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Public Comment No. 82-NFPA 101-2013 [ New Section after
8.2.3.1.2 ]
8.2.3.1.3* The fire resistance rating of an element or assembly determined by tests
conducted in accordance with NFPA 251 or other approved test methods shall not
be permitted to rely on an automatic fire protection system, unless evaluated as an
equivalency in accordance with Section 1.4 or as part of a performance-based option
in accordance with Chapter 5.
Statement of Problem and Substantiation for Public Comment
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This proposal deals with the basics of fire resistance rated assemblies that become
continuous systems when installed to the listed design. The inappropriate use of sprinkler
technology in combination with construction elements to assign a “fire resistance rating in
accordance with ASTM E119, UL 263, or NFPA 251”, creates a risk to life safety in
buildings. Fire-resistance ratings represent the inherent fire resistance of an assembly or
system (passive fire protection), independent of any active fire protection, (water washing).
Some parties submit test reports to AHJs claiming non fire rated assemblies have “fireresistance ratings” that are derived from modified test standards using a flow of cooling
water on the assembly surfaces during the fire test.
Fire-resistance ratings are a property that is meant to represent the inherent resistance to
fire of an assembly (passive fire protection), independent of any active fire protection. The
code already allows the ability to reduce a fire rating once a sprinkler system and other
elements are installed. This water washing of an assembly potentially doubles the ‘trade
off’.
Designers feel that because the atrium language permits sprinkler protection in lieu of the 1
-hour fire separation requirements that it is acceptable in other areas of buildings. ASTM
E119, NFPA 251, and UL 263 make no provisions for testing such combinations to achieve
fire-resistance ratings.
NFPA 101provided two options that are acceptable for proving equivalency:
1.
2.
The equivalency provisions of Section 1.4
Performance-based option in Chapter 5.
Those are established processes that are scientific. There are several other elements to
consider in addition to washing the element. Since the source of this ‘concept for fire
rating’ appears to be derived from the requirements for glazing used in atria, below is the
the explanatory language that has existed in NFPA 101 as early as 1988 and remains in
the 2012 edition:
“The intent of the requirement for closely spaced sprinklers to wet the atrium glass wall is
to ensure that the surface of the glass is wet upon operation of the sprinklers…The concept
of wetting the glass that is exposed to a fire, without specifying a water application rate, is
similar to boiling water in a Pyrex® container over an open flame. As long as there is some
water present to absorb the heat, the glass itself does not reach excessive temperatures
that would cause failure [emphasis added].
Found 2012 edition of the 101 Handbook: “To allow visual contact between the atrium and
floors that have not been proven by engineering analysis to warrant openness, 8.6.7(1)(c)
permits smoke-resisting separation consisting of glass walls, vision panels, and windows in
lieu of 1-hour-rated fire barriers” [emphasis added].
So the language found within the Handbook explains by use of example that the purpose of
the sprinklers wetting the glazing is to prevent failure of the partition and newer language
further explains that the TC is permitting a smoke-resisting separation in lieu of 1-hour. The
language seems to indicate that the TC realizes that this will not be a 1-hour fire-resistance
rated partition. There is just no scientific effort presented to this committee that sprinklers
somehow provide and equivalent fire-resistance rating.
In the last revision cycle, negative voters cited the fact that this provision, which existed in
the 2009 edition of NFPA 5000 was removed. This was not done for technical reason, but
rather, for consistency with NFPA 101 (NFPA 5000, Section 8.2.1.3). The correct technical
position is to include this provision in both Codes. Also, as a reminder, for the 2012 edition,
the requirement passed committee, failed in the letter ballot, passed on the floor and then
failed again in the letter ballot after the annual meeting. The last ballot for the 2015 edition
(First Revision) failed by < 1% or 1 vote.
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Where the Code specifies the need for a 1-hour assembly, the intent in the development of
that code provision would have clearly been to have an assembly that could survive a fire
without being breached and without losing any load-bearing capabilities all by itself, without
relying on an external water source of continued cooling. If sprinkler protection was also
required for such occupancy, then the overall intent of the Code is to have these tow
systems act independently, but in concert with each other.
