Trying To Tweak The Code
Mark Bromann
Your chances of passing an NFPA 13 code amendment is increased greatly if you have someone in your corner.
The last several pages of any current NFPA pamphlet contain forms to submit amendment proposals. The various NFPA Technical Committees welcome these proposals.
Chronologically, there is a call for proposals, followed by initial committee meetings, a committee vote, then a published Report on Proposals (ROP), which methodically lists every detail regarding the proposed code changes. After further meetings, there comes a published supplementary report, another vote at the NFPA annual meeting, an appeals process, and, finally, an official decision by the Standards Council on whether to adopt and issue the new standard as amended.
The ROP meetings for the current NFPA 13 (2002) edition were conducted between January and April of 2001, in which approximately 400 proposals were reviewed and discussed. As you might expect, many proposals were concerned with nomenclature and wording particulars that were not as definitive, precise or comprehensive as someone desired. While the goal is not to fatten the code, its magnitude will grow in congruence with the desire for exactitude.
While I do not claim to have the entire NFPA 13 volume totally mastered or committed to memory, I am quite familiar with its contents and have been an NFPA member for years. So after 20-plus years in the business, I decided to propose what I considered to be two plausible NFPA 13 code amendments for consideration way back in 2000. All proposals must include a recommendation followed by a written substantiation for the change. Since the substantiation is limited to 200 words, I revised these proposals and added a third. Here's my first proposal:
This was all published later, in the May 2002 ROP, with these added notes:
The ROP also mentioned that my proposed code addition was defeated by a vote of 27-0. I was a little confused by the committee statement, since flushing connections are required by NFPA 13, with rules governing their installation outlined in three chapters. Sections 8.14.16.1-2 currently read as follows: “All sprinkler systems shall be arranged for flushing. Readily accessible fittings shall be provided at the end of all cross mains.” (FYI, a submitter is not notified of any committee actions until the ROP report is published.)
Here's my second proposal:
While 15 ft. is an arbitrary figure, it is closely appropriate considering general outside atmospheric conditions of differing climates. A sprinkler would either be inoperable if installed at a higher distance, or be of ineffective response time. And the higher the overhang, the less likely it is that products will be stored below. Requiring the protection at elevations less than 15 ft. would provide for a greater level of protection than the 10-ft. limitation noted in the 13-R section (2-4.5.6 exception) that is also concerned with anticipated sprinkler sensitivity. And certainly, if the overhang is, say, 40 ft. off the ground, then the requirement for sprinkling beneath the roof overhang would be an unnecessary part of the standard in that instance.
(This wordy substantiation, by the way, fell a few words shy of the 200-word limit.)
Like the first, this proposal was rejected 27-0. First of all, I am sure that the committee has previously reviewed mountains of test data regarding sprinkler response time, indoors and out. Secondly, the way the code is currently scripted, a fire sprinkler contractor is required to install fire sprinklers (see NFPA 13-2002: 8.14.7) beneath exterior combustible balconies, decks and similar projections that extend over 48 inches from the building, even if they extend from the 10th floor. That 10th-floor sprinkler, incidentally, will never discharge water unless it is clipped by the wing of a small airplane.
Without some cogent editing, the code is a little silly as written in this section. Recognizing this, some measure surely needs to be taken.
My third proposed amendment (exceedingly wordy, and also defeated 27-0) hoped to eliminate the redundant requirement that a backflow preventer be installed upstream of an electric fire pump, where the pump and bypass configuration begins.
In such a situation, fire sprinkler system water would have to already backflow through two or three check valves, and/or a pump impeller, so the need for additional “double-check” backflow prevention is unnecessary.
Compounding that impracticality, you have 1) added costs; 2) additional friction loss; and 3) mechanical operative problems down the road due to pockets of air repeatedly entering the pump casing area - causing turbulence and possible damage to the motor. So what in the world is a backflow preventer doing there?
This should be of vital concern to the NFPA, but it's not. I'll tell you right now what would eliminate a boatload of problems, if NFPA 13 included the following wording: “for the purposes of this standard, two listed and approved check valves, joined together, are to be considered an acceptable backflow prevention device.”
This would be of particular benefit in smaller and/or residential systems, where the inclusion of a backflow preventer drives system costs through the roof, while providing a lessened degree of fire safety for occupants due to its pressure-restricting characteristics.
While there is some indecision among NFPA committee members with regard to the backflow quagmire, the lion's share does not want to conflict with state plumbing codes. They feel that it's not their jurisdiction. In my view, this gutless approach is dubious, considering the fact that countless problems have been caused, and millions of dollars wasted, by erratic and confusing backflow prevention retrofit statutes scripted by bureaucrats instead of engineers.
Confusion has run amok, and that bodes badly for the fire protection industry. A paragraph on the back cover of NFPA 13 states, “the users of this document should consult applicable federal, state, and local laws … NFPA does not, by publication of this document, intend to urge action that is not in compliance with applicable laws.” What this statement bypasses is the fact that NFPA 13 is already the adopted and enacted legislation in most jurisdictions.
Politics
I do talk with NFPA 13 committee members from time to time, so over the last couple of years I have been able to obtain some enlightenment with regards to the NFPA code proposal process.
First of all, all proposals are available to be read by committee members prior to the initial meetings, where the committee breaks up into code section subcommittees. After some review and commentary, they bring everything back to the congregated technical committee for any further discussion that may be warranted and vote. With hundreds of proposals to be heard, this all takes about three days.
The time taken during meetings for proposal discussion varies greatly depending on the particular change submitted. My three proposals, apparently, required no serious or lengthy discussion. Some committee members wondered aloud who the heck I was.
What I know now is that chances for passing an NFPA 13 code amendment is increased greatly if you have a proponent on the committee - someone who shows special interest, and who encounters no vocal opposition. Without a rallying committee member behind a new proposal, any such change proffered is likely to be dismissed with comments like “we've ruled on this in the past and we're not going to change now,” or “this is implied somewhere else in the standard,” or “an AHJ can waive this.”
The latter comment, of course, assumes that the average fire inspector knows what he's doing and has experienced a substantial amount of formal training.
The process of fire protection code-amending is strikingly similar to what you would encounter if submitting an ordinance change to any large American city. The common denominator being that it almost takes a major lobbying effort by the submitter with someone who sits on a committee prior to the actual formal meetings, in order for proactive change to be accomplished. In reality, what actually is proposed and sticks is most frequently what is proposed by the committee members themselves.
It's hard to sort out all the implications when you've put three sensible code revisions up for a vote only to have them all defeated by a resounding margin. However, it's not the purpose of this brief dissertation to desist you in any way from submitting your own code change amendment during the next forthcoming NFPA 13 (or 15, 24, 72, etc.) revision cycle. It is a privilege to be able to do so. And nothing is going to change without a submitted proposal.
The technical committees are made up of experienced, informed and well-regarded fire protection professionals. In fire protection engineering jargon, there are probably more “code guys” on the committee than “design guys,” so make sure that you adopt an exacting language similar to what is already in the code. Stick with the code structure. Be concise and clear, and make sure that what you're submitting is not already covered in the code. And a little politicizing can't hurt.
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