved
PC Form
Statement of Problem and Substantiation for Public Comment
Editorial revision for clarity.
Related Item
First Revision No. 154-NFPA 13-2013 [Section No. 8.16.2.4.2]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 10:04:05 EDT 2014
5/19/2014 1:50 PM
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Public Comment No. 155-NFPA 13-2014 [ Section No. A.8.18.1 ]
A.8.18. 1
2
While the use of the sprinkler system piping as the grounding electrode for the building is prohibited, NFPA
70 requires that all metallic piping systems be bonded to disperse stray electrical currents. Therefore, the
sprinkler system piping should be bonded to other metallic systems.
Additional Proposed Changes
File Name
Description Approved
LGK_NFPA_13-2013_Comment_8-18.pdf
PC Form
Statement of Problem and Substantiation for Public Comment
Editorial revision to co-ordinate the text with the similar provisions for grounding and bonding of NFPA 24.
A sprinkler system is not "used for" bonding, it is "bonded to". Therefore, I would suggest that the wording of NFPA
24 should be followed more closely.
Related Item
First Revision No. 152-NFPA 13-2013 [New Section after 8.17]
Submitter Information Verification
Submitter Full Name: Larry Keeping
Organization:
Professional Loss Control
Street Address:
City:
State:
Zip:
Submittal Date:
Mon Apr 28 08:48:33 EDT 2014
5/19/2014 1:50 PM