Submitter Information Verification
Submitter Full Name: Catherine Stashak
Organization:
Office of the Illinois State Fire Marshal
Submittal Date:
Fri Apr 26 11:59:50 EDT 2013
Copyright Assignment
I, Catherine Stashak, 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 Catherine Stashak, 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. 51-NFPA 101-2013 [ New Section after
8.3.3.2.3 ]
TITLE OF NEW CONTENT 8.3.3.2.3.1
In existing installations, steel door frames without a label are permitted where
approved by the AHJ.
Statement of Problem and Substantiation for Public Comment
The reference to "legible" labels was removed to address the comment from the committee
that the initial proposed text would have permitted existing labels to be made illegible which
is not the intent of the proposed code change. Steel door frames in good condition
routinely recieve a labels during inspection from a testing lab at a cost to the building
owner. The proposed change is consistent NFPA 5000 Section 15.5.2.2.5 on building
rehabilitation which requires door frames to be provided with a label OR be constructed of
steel.
Submitter Information Verification
Submitter Full Name: LENNON PEAKE
Organization:
KOFFEL ASSOCIATES INC
Submittal Date:
Mon Apr 08 13:52:30 EDT 2013
Copyright Assignment
I, LENNON PEAKE, 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 LENNON PEAKE, 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. 71-NFPA 101-2013 [ New Section after 8.5.6.4 ]
(NEW) 8.5.6.5 Penetrations in smoke barriers shall be protected by an approved
through penetration firestop system tested in accordance with the requirements of
UL 1479 for air leakage and installed to the listed system and manufacturers
instructions. The L rating of the system measured at 0.30 inch (7.47 Pa) of water in
both the ambient temperature and elevated temperature tests, shall not exceed:
1. 5.0 cfm per square foot (0.025 m3/s m2) of penetration opening for each throughpenetration fire stop system; or
2. A total cumulative leakage of 50 cfm (0.024 m3/s) for any 100 square feet (9.3 m2)
of wall area, or floor area.
Statement of Problem and Substantiation for Public Comment
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Currently, the Code requirements for smoke barriers lack quantitative guidance and
performance requirements for the maximum leakage that is acceptable. Designers,
contractors and AHJs have no way to determine acceptability of individual or a complete
area of penetration or joint firestops. Simply put: How much leakage is too much before the
barrier is no longer a smoke barrier?
The Life Safety code already recognizes that there are instances in Chapters 11 through
43 where leakage rated doors and dampers are required. What is still lacking is identifying
a performance level that is realistic and achievable for joints and penetrations in Smoke
Barriers.
This proposed Code change is intended to improve the Code regarding the requirements
for smoke leakage through penetrations in smoke barriers. The proposal has been
modified to only require leakage rated penetration for new construction as requested by the
Committee. In these cases, this proposal would allow 5 cfm/ft2 for individual through
penetrations as one option, and would also allow an alternative requirement for the
cumulative total leakage of all through-penetrations in a given area of smoke barrier.
NFPA 101 currently includes requirements for individual components, such as doors in
corridors and smoke barriers, to be tested in accordance with a nationally recognized UL
Standard (UL 1784) for the quantitative measurement of air leakage rates through door
assemblies under prescribed conditions.
To be consistent in Smoke Barrier code language, it is reasonable to require a total smoke
barrier performance level per 100 ft2 (for example) in addition to dealing with individual
items. Individual items are permitted to have maximum smoke leakage, but the sum of the
total cannot exceed an identified criteria. This mehtod will permit flexibility with the
individual penetrations, but more comprehensive on the smoke barrier leakage
performance.
The 50 cfm suggested here is the theoretical maximum of 10 through penetraions at
maximum allowed 5 cfm/ft2 in 100 ft2 of wall or floor area.
The Life Safety Code permits 1 sq. ft. of leakage are per 1,000 ft2 of wall space. Based on
some fundamental assumptions about anticipated presure differentials during fires, the
cumulative value of 50 cfm per 100 ft2 proposed also represents approximately 50% of that
permitted leakage.
Consequently, if installing a through-penetration firestop system that has an L-Rating of
more than 5.0 cfm/ft2, such as might be the case for a cable tray where additional leakage
can occur between the individual cables in a bundle, then the overall installation can still be
compliant with the Code either by spacing out the penetrations sufficiently to maintain the
average leakage of 50cfm/100ft2 or ensure that other through-penetrations within the same
100 ft2 control area have leakage rates that are low enough to compensate for one or more
penetrations with higher L-Ratings.
The addition of the UL 1479 Air Leakage rating will provide a nationally recognized UL
Standard for the quantitative measurement of air leakage rates through a barrier containing
penetrations under prescribed conditions. This would follow the same approach currently
taken in NFPA 101 for the other elements within smoke barriers, and would be consistent
with the current smoke barrier requirements in other model building codes. The UL and
Intertek directories identify "L" ratings and contain thousands of penetration and joint
designs that have an "L" rating. The knowledge required for firestop "L-Rated Systems" is
the same as for systems selection of the firestop.
Submitter Information Verification
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Submitter Full Name: Catherine Stashak
Organization:
Office of the Illinois State Fire Marshal
Submittal Date:
Thu Apr 25 13:16:58 EDT 2013
Copyright Assignment
I, Catherine Stashak, 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 Catherine Stashak, 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. 12-NFPA 101-2013 [ Section No. 8.6.9.2 ]
8.6.9.2
Where permitted by Chapters 11 through 43 , unenclosed vertical
openings created by convenience stairways shall be permitted as
follows:
(1)
The convenience stair openings shall not serve as required
means of egress.
(2)
The building shall be protected throughout by an approved,
supervised automatic sprinkler system in accordance with
Section 9.7 .
(3) * The convenience stair openings shall be protected in
accordance with the method detailed for the protection of vertical
openings in NFPA 13, Standard for the Installation of Sprinkler
Systems .
(4)
In new construction, the area of the floor opening shall not
exceed twice the horizontal projected area of the stairway.
(5)
(5) For new construction, such openings shall not connect more
than four contiguous stories unless otherwise permitted by
chapter 11 through 43 .
Statement of Problem and Substantiation for Public Comment
This comment is in relation ot CI 1. The issues associated with allowing such openings to
connect several stories are related to fire behavior and other physical phenomena (i.e.
stratification, stack effect, etc.) and are not occupancy specific.
Submitter Information Verification
Submitter Full Name: Bill Galloway
Organization:
Southern Regional Fire Code De
Submittal Date:
Tue Mar 12 13:43:18 EDT 2013
Copyright Assignment
I, Bill Galloway, 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 Bill Galloway, 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. 127-NFPA 101-2013 [ Section No. 8.6.9.2 ]
8.6.9.2
Where permitted by Chapters 11 through 43 , unenclosed
vertical openings created by convenience stairways shall be
permitted as follows:
(1) The convenience stair openings shall not serve as required
means of egress.
(2) The building shall be protected throughout by an approved,
supervised automatic sprinkler system in accordance with
Section 9.7 .
(3) * The convenience stair openings shall be protected in
accordance with the method detailed for the protection of vertical
openings in NFPA 13, Standard for the Installation of Sprinkler
Systems .
(4) In new construction, the area of the floor opening shall not
exceed twice the horizontal projected area of the stairway.
(5) The convenience stair opening shall not connect more than
two adjacent stories (one floor pierced only).
Additional Proposed Changes
File Name
101_Original.pdf
Description Approved
Orignal Comment
Statement of Problem and Substantiation for Public Comment
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Related to PI 208
Problem: This new provision in the 2012 edition of NFPA 101 and NFPA 5000 for
convenience stairs permits unenclosed vertical openings created by convenience stairs to
potentially be installed in any occupancy, with no limitation on the maximum number of
interconnected floors. It is not justifiable to extend the protection measures previously
permitted for escalators to all convenience openings. This proposals restores the 2 storey
limitation for convenience openings from the 2009 edition.
Substantiation: This article introduces an unjustified level of risk to building occupants.
This provision was added into the 2012 Life Safety Code and NFPA 5000 based on a
proposal from the Detention and Care technical Committee. The item was information
balloted to the BLD-FIR after their meeting had occurred. It was never justified Technically.
One of the fundamental requirements of the Life Safety Code is that the design of buildings
cannot rely solely on any one means of safeguarding occupants. This section relies
exclusively on sprinkler performance. As we are all aware, sprinklers are an invaluable life
safety and property protection technology. However, even the March 2012 edition of
NFPA’s Report on US Experience with Sprinklers states that the combined performance of
operating effectiveness of sprinklers is 88% of reported fires where sprinklers were present
in the fire area and fire was large enough to activate the sprinklers.
One of the fundamental requirements of the Life Safety Code is that the design of buildings
cannot rely solely on any one means of safeguarding occupants. This section relies
exclusively on sprinkler performance. If sprinklers were to fail to operate, or fail to control a
fire, this large multi-story hole in several floors could allow massive vertical spread of fire
and products of combustion. As we are all aware, sprinklers are an invaluable life safety
and property protection technology. However, even the March 2012 edition of NFPA’s
Report on US Experience with Sprinklers states that the “…combined performance of
operating effectiveness of sprinklers is 88% of reported fires where sprinklers were present
in the fire area and fire was large enough to activate the sprinklers.” This further helps to
justify the over-arching NFPA 101 philosophy that safety to life shall not depend on a single
safeguard, Any permitted vertical opening should include consideration of what would
happen if one protection measure failed,
This new provision for convenience stairs is a major technical change to the philosophy of
NFPA 101 in protection of vertical openings. It is not appropriate to extend the protection
measures previously permitted for escalators to now permit other multi-story convenience
openings. As stated in the substantiation provided on Log 101-190 and Log 101-191b in
the previous (2012 edition) cycle, Escalators represent a unique condition. The closelyspaced sprinkler form of protection has historically been permitted for escalators because it
might be dangerous to enclose an escalator with walls and doors as an escalator will
continue to run and deposit people at a floor even if the door on that floor becomes
inoperative. Users of convenience stairs are not mechanically moved and deposited at a
floor, so it is not necessary to make a special allowance removing the stairway enclosure
needed for fire safety for such convenience stairs.
The solution historically provided for escalators to be protected in accordance with the
method detailed for the protection of vertical openings in NFPA13, Standard for the
Installation of Sprinkler Systems, has been provided out of this necessity. Having this
arrangement for escalator openings may not provide the same level of risk reduction and
same level of smoke and fire containment as an enclosed stair shaft would, but it is a
reasonable accommodation for unavoidable conditions, given that escalators are a building
feature that will need to be accommodated. This sub-optimal but necessary solution should
not be expanded without justification. In the 2012 edition of NFPA 101, Chapters 12 and
13 have already permitted the use of these new unlimited vertical openings for
convenience stairs on the basis of their inclusion in 8.6.9.2. These Chapters address
multiple new and existing assembly occupancies, including dance halls and drinking
establishments. The ability to utilize this provision is not restricted to any occupancy types.
It is highly debatable if allowing these multi-story “convenience openings” for the first time
ever is a reasonable relaxation of fire safety requirements, or if it potentially sacrifices the
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safety of occupants for some architectural freedom that was never needed or allocated
before.
Article 4.5.1 of the Code requires that “The design of every building or structure intended
for human occupancy shall be such that reliance for safety to life does not depend solely
on any single safeguard. An additional safeguard(s) shall be provided for life safety in case
any single safeguard is ineffective due to inappropriate human actions or system failure.”
Further, 4.5.6 under the fundamental requirements for Vertical Openings states “Every
vertical opening between the floors of a building shall be suitably enclosed or protected, as
necessary, to afford reasonable safety to occupants while using the means of egress and
to prevent the spread of fire, smoke, or fumes through vertical openings from floor to floor
before occupants have entered exits.” Sprinklers installed in accordance with the method
detailed for the protection of vertical openings in NFPA13 should not be assumed as
achieving this level of performance, because sprinklers will not prevent the development or
spread of smoke or fumes through these multiple floors. This is particularly true in shielded
fire scenarios. Of course, in the scenario where sprinklers fail to control a fire, which NFPA
statistics indicate could be a 12% probability, then smoke and products of combustion
would definitely not be minimized nor prevented from migrating to other floors, thus
endangering egress on those upper floors.
Submitter Information Verification
Submitter Full Name: TONY CRIMI
Organization:
AC CONSLT SOLUTIONS INC
Submittal Date:
Mon May 06 13:36:10 EDT 2013
Copyright Assignment
I, TONY CRIMI, 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 TONY CRIMI, 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. 13-NFPA 101-2013 [ Section No. 8.6.9.7 ]
8.6.9.7
Any escalators and moving walks not constituting an exit shall have
their floor openings enclosed or protected as required for other vertical
openings, unless otherwise permitted by one of the following:
(1)
The requirement of 8.6.9.7 shall not apply to escalators in large
open areas, such as atriums and enclosed shopping malls.
(2) * In buildings protected throughout by an approved automatic
sprinkler system in accordance with Section 9.7 , escalator and
moving walk openings shall be permitted to be protected in
accordance with the method detailed in NFPA 13, Standard for
the Installation of Sprinkler Systems , or in accordance with a
method approved by the authority having jurisdiction.
(3) In new buildings protected throughout by an approved
automatic sprinkler system in accordance with Section 9.7 ,
escalator and moving walk openings shall be permitted to be
protected by rolling steel shutters appropriate for the fire
resistance rating of the vertical opening and complying with
all of the following in accordance with the method detailed in
NFPA 13, Standard for the Installation of Sprinkler Systems, or in
accordance with a method approved by the authority having
jurisdiction , and the opening shall not connect more than four
contiguous stories unless otherwise permitted by Chapter 11
through 43 . :
(a) The shutters shall close automatically and independently of
each other upon smoke detection and sprinkler operation.
(b) A manual means of operating and testing the operation of
the shutters shall be provided.
(c) The shutters shall be operated not less than once a week to
ensure that they remain in proper operating condition.
(d) The shutters shall operate at a speed not to exceed 30
ft/min (0.15 m/s) and shall be equipped with a sensitive
leading edge.
(e) The leading edge shall arrest the progress of a moving
shutter and cause it to retract a distance of approximately 6
in. (150 mm) upon the application of a force not exceeding
20 lbf (90 N) applied to the surface of the leading edge.
(f)
The shutter, following the retraction specified in 8.6.9.7 (3)
(e), shall continue to close.
(g) The operating mechanism for the rolling shutter shall be
provided with standby power complying with the provisions
of NFPA 70 , National Electrical Code .
Statement of Problem and Substantiation for Public Comment
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This comment is on CI 2.The issues associated with allowing such openings to connect
several stories are related to fire behavior and other physical phenomena (i.e. stratification,
stack effect, etc.) and are not occupancy specific.
Submitter Information Verification
Submitter Full Name: Bill Galloway
Organization:
Submittal Date:
Southern Regional Fire Code De
Tue Mar 12 13:47:02 EDT 2013
Copyright Assignment
I, Bill Galloway, 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 Bill Galloway, 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. 83-NFPA 101-2013 [ New Section after
A.8.2.3.1 ]
A.8.2.3.1.3. NFPA 251, ANSI/UL 263, and ASTM E119 are nationally recognized
methods of determining fire resistance of building elements and assemblies.
Assemblies tested in accordance with these fire-resistance test standards provide
passive fire protection as a system. The test procedures set forth in these standards
make no provision for testing fire resistance rated assemblies and systems washed
with water from a n automatic fire suppression systems or water sprays in vertical or
horizontal furnaces. As such, it is not possible to assign a fire resistance rating. Such
evaluations can only be done via the Equivalency language in Section 1.4 or
evaluation as a performance-based option in Chapter 5.
Statement of Problem and Substantiation for Public Comment
This is proposed annex language for the newly proposed Section 8.2.3.1.3.
Submitter Information Verification
Submitter Full Name: Catherine Stashak
Organization:
Office of the Illinois State Fire Marshal
Submittal Date:
Fri Apr 26 12:27:32 EDT 2013
Copyright Assignment
I, Catherine Stashak, 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 Catherine Stashak, 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